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                                    U.S. NUCLEAR REGULATORY COMMISSION
U.S. NUCLEAR REGULATORY COMMISSION
                                                    REGIONlli
REGIONlli
                          Docket Nos.         50-282; 50-306
Docket Nos.
                          License Nos.         DPR-42; DPR-60
50-282; 50-306
                          Report No.           5(. 482/97023(DRP); 50-306/97023(DRP)
License Nos.
                          Licensee:             Northem States Power Company                               .
DPR-42; DPR-60
                          Facility:           Prairie Island Nuclear Generating Plant
Report No.
                          Location:           1717 Wakonade Drive East
5(. 482/97023(DRP); 50-306/97023(DRP)
                                              Welch, MN 55089
Licensee:
                          Dates:               December 3,1997, through January 13,1998
Northem States Power Company
                          Inspectors:         S. Ray, Senior Resident inspector
.
                                              P. Krohn, Resident inspector
Facility:
                                              S. Thomas, Resident inspector
Prairie Island Nuclear Generating Plant
                          Approved by:         J. W. McCormick-Barger, Chief
Location:
                                              Reactor Projects Branch 7
1717 Wakonade Drive East
                9002120155 900130
Welch, MN 55089
                PDR ADOCK 05000282
Dates:
                G                 PDR
December 3,1997, through January 13,1998
                                                                                        - - _ _ _ _ _ - _ _
Inspectors:
S. Ray, Senior Resident inspector
P. Krohn, Resident inspector
S. Thomas, Resident inspector
Approved by:
J. W. McCormick-Barger, Chief
Reactor Projects Branch 7
9002120155 900130
PDR
ADOCK 05000282
G
PDR
- - _ _ _ _ _ - _ _


                                      -_____                         __ _ _ - _ _ _ _ - _ _ - _ _ _ _ _ __ -________ - -______-___ _ ___ - _ _.
-_____
l-       n e
__ _ _ - _ _ _ _ - _ _ - _ _ _ _ _ __ -________ - -______-___ _ ___ - _ _.
  o _, s
l-
n e
o _, s
L
L
l
l
                                                        EXECUTIVE SUMMARY
EXECUTIVE SUMMARY
                                          Prairie Island Nuclear Generating Plant, Units 1 & 2
Prairie Island Nuclear Generating Plant, Units 1 & 2
                              NRC Inspection Report No. 50-282/97023(DRP); 50-306/97023(DRP)
NRC Inspection Report No. 50-282/97023(DRP); 50-306/97023(DRP)
              This inspection included aspects of licensee operations, maintenance, engineering, and plant
This inspection included aspects of licensee operations, maintenance, engineering, and plant
              support. The report covers a six-week period of resident inspection.
support. The report covers a six-week period of resident inspection.
              fioerations
fioerations
              *       Management expectations and procedures for conduct in the control room, such as those
*
                      delineating the frequency and completeness of main control board walkdowns, were not
Management expectations and procedures for conduct in the control room, such as those
                      always clear, in addition, first line supervisors did not always enforce those procedures
delineating the frequency and completeness of main control board walkdowns, were not
                      that were clear, such as those relating to communications and control room access
always clear, in addition, first line supervisors did not always enforce those procedures
                      (Section 01.1),
that were clear, such as those relating to communications and control room access
              o      Unit i startup operations from the refueling outage were generally conducted well with no
(Section 01.1),
                      significant problems. Procedures were followed and operators remained attentive to
Unit i startup operations from the refueling outage were generally conducted well with no
                      plant indications during plant mode changes (Section 01.2).
o
              *      One instance occurred during the Unit 1 startup where an operator did not verify that an
significant problems. Procedures were followed and operators remained attentive to
                      annunciator (the ROD AT BOTTOM annunciator) had cleared in a timely manner.
plant indications during plant mode changes (Section 01.2).
                      Although this error was not safety significant, it emphasized the need for improvements in
One instance occurred during the Unit 1 startup where an operator did not verify that an
                      procedure organization and for further evaluation of procedure use expectations
*
                      (Section 01.2).
annunciator (the ROD AT BOTTOM annunciator) had cleared in a timely manner.
              *      Following the retum to full power operations after the Unit i refueling outage, power was
Although this error was not safety significant, it emphasized the need for improvements in
                      reduced to 5 percent to allow balancing of the main turbine. Control room activities for
procedure organization and for further evaluation of procedure use expectations
                      the power reduction, turbine balancing, and retum to full power were conducted well
(Section 01.2).
                      (Section 01.3).
Following the retum to full power operations after the Unit i refueling outage, power was
                                                                                                                                                                                                .
*
              o      During a walkdown of the Unit 2 containment spray and caustic addition systems, the
reduced to 5 percent to allow balancing of the main turbine. Control room activities for
                      inspectors found the systems properly lined-up and ready for safeguards operation. No
the power reduction, turbine balancing, and retum to full power were conducted well
                      significant material discrepancies or system deficiencies were identified that would
(Section 01.3).
                      prevent either system from performing its intended function (Section O2.1).
.
              Ma'ntenance
During a walkdown of the Unit 2 containment spray and caustic addition systems, the
                e      Operators involved in maintenar.ce and surveillance activities displayed a good
o
                        questioning attitude and appreciation of radiation dose control (Section M1.1).
inspectors found the systems properly lined-up and ready for safeguards operation. No
                *      A good questioning attitude by an operator resulted in identification of an inadequacy in a
significant material discrepancies or system deficiencies were identified that would
                        procedure for main turbine torsional testing. However, the initial review of the operator's
prevent either system from performing its intended function (Section O2.1).
                        concem by engineering was poor, and the concem was not validated until the test was
Ma'ntenance
                        started and equipment did not respond as expected (Section M1.1).
Operators involved in maintenar.ce and surveillance activities displayed a good
                e      The inspectors identified that a physics testing procedure had not been followed in that
e
                        the amount of reactor coolant system temperature change called for la the procedure was
questioning attitude and appreciation of radiation dose control (Section M1.1).
                        not accomplished (Section M1.2).
A good questioning attitude by an operator resulted in identification of an inadequacy in a
                                                                    2
*
                                                                                                                                                _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
procedure for main turbine torsional testing. However, the initial review of the operator's
concem by engineering was poor, and the concem was not validated until the test was
started and equipment did not respond as expected (Section M1.1).
The inspectors identified that a physics testing procedure had not been followed in that
e
the amount of reactor coolant system temperature change called for la the procedure was
not accomplished (Section M1.2).
2
_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _


    . w e
. w e
  ns
ns
          e     The inspectors identified several minor deficiencies in the surveillance Mures for
e
                  operational pressure test inspections of the cooling water system (Section M3.1).
The inspectors identified several minor deficiencies in the surveillance Mures for
            Ennineerino
operational pressure test inspections of the cooling water system (Section M3.1).
          e      System engineers were heavily involved with all asper:ts of operations, maintenance, and
Ennineerino
l                 testing of their systems. The engineers rapidly investigeled any operational
System engineers were heavily involved with all asper:ts of operations, maintenance, and
                  abnormatities, took an active role in maintenance and troubleshooting activities, and
e
                  closely followed alt surveillance testing on the',r systems; however, in one instanca, during
l
                  turt>lne torsional testing, a system enginser did net provide adequate technical support
testing of their systems. The engineers rapidly investigeled any operational
                  (Section E2.2).
abnormatities, took an active role in maintenance and troubleshooting activities, and
          *      Recer:< findings by tne engineering orgsnization involving the control room ventilation
closely followed alt surveillance testing on the',r systems; however, in one instanca, during
                  system and a 10 CFR Part 50, Appendix R issue regarding inadequate separation of
turt>lne torsional testing, a system enginser did net provide adequate technical support
                  pressurizer level cables indicated that thorough design reviews were being conducted
(Section E2.2).
                  and reflected a wi'lingness to Idantify and resolve old jesign and compliance issues
Recer:< findings by tne engineering orgsnization involving the control room ventilation
                  (Section E3.1).
*
          Plant Sucoort
system and a 10 CFR Part 50, Appendix R issue regarding inadequate separation of
          e      Good involvemeM of radiatk,n protection personnel in job p'- aning and execution in order -
pressurizer level cables indicated that thorough design reviews were being conducted
                  to rnaintain low ooses was observed, as exemplified by the involvement of radiation
and reflected a wi'lingness to Idantify and resolve old jesign and compliance issues
                  protection personnel with operators during performance of a reactor coolant system
(Section E3.1).
                  integrity test (Sections M1.1 and R1),
Plant Sucoort
          e      An old Appendix R compliance issue involving inadequate separation of pressurizer level
Good involvemeM of radiatk,n protection personnel in job p'- aning and execution in order -
                  cables was identified and rapidly corrected as a result of a proactive lic6nsee initiative
e
                  (Section F2.1).
to rnaintain low ooses was observed, as exemplified by the involvement of radiation
                                                              3
protection personnel with operators during performance of a reactor coolant system
              ,                                                             _
integrity test (Sections M1.1 and R1),
                                                                                          -
An old Appendix R compliance issue involving inadequate separation of pressurizer level
                                                                                                                _ _ _ _
e
cables was identified and rapidly corrected as a result of a proactive lic6nsee initiative
(Section F2.1).
3
,
_
-
_ _ _ _


                                                                                                -
-
                                                                                                                              .
.
                                                                                                                                -- . - . -
-- . - . -
        . - m ,
. - m ,
                                                                                                                                                                  l
%, < -
%, < -
'
'
                                                                                                                                                                  l
Report Details
;
;
                                                                        Report Details
i
i                Summary of Plant Status
Summary of Plant Status
                Unit 1 was restarted upon completion of a refueling outage on December 13,1997, and the
Unit 1 was restarted upon completion of a refueling outage on December 13,1997, and the
4                generator was placed on the grid for the first time on December 14. After extensive test 8ng of the
generator was placed on the grid for the first time on December 14. After extensive test 8ng of the
                newly installed turbines, the b,'.it reached full power on December 19. Power on Unit 1 was
4
                reduced to about 5 percent on January g,1998, and the generator was taken off line in order to                                                 !
newly installed turbines, the b,'.it reached full power on December 19. Power on Unit 1 was
reduced to about 5 percent on January g,1998, and the generator was taken off line in order to
!
accomplish turbine balancing. The generator was placed back on line January 10 and the unit
*
*
                accomplish turbine balancing. The generator was placed back on line January 10 and the unit
retumed to full power on January 11. Unit 2 operated at or near full power for the entire
                retumed to full power on January 11. Unit 2 operated at or near full power for the entire
inspection period.
                inspection period.
!'
!'                                                                       l. Operations
l. Operations
                01     Conduct of Operations                                                                                                                 i
01
                01.1   General Comments
Conduct of Operations
                  a.   inspection Scoce (71707. g2901)
i
:                        The inspectors conducted frequent reviews of plant operations. The inspectors
01.1
                        performed observations in the control room for extended periods and focused on shift
General Comments
a.
inspection Scoce (71707. g2901)
The inspectors conducted frequent reviews of plant operations. The inspectors
:
performed observations in the control room for extended periods and focused on shift
;
tumovers, prejob briefs, communications, control room access control, logkeeping,
control boarc monitoring, and general control room decorum. Section 13. "P%nt
;
;
                        tumovers, prejob briefs, communications, control room access control, logkeeping,
Operations," of the Updated Safety Analysis Report (USAR) was reviewed as part of the
                        control boarc monitoring, and general control room decorum. Section 13. "P%nt                                                          ,
,
;                        Operations," of the Updated Safety Analysis Report (USAR) was reviewed as part of the
inspection.
-
-
                        inspection.                                                                                                                            ;
;
                  b.   Observations and Findinas
b.
Observations and Findinas
'
The inspectors noted that shift tumovers were usually good, covering the status of both
;
units, on-going maintenance and evolutions, and other specific instructin1s for the safe
~
operati sn of the units. However, on two occasions operators arrived late for the moming
control qum shift tumover briefing, missing significant portions of the information -
'
'
'
                        The inspectors noted that shift tumovers were usually good, covering the status of both                                                ;
;
                                                                                                                                                                ~
presented.
                        units, on-going maintenance and evolutions, and other specific instructin1s for the safe
The inspectors observed numerous projob briefs, including briefs for int < rated safety
                        operati sn of the units. However, on two occasions operators arrived late for the moming                                              '
injection testing, Unit i reactor startup, Unit i reactor physics testing, and Unit i turbine
'
'
                        control qum shift tumover briefing, missing significant portions of the information -
;-
;                        presented.
overspeed and torsional testing. Generally, the briefs were concise, but thorough. The
                        The inspectors observed numerous projob briefs, including briefs for int < rated safety
inspectors noted that the use of formal communications, the slow and cot trolled conduct
                        injection testing, Unit i reactor startup, Unit i reactor physics testing, and Unit i turbine                                          '
,
;-                      overspeed and torsional testing. Generally, the briefs were concise, but thorough. The
of the evolution, and reactor safety were common issues stressed in each brief. No
,                        inspectors noted that the use of formal communications, the slow and cot trolled conduct
L
                        of the evolution, and reactor safety were common issues stressed in each brief. No
specific discrepancies were noted.
L                       specific discrepancies were noted.
The inspectors observed operator commu,,ications during numerous evolutions including
                        The inspectors observed operator commu,,ications during numerous evolutions including
both routine and noteroutine operations. While communications were deemed adequate,
                        both routine and noteroutine operations. While communications were deemed adequate,
they rer.ged from excellent to poor, depending on the evolution in progress and/or crew
'
'
                        they rer.ged from excellent to poor, depending on the evolution in progress and/or crew
ob. served. Specific observations included:
                        ob. served. Specific observations included:
:
                                                                                                                                                                :
l-
l-                       e       - the consistency with which formal ccmmunications were used varied from crew to
e
                                    crew;
- the consistency with which formal ccmmunications were used varied from crew to
                                                                                        4
crew;
4
i
i
.                                                                                                                                                               .
.
.
6
6
  ,..,-o                   ,---,,e         -,w- --,yw ..,-.v- ,,,- ----m,n,w--nne.,n,--   y - , ma-g-y-, y-n,y,-,ne-w w~,,ow,             . - - , . 7, yp p r
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_
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      . w c
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  *qs
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                                                                                                          ,
,
            e      formal communications tended to be used more frequently during planned
formal communications tended to be used more frequently during planned
                    evolutions, such as reactor startups, but less frequently during abnormal operaHng
e
                    situations; and
evolutions, such as reactor startups, but less frequently during abnormal operaHng
            e       communications in the plant were generally not ab formal as those in the
situations; and
                    simulator.
e
            During tl o extended periods of control room obscrvation, the inspectors monitorea how
communications in the plant were generally not ab formal as those in the
            control ri cm access was managed. Section Work Instruction (SWI) 0 2, ' Shift
simulator.
            Organta tion, Operatica, and Tumover," Revision 38, stated that the 'thift supervisor (SS)
During tl o extended periods of control room obscrvation, the inspectors monitorea how
            *shall be responsible for maintaining control of personnel entering the control room" and
control ri cm access was managed. Section Work Instruction (SWI) 0 2, ' Shift
            the lead plant equipment and reactor operator (LPE&RO) shall be responsible for
Organta tion, Operatica, and Tumover," Revision 38, stated that the 'thift supervisor (SS)
            " granting permission to non-operations personnel for entry Ido the control room."
*shall be responsible for maintaining control of personnel entering the control room" and
            Implementation of those aspects of SWI O 2 was poor. Specific discrepancies noted in
the lead plant equipment and reactor operator (LPE&RO) shall be responsible for
            the control of controt room af4:ss were:
" granting permission to non-operations personnel for entry Ido the control room."
            e       on numerot.s occasions, instrument and control technicians entered the control
Implementation of those aspects of SWI O 2 was poor. Specific discrepancies noted in
                    area boundaries within the control room and approached control panelt without
the control of controt room af4:ss were:
                    first obtaining permission and/or informing the LPE&RO of their reason for doing
e
                    so; and                                                                                 4
on numerot.s occasions, instrument and control technicians entered the control
            e      on several occasions, personnel entered the control area of the control room and
area boundaries within the control room and approached control panelt without
                    approached control panels wecring hard hats even though there was a si-ln,
first obtaining permission and/or informing the LPE&RO of their reason for doing
                    located at the entry to the control area, which stated that hard hats were not
so; and
                    allowed beyond that point.
4
            The inspectors observed control room operators during the performance of routine log
on several occasions, personnel entered the control area of the control room and
            taking and control board monitoring. The inspectors considered the Operations Log and
e
            the individual Unit 1 and Unit 2 Reactor Logs to be an accurate accounting of shift events
approached control panels wecring hard hats even though there was a si-ln,
            and noted that relevaret shift information was consistently logged. The Inspectors could
located at the entry to the control area, which stated that hard hats were not
            find no specific uperator guidance, nor could any be provided by the poneral
allowed beyond that point.
            superintendent of operations, on the frequency that it.e control berds should be " walked
The inspectors observed control room operators during the performance of routine log
            down." Control board monitoring was considered adequate, but me time between
taking and control board monitoring. The inspectors considered the Operations Log and
            walkdowns varied widely from crew to crew. Specific discrepancies noted in control
the individual Unit 1 and Unit 2 Reactor Logs to be an accurate accounting of shift events
            board monitoring were:
and noted that relevaret shift information was consistently logged. The Inspectors could
              o      the continuous monitoring of control boards exhibited by operators participating in
find no specific uperator guidance, nor could any be provided by the poneral
                      graded simulator scenarios was not observed in the main control room;
superintendent of operations, on the frequency that it.e control berds should be " walked
              e      during one of the inspectors' control room tours, the inspectors noted that over a
down." Control board monitoring was considered adequate, but me time between
                      two hour period of time, the only time the Unit 1 panels were walked down was
walkdowns varied widely from crew to crew. Specific discrepancies noted in control
                      when the hourly logs were taken;
board monitoring were:
              e      annunciators were frequently silenced and acknowledgod by a single operator
the continuous monitoring of control boards exhibited by operators participating in
                      without announcing to other control room personnel what the alarm was and the
o
                      reasoa for the alarm; and
graded simulator scenarios was not observed in the main control room;
              e       the inspectors identified tht.t incorrect work order numbers were referred to in one
during one of the inspectors' control room tours, the inspectors noted that over a
                      reactor log entry. When identified, th SS corrected the log entry.
e
                                                          5
two hour period of time, the only time the Unit 1 panels were walked down was
when the hourly logs were taken;
annunciators were frequently silenced and acknowledgod by a single operator
e
without announcing to other control room personnel what the alarm was and the
reasoa for the alarm; and
e
the inspectors identified tht.t incorrect work order numbers were referred to in one
reactor log entry. When identified, th SS corrected the log entry.
5


                                                                    _
_
        . .. ,
. .. ,
  *yi
*yi
'
'
                      The inspec* ors observed the overall control roor.1 decorum during evolutions which
The inspec* ors observed the overall control roor.1 decorum during evolutions which
                      ranged from complex to routine. The inspectors gens, ally categorized the overall
ranged from complex to routine. The inspectors gens, ally categorized the overall
                      atmosphere as relaxed, but professional. The appropriate level of conoom and
atmosphere as relaxed, but professional. The appropriate level of conoom and
                      supervisory oversight was demonstrated during complex and Infrequently performed
supervisory oversight was demonstrated during complex and Infrequently performed
                      evo;utions. The SSs and shift managers generally handled administrative matters,
evo;utions. The SSs and shift managers generally handled administrative matters,
                      leaving the other control room operators free to monitor and t,ontrol 6ach Unit's operation.
leaving the other control room operators free to monitor and t,ontrol 6ach Unit's operation.
                      The inspectors noted that some activities detracted from a professional control room
The inspectors noted that some activities detracted from a professional control room
                      atmosphere, including:
atmosphere, including:
                      o       eating food and/or drinking beverages while , < rating components at a control
o
                              panel;
eating food and/or drinking beverages while , < rating components at a control
;                     e      inappropriate screen savers on the computer monitors in the control room;
panel;
                      e       extended discussions of toples not related to the operation of the plant; and
;
                      e       inappropricte material posted on the walls of the SS's area.
inappropriate screen savers on the computer monitors in the control room;
                c.   Conclusions
e
                      Management expectations and procedures for conduct in the control room, such as those
extended discussions of toples not related to the operation of the plant; and
                      delinteting the frequency and completeness of main control board walkdowns, were not
e
                      always clear. In addition, first line supervisors did not always enforce those procedures
e
                      that were clear, such as those relating to communications and control room access.
inappropricte material posted on the walls of the SS's area.
                      inconsistencies in performance between crews indicated the need for additional guidance
c.
                      and tialning in this area. The discrepancies discussed above did not lead to any unsafe
Conclusions
                      conditior,s or violations of NRC requirements. The plant manager informed the inspectors
Management expectations and procedures for conduct in the control room, such as those
                      that a revised section work instruction on control room access and other expectations
delinteting the frequency and completeness of main control board walkdowns, were not
                      was being developed.
always clear. In addition, first line supervisors did not always enforce those procedures
                01.2 Unit i Retum to.100 Percent Power Operation
that were clear, such as those relating to communications and control room access.
inconsistencies in performance between crews indicated the need for additional guidance
and tialning in this area. The discrepancies discussed above did not lead to any unsafe
conditior,s or violations of NRC requirements. The plant manager informed the inspectors
that a revised section work instruction on control room access and other expectations
was being developed.
01.2 Unit i Retum to.100 Percent Power Operation
,
,
                a.     inspection Scope (71707)
a.
                      The inspectors observed significant portions of operations leading from a refueling
inspection Scope (71707)
                        shutdown to 100 percent power operation on Unit 1. Major activities observed included:
The inspectors observed significant portions of operations leading from a refueling
                        e       integrated safety injection test;
shutdown to 100 percent power operation on Unit 1. Major activities observed included:
                        e      transition from Mode 5 to Mode 4 (Cold Shutdown to Intermediate Shutdown);
e
                        e     drawing a pressurizer bubble;
integrated safety injection test;
                        e      transition from Mode 4 to Mode 3 (Intermediate Shutdown to Hot Shutdown);
transition from Mode 5 to Mode 4 (Cold Shutdown to Intermediate Shutdown);
                        e     reactor stanup;
e
                        e     reactor physics testing;
e
                                                                  6
drawing a pressurizer bubble;
    .. .
transition from Mode 4 to Mode 3 (Intermediate Shutdown to Hot Shutdown);
                            ..     . . . . .                   .
e
                                                                      .
e
reactor stanup;
e
reactor physics testing;
6
.. .
..
. . . . .
.
.


                                                                                _               _ _ _ _ _ _ _ _ _ _ _ - _ -
_
      . > . .
_ _ _ _ _ _ _ _ _ _ _ - _ -
  ...<
. > . .
                e      transition from Mode 3 to 2 to 1 (Hot Shutdown to Hot Standby to Power
. . . <
                        Operation); and
transition from Mode 3 to 2 to 1 (Hot Shutdown to Hot Standby to Power
                e       turbine overspeed and torsional testing.
e
Operation); and
e
turbine overspeed and torsional testing.
i
i
                included in the startup observations was a review of the appropriate USAR sections and
included in the startup observations was a review of the appropriate USAR sections and
                operating procedures regarding the activities. The inspectors verified that Jpplicablu
operating procedures regarding the activities. The inspectors verified that Jpplicablu
                surveillance procedures performed as part of the startup met the requirements of the
surveillance procedures performed as part of the startup met the requirements of the
                Technical Specifications (TSF).
Technical Specifications (TSF).
              b. Observations and Findinat
b.
                For most of the evolutions observed, procedures were properly used and followed.
Observations and Findinat
                Operations personnel demonstrated experience and knowledge during the performance
For most of the evolutions observed, procedures were properly used and followed.
                of their tasks. Noteworthy comments on specific evolutions are discussed below.
Operations personnel demonstrated experience and knowledge during the performance
                  *      The inspectors attended the prejob brief and obse ved performance of
of their tasks. Noteworthy comments on specific evolutions are discussed below.
                          surveillance procedure SP 1063, * Unit 1 Irstegrated Safety injection Test With a
The inspectors attended the prejob brief and obse ved performance of
                          Simulated Loss of Offsite Power," Revision 24, from the control room and
*
                          emergency diesel generator rooms. The prejob brief was thorough and attended
surveillance procedure SP 1063, * Unit 1 Irstegrated Safety injection Test With a
                          by the plant manager who stressed proper command and control, personnel
Simulated Loss of Offsite Power," Revision 24, from the control room and
                          safety, nuclear safety, and equipment protection.
emergency diesel generator rooms. The prejob brief was thorough and attended
                  *      The inspectors observed good command, control, and coordination of activities
by the plant manager who stressed proper command and control, personnel
                          during the integrated safety injection test. The complex test required the
safety, nuclear safety, and equipment protection.
                          coordinated effort of many operations, engineering, and maintenance personnel to
The inspectors observed good command, control, and coordination of activities
                          establish the required test conditions and monitor system performance as the test
*
                          was performed,
during the integrated safety injection test. The complex test required the
                  e      The inspectors observed the prejob brief conducted prior to the Unit i reactor
coordinated effort of many operations, engineering, and maintenance personnel to
                          startup. Reactivity manegement, expected indications, and personnel roles and
establish the required test conditions and monitor system performance as the test
                          responsibilities were discussed. An extra reactor operator (RO) and SS, in
was performed,
                          addition to the normal crew complement, were assigned to perform the startup.
The inspectors observed the prejob brief conducted prior to the Unit i reactor
                          Other plant activities and distractions were kept to a minimum. Nuclear
e
                          engineering personnel were also present and perform 3d independent verifications
startup. Reactivity manegement, expected indications, and personnel roles and
                          of reactivity management as the startup progressed.
responsibilities were discussed. An extra reactor operator (RO) and SS, in
                          The inspectors observed the withdrawal of the control banks and dilution to
addition to the normal crew complement, were assigned to perform the startup.
                          criticality. The SS and RO remained attentive to reactor power ievels and startup
Other plant activities and distractions were kept to a minimum. Nuclear
                          rate iridications throughout the reactor startup. However, after control
engineering personnel were also present and perform 3d independent verifications
                          bank A rods had been withdrawn to 129 steps, the RO noticed that tr,e ROD AT
of reactivity management as the startup progressed.
                          BOTTOM annunciator had not cleared. The reactor operator drove bank A rods
The inspectors observed the withdrawal of the control banks and dilution to
                          to O steps and a work order was issued to investigate the cause of the
criticality. The SS and RO remained attentive to reactor power ievels and startup
                          annunciator not clearing at 20 steps as expected. it was deteImined that the
rate iridications throughout the reactor startup. However, after control
                            pulse to-analog bistable for control bank D had failed causing the ROD AT
bank A rods had been withdrawn to 129 steps, the RO noticed that tr,e ROD AT
                            BOTTOM annunciator to remain energized (the position of rods in all four of the
BOTTOM annunciator had not cleared. The reactor operator drove bank A rods
                            control banks input into the logic for the annunciator).
to O steps and a work order was issued to investigate the cause of the
                                                                7
annunciator not clearing at 20 steps as expected. it was deteImined that the
                      .                                                 .
pulse to-analog bistable for control bank D had failed causing the ROD AT
                                                                                          _
BOTTOM annunciator to remain energized (the position of rods in all four of the
control banks input into the logic for the annunciator).
7
.
.
_


  . . . .
. . . .
3i
3i
                        Operating Procedure 1C1.2, " Unit i Startup Procedure," Revision 18, Step 5.5.0,
Operating Procedure 1C1.2, " Unit i Startup Procedure," Revision 18, Step 5.5.0,
                        instructed the reactor operator to startup the reactor per Appendix C18, " Appendix
instructed the reactor operator to startup the reactor per Appendix C18, " Appendix
                        - Reactor Startup," Revirion 6. Appendix C1B was intended to be an aid to the
- Reactor Startup," Revirion 6. Appendix C1B was intended to be an aid to the
                        RO for conducting the startup and was not required to be "in-hand' during the
RO for conducting the startup and was not required to be "in-hand' during the
                        actual startup evolution since the operator's attention should be focussed on the
actual startup evolution since the operator's attention should be focussed on the
                        control board. Step 5.2.2.C of Appendix C18, required th;; RO to verify that the
control board. Step 5.2.2.C of Appendix C18, required th;; RO to verify that the
                        ROD AT BOTTOM annunciator (47013-0407) cleared with bank A control rods at
ROD AT BOTTOM annunciator (47013-0407) cleared with bank A control rods at
                        appro41mately 20 steps during the reactor startup. The RO did not perform that
appro41mately 20 steps during the reactor startup. The RO did not perform that
                        verification until the control bank A rods had reached 129 steps.
verification until the control bank A rods had reached 129 steps.
                        Technical Specification 6.5.A.1 required that detailed written procedures for
Technical Specification 6.5.A.1 required that detailed written procedures for
                        normal startup of the reactor be prepared and followed. On December 12,1997,
normal startup of the reactor be prepared and followed. On December 12,1997,
                        Operating Procedure C18, * Appendix Reactor Startup," Revision 6, Step 5.2.2.C,
Operating Procedure C18, * Appendix Reactor Startup," Revision 6, Step 5.2.2.C,
                        was not followed wnen the RO did not verify that the ROD AT BOTTOM
was not followed wnen the RO did not verify that the ROD AT BOTTOM
                          annunciator cleared when rod bank A was withdrawn to approximately 20 steps.
annunciator cleared when rod bank A was withdrawn to approximately 20 steps.
                          The RO later identified that the annunciator h::J not cleared when he stopped
The RO later identified that the annunciator h::J not cleared when he stopped
                          moving bank A rods at 129 steps. The event was not stafety significant and only
moving bank A rods at 129 steps. The event was not stafety significant and only
                          resulted in an equipment problem not being identified as soon as it could have
resulted in an equipment problem not being identified as soon as it could have
                          been. The general superintendent of operations was reevaluating the reactor
been. The general superintendent of operations was reevaluating the reactor
                          startup procedure and c.onsidering adding hold points to refer to the procedure
startup procedure and c.onsidering adding hold points to refer to the procedure
                          and conduct the various verifications rather than expect the RO to remember the
and conduct the various verifications rather than expect the RO to remember the
                          entire C1B Procedure. This non-repetitive, licensee luentified and corrected
entire C1B Procedure. This non-repetitive, licensee luentified and corrected
                          violation is being treated as a Non-C;ted Violation, consistent with Section Vll.B.1
violation is being treated as a Non-C;ted Violation, consistent with Section Vll.B.1
                          of the NRC Enforcement Policy (50 282/97023-01(DRP)).
of the NRC Enforcement Policy (50 282/97023-01(DRP)).
            c.   Conclusions
c.
                Unit i startup operations were generally conducted well with no significant problems.
Conclusions
                Procedures were followed and operators remained attentive to plant indications during
Unit i startup operations were generally conducted well with no significant problems.
                plant mode changes. The ROD AT BOTTOM annunciator cleared verification
Procedures were followed and operators remained attentive to plant indications during
                requirement in Appendix C1B, Step 5.5.8.C, which should have been performed at
plant mode changes. The ROD AT BOTTOM annunciator cleared verification
                approximately 20 steps on control bank A, was not performed until 129 steps, primarily
requirement in Appendix C1B, Step 5.5.8.C, which should have been performed at
                because the procedure was not required to be in-hand during the actual startup evolution.
approximately 20 steps on control bank A, was not performed until 129 steps, primarily
                This error emphasized the need for improvements in pocedure organization and further
because the procedure was not required to be in-hand during the actual startup evolution.
                evaluation of procedure use expectations. The licensee was evaluating possible
This error emphasized the need for improvements in pocedure organization and further
                improvements.
evaluation of procedure use expectations. The licensee was evaluating possible
          01.3 Unit 1 Power Reduction for Turbine Balancina and Retum to Fu!! Power Operatim
improvements.
            a,   Inspection Scope f71707)
01.3 Unit 1 Power Reduction for Turbine Balancina and Retum to Fu!! Power Operatim
                The inspectors observed significant portions of the Unit 1 power reduction frura
a,
                  100 percent to approximately 5 percent power, the turbine balancing evolution, and the
Inspection Scope f71707)
                  subsequent retum to 100 percent power operation conducted from January 9 to
The inspectors observed significant portions of the Unit 1 power reduction frura
                  January 11,1998,
100 percent to approximately 5 percent power, the turbine balancing evolution, and the
            b.   Observations and Findinas
subsequent retum to 100 percent power operation conducted from January 9 to
January 11,1998,
b.
Observations and Findinas
The power reduction from 100 percent to 5 percent power was conducted very well. The
*
*
                  The power reduction from 100 percent to 5 percent power was conducted very well. The
inspectors observed excellent communications between all operating crew personnel,
                  inspectors observed excellent communications between all operating crew personnel,
8
                                                              8
.
    .   .     .
.
                                  ..           .
.
                                                    .
..
                                                                        _ - - - .
.
.
_ - - - .


  ._. -. . . .                   _ - - - -             .   -- -               -   - - -__       - . . - _ - - . . - - - -.-
._. -. . . .
            . ... o
_ - - - -
: ,. .                                                                                                                         ;
.
                                                                                                                              1
-- -
-
- - -__
- . . - _ - - . . - - - -.-
. . .
.
o
: ,. .
;
;
                          both inside and outside the control room. The RO and LPE&RO malntained good control
both inside and outside the control room. The RO and LPE&RO malntained good control
                          of the plant and awareness of plant parameters, and frequently kept each other informed
of the plant and awareness of plant parameters, and frequently kept each other informed
                          of changes in these parameters as indicated on the control room panels. The LPE&RO
of changes in these parameters as indicated on the control room panels. The LPE&RO
                          executed the require!.ients specified in the Unit 1 power reduction (101.4, " Unit 1 Power
executed the require!.ients specified in the Unit 1 power reduction (101.4, " Unit 1 Power
                          Operation,' Revision 15) and shutdown (1C1.3, * Unit i Shutdown,' ."evision 38)
Operation,' Revision 15) and shutdown (1C1.3, * Unit i Shutdown,' ."evision 38)
procedures without error and effectively planned ahead to begin mwntenance activities at
'
'
                          procedures without error and effectively planned ahead to begin mwntenance activities at
the earliest appropriate opportunity The SS maintained overall cognizance of the power
                          the earliest appropriate opportunity The SS maintained overall cognizance of the power
reduction evolution, appropriately observing selected actions of the operators.
                          reduction evolution, appropriately observing selected actions of the operators.
4
4
                          A second operating crew was observed performing the turbine stariup after the balanc!ng.
A second operating crew was observed performing the turbine stariup after the balanc!ng.
                          Again, excellent communications and plant control were exhibited. Procedures were
Again, excellent communications and plant control were exhibited. Procedures were
                          property implemented and the activities were closely supervised. The LPE&RO
property implemented and the activities were closely supervised. The LPE&RO
                          controlling the turbine kept the RO closely informed of any changes that could affect the
controlling the turbine kept the RO closely informed of any changes that could affect the
                          reactor. The LPE&RO was also observed correcting a system engineer when the
reactor. The LPE&RO was also observed correcting a system engineer when the
                          engineer failed to use three way communications over the radio,
engineer failed to use three way communications over the radio,
                      c. Conclusions
c.
Conclusions
'
'
                          The Unit 1 power reduction, turbine balancing, and retum to full power were conducted
The Unit 1 power reduction, turbine balancing, and retum to full power were conducted
                          well. Significant improvements were noted c.ompared to the control room etservations
well. Significant improvements were noted c.ompared to the control room etservations
                          desensed in Section 01.1 of this report.
desensed in Section 01.1 of this report.
                    02   Operational Status of Facilities and Equipment
02
                    O2.1 Engineered Safety System Walkdown
Operational Status of Facilities and Equipment
                      a.   Inspection Scope (71707)
O2.1 Engineered Safety System Walkdown
                          The inspectors performed a walkdown of the Unit 2 containment spray and caustic
a.
Inspection Scope (71707)
The inspectors performed a walkdown of the Unit 2 containment spray and caustic
addition systems as part of the monthly inspections of the Unit 2 engineered safety
-
syt,tems. Included in this inspection was a review of USA't, Section 6.4, * Containment
Vessel Internal Spray," Revision 14, and the following diagram::
NF 39252, " Flow Diagram Unit 1 & 2 Caustic Addition System," Revision N;
*
e
NF 39824, " Containment Intemal Spray System Units 1 & 2," Revision B;
e
NF 39237, * Flow Diagram, Containment Internal Spray System," Revision AB; and
NF 393331, * Reactor Safety injection ar'i Containment Spray Piping-Unit 2,"
*
-
Revision R.
b.
Observations and Findinas
The inspectors noted that the valves in the main system f'tw paths were in the correct
position, components were properly labeled, locking devices were present and properly
installed, and that power supplies and breakers were properly aligned to support intended
system operation. No discrepancies were noted when comparing the system
components and layout with the system dese.riptions in the USAR. The material condition
of the systems was generally good, with the following exceptions:
9
. . .
. .
-
-
                          addition systems as part of the monthly inspections of the Unit 2 engineered safety
                          syt,tems. Included in this inspection was a review of USA't, Section 6.4, * Containment
                          Vessel Internal Spray," Revision 14, and the following diagram::
                          *          NF 39252, " Flow Diagram Unit 1 & 2 Caustic Addition System," Revision N;
                          e          NF 39824, " Containment Intemal Spray System Units 1 & 2," Revision B;
                          e            NF 39237, * Flow Diagram, Containment Internal Spray System," Revision AB; and
-                          *          NF 393331, * Reactor Safety injection ar'i Containment Spray Piping-Unit 2,"
                                        Revision R.
                      b.  Observations and Findinas
                          The inspectors noted that the valves in the main system f'tw paths were in the correct
                          position, components were properly labeled, locking devices were present and properly
                          installed, and that power supplies and breakers were properly aligned to support intended
                          system operation. No discrepancies were noted when comparing the system
                          components and layout with the system dese.riptions in the USAR. The material condition
                          of the systems was generally good, with the following exceptions:
                                                                        9


    _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _                                   _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _                         -____
_ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
                                    . . ,
_ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
                ,
- _ _ _ _
                                                    e
. . ,
  ..e
,
                                                            e      heavy buildup of sodium hydroxide crystals on the valve siem and packing gland
e
                                                                    area of valve 2 CA 20 5; and
..e
                                                            e      light buildup of cheinical residue on the packing glands of valves MV 32110,
heavy buildup of sodium hydroxide crystals on the valve siem and packing gland
                                                                    MV 32111, CS 251, CS 40, CS 42, and 2 CA 19-4.
e
                                                            The discrepancies did not affect system operability.
area of valve 2 CA 20 5; and
.
light buildup of cheinical residue on the packing glands of valves MV 32110,
                                                        c.   Conclus[gnt
e
                                                            During system walkdowns, the inspectors found the Unit 2 containment spray and caustic
MV 32111, CS 251, CS 40, CS 42, and 2 CA 19-4.
                                                            addition systems lined up and ready for safeguards operation. No significant material
The discrepancies did not affect system operability.
                                                            discrepancies or system deficiencies were identified that would prevent either system
.
                                                            from performing its intended function.
c.
                                                      08   Miscellaneous Operations issues (92700,92901)
Conclus[gnt
                                                      08.1 (Closed) Licensee Event Report 50 306/97005 (2 97-05): Sudden Pressure Lockout of
During system walkdowns, the inspectors found the Unit 2 containment spray and caustic
                                                            No.10 Transformer Resulting in Auto Load Rejection /Restcration on Safety Related Bus.
addition systems lined up and ready for safeguards operation. No significant material
                                                            This event was previously discussed in Inspection Report No. 50>282/97021(DRP);
discrepancies or system deficiencies were identified that would prevent either system
                                                            50-306/97021(DRP), Section 01.3. The Licensee Event Report (LER) contained a
from performing its intended function.
                                                            detailed description of the event, investigation, and restoration sequence. Despite an
08
                                                            extensive investigation, no cause for the actuation was detem,ined, but the sudden
Miscellaneous Operations issues (92700,92901)
                                                            pressure relay was replaced as a precautionary measure. No additional corrective
08.1
                                                            actions were initiated since the causa of the actuation was not known.
(Closed) Licensee Event Report 50 306/97005 (2 97-05): Sudden Pressure Lockout of
                                                                                                                            II. Maintenance
No.10 Transformer Resulting in Auto Load Rejection /Restcration on Safety Related Bus.
                                                      M1   Conduct of Maintenance
This event was previously discussed in Inspection Report No. 50>282/97021(DRP);
                                                      M1,1 General Cornments
50-306/97021(DRP), Section 01.3. The Licensee Event Report (LER) contained a
                                                        a.   inspection Scope (61726. 62707)
detailed description of the event, investigation, and restoration sequence. Despite an
                                                            The inspectors observed all or major portions of the following maintenance and
extensive investigation, no cause for the actuation was detem,ined, but the sudden
                                                            surveillance activities. Included in the inspection was a review of the surveillance
pressure relay was replaced as a precautionary measure. No additional corrective
                                                            procedures (SPs) and work orders (WOs) listed as well as the appropriate Updatad
actions were initiated since the causa of the actuation was not known.
II. Maintenance
M1
Conduct of Maintenance
M1,1 General Cornments
a.
inspection Scope (61726. 62707)
The inspectors observed all or major portions of the following maintenance and
surveillance activities. Included in the inspection was a review of the surveillance
procedures (SPs) and work orders (WOs) listed as well as the appropriate Updatad
Safety Analysis Report (USAR) sections regarding the activi'ies. The inspectors verified
'
'
                                                            Safety Analysis Report (USAR) sections regarding the activi'ies. The inspectors verified
that the surveillance procedures reviewed met the requirements of the TSs.
                                                            that the surveillance procedures reviewed met the requirements of the TSs.
e
                                                              e     SP 1018A         Rod Position Indication Cold Calibration, Revision 6
SP 1018A
                                                              *     SP 1070         Reactor Coolant System Integrity Test, Revision 26 (400 pounds
Rod Position Indication Cold Calibration, Revision 6
                                                                                      per square inch inspection portion only)
*
                                                              *     SP 1083         Unit 1 integrated Safety injection Test with a Simulated Loss of
SP 1070
                                                                                      Offsite Power, Revision 24
Reactor Coolant System Integrity Test, Revision 26 (400 pounds
                                                                                                                                    10
per square inch inspection portion only)
                                                                -           -                                                             . - _ -
*
SP 1083
Unit 1 integrated Safety injection Test with a Simulated Loss of
Offsite Power, Revision 24
10
. - - .
-
-
- --
. - _ -


                                                                                          __
__
    ,
.. . c
      .. . c
,
. . .
. . .
                *       SP 1089       Residual Heat Removal Pumps and Suction Valves from the
*
                                        Refueling Water Storage Tank, Revision 46
SP 1089
                *       SP 1194       Cardox [Carben Dioxide) System Test, Revision 8
Residual Heat Removal Pumps and Suction Valves from the
                *       SP1231         121 Catalytic Hydrogen Recombiner Gas Analyzer Monthly
Refueling Water Storage Tank, Revision 46
                                        Functional and Calibration Test, Revision 11
*
                *       LF 1301         11 Turbine Driven Auxiliary Feedwater Pump Auto Start and
SP 1194
                                        Function Testing Revision 8
Cardox [Carben Dioxide) System Test, Revision 8
                *       SP 1750       Post Outage Containment Closeout inspection, Revision 14
*
                *       SP 2548       Analog Reactor Control System Calibration, Revision b
SP1231
                o       WO 9601293 Motor Operated Valve 32077 Excessive Packing Leakage
121 Catalytic Hydrogen Recombiner Gas Analyzer Monthly
                *       WO 9706505 Fuel Oil Storage Tank Tightness Tests
Functional and Calibration Test, Revision 11
                *       WO 9711674 Modify Tubing for 122 Control Room Chiller
*
                *       WO 9711686 Modify Tubing for 121 Control Room Chiller
LF 1301
                  *       WO 9712636 Turbine Torsional Test
11 Turbine Driven Auxiliary Feedwater Pump Auto Start and
                  *       WO 9713386 Annunciator 47013-0407 Doesn't Clear
Function Testing Revision 8
                  *       WO 9713389 G3 and C7 Rod Bottom Bistables Will Not Clear
*
                  *       WO 9713491 Balance Unit 1 Turbine
SP 1750
                  *       WO 9715204 Possible Foreign Object Noise on DMIMS (Digital Metal Impact
Post Outage Containment Closeout inspection, Revision 14
                                          Monitoring System) Channels 750/751
*
                  *       WO 9715218 Monitor DMIMS Channels 750 and 751 for Noise
SP 2548
                  *       WO 9800004 High Average Coolant Temperature Compensator Module Spiking
Analog Reactor Control System Calibration, Revision b
              b. Observationi md Findinas
o
                  For all of the work observed, procedures were properly used and followed except for one
WO 9601293 Motor Operated Valve 32077 Excessive Packing Leakage
                  activity discussed in Section M1.2 of this report. Maintenance personnelwere
*
                  experienced and knowledgeable of their tasks. The inspectors observed frequent
WO 9706505 Fuel Oil Storage Tank Tightness Tests
                  monitoring of work by system engineers. Noteworthy comments on specific work
*
                  activities are discussed below.
WO 9711674 Modify Tubing for 122 Control Room Chiller
                  *      For SP 1070, the inspectors accompanied two operators and a radiation
*
                          protection technician on an inspection for indications of reactor coolant system
WO 9711686 Modify Tubing for 121 Control Room Chiller
                          leakage in the Unit 1 containment. Two prejob briefings were held: one involved
*
                          the operators and the shift supervisor to discuss the technical aspects of the task,
WO 9712636 Turbine Torsional Test
                                                            11
*
                                                                                                                l
WO 9713386 Annunciator 47013-0407 Doesn't Clear
                                                                                                                i
*
WO 9713389 G3 and C7 Rod Bottom Bistables Will Not Clear
*
WO 9713491 Balance Unit 1 Turbine
*
WO 9715204 Possible Foreign Object Noise on DMIMS (Digital Metal Impact
Monitoring System) Channels 750/751
*
WO 9715218 Monitor DMIMS Channels 750 and 751 for Noise
*
WO 9800004 High Average Coolant Temperature Compensator Module Spiking
b.
Observationi md Findinas
For all of the work observed, procedures were properly used and followed except for one
activity discussed in Section M1.2 of this report. Maintenance personnelwere
experienced and knowledgeable of their tasks. The inspectors observed frequent
monitoring of work by system engineers. Noteworthy comments on specific work
activities are discussed below.
For SP 1070, the inspectors accompanied two operators and a radiation
*
protection technician on an inspection for indications of reactor coolant system
leakage in the Unit 1 containment. Two prejob briefings were held: one involved
the operators and the shift supervisor to discuss the technical aspects of the task,
11
l
i


                                                                                                .. __
..
        ....
__
  . . .
. . . .
. . .
!
!
              and the other involved the operators and a radiation protection superviser to
and the other involved the operators and a radiation protection superviser to
              discuss the radiation protection aspects. The two operators split the areas to be
discuss the radiation protection aspects. The two operators split the areas to be
              inspected and carefully planned their routes with the ascistance of the radiation
inspected and carefully planned their routes with the ascistance of the radiation
              protection technician to minimize radiation exposure. The inspections were
protection technician to minimize radiation exposure. The inspections were
              conducted expeditiously, but thoroughly, No indications of leakage were
conducted expeditiously, but thoroughly, No indications of leakage were
              identified. The operators displayed a suitable approciation for maintaining their
identified. The operators displayed a suitable approciation for maintaining their
              radiation dose as low as reasonably achievable wt'lle still property conducting the
radiation dose as low as reasonably achievable wt'lle still property conducting the
              inspections.
inspections.
            * For SP 1089, the operators identified a proceduru enhancement during the
For SP 1089, the operators identified a proceduru enhancement during the
              conduct of the test. The test required the operators to record differential pressure
*
              (D/P) in the residual heat removal pump mini-flow recirculation line. Since the D/P
conduct of the test. The test required the operators to record differential pressure
              gauge exhibited fluctuations around the actual reading, the procedure allowed the
(D/P) in the residual heat removal pump mini-flow recirculation line. Since the D/P
                option of throttling the instrument root valves to dampen the fluctuations. The
gauge exhibited fluctuations around the actual reading, the procedure allowed the
                operators properly followed the procedure and throttled the root valves, but
option of throttling the instrument root valves to dampen the fluctuations. The
                performance of that step was quite difficult. The root valves were located in the
operators properly followed the procedure and throttled the root valves, but
                next room from the gauge,in a contaminated area, approximately 10 feet off the
performance of that step was quite difficult. The root valves were located in the
                floor. The gauge was not visible from the va'ves. Close coordination of two
next room from the gauge,in a contaminated area, approximately 10 feet off the
                operators was necessary to complete the task. The operators identif5d that it
floor. The gauge was not visible from the va'ves. Close coordination of two
                would have been much easier to throttle the instrument isolation valves on the
operators was necessary to complete the task. The operators identif5d that it
                manifold just under the gauge. The chift supervisor initiated action to get the
would have been much easier to throttle the instrument isolation valves on the
                procedure revised.
manifold just under the gauge. The chift supervisor initiated action to get the
                Just before throttling the instrument root valves, the local operators questioned
procedure revised.
                whether there was any other indication or actuation circuitry off the same
Just before throttling the instrument root valves, the local operators questioned
                instrument lines. They were concer,.ed that they might accidently isolate the line
whether there was any other indication or actuation circuitry off the same
                by overthrottling and cause some kind of problem in other instrumentation. The
instrument lines. They were concer,.ed that they might accidently isolate the line
                operators stopped and resolved their concem with the shift supervisor before
by overthrottling and cause some kind of problem in other instrumentation. The
                proceeding. The operators displayed a conservative operating philosophy and
operators stopped and resolved their concem with the shift supervisor before
                questioning attitude during the test,
proceeding. The operators displayed a conservative operating philosophy and
            e  On December 15,1997, the inspectors observed activities govemed by
questioning attitude during the test,
                WO 9712636, * Unit 1 Turbine Torsional Testing,'' required after the replacement
On December 15,1997, the inspectors observed activities govemed by
                of the turbine generator low pressure rotors. The test measured the torsional
e
                natural frequencies and response levels of the turbine generator shaft system.
WO 9712636, * Unit 1 Turbine Torsional Testing,'' required after the replacement
                Step 8.1.8.f of the turbine torsional test procedure instructed the contrei room
of the turbine generator low pressure rotors. The test measured the torsional
                operator to close generator output breaker 6 H 17. The control room operator
natural frequencies and response levels of the turbine generator shaft system.
                displayed a questioning attitude by asking the system engineer if it was necessary
Step 8.1.8.f of the turbine torsional test procedure instructed the contrei room
                to place the synchroscope selector switch in the BKR 17 position prior to closing
operator to close generator output breaker 6 H 17. The control room operator
                B H 17. The system engineer responded that this was not necessary since the
displayed a questioning attitude by asking the system engineer if it was necessary
                synchro-check relay had been bypassed. When the control room operator
to place the synchroscope selector switch in the BKR 17 position prior to closing
                attempted to close 8-H 17, in accordance with Step 8.1.8.f of the WO, the breaker
B H 17. The system engineer responded that this was not necessary since the
                did not close. Further review of the electrical schematics with the system
synchro-check relay had been bypassed. When the control room operator
                engineer revesk ; that, although a jumper had been installed to bypass the
attempted to close 8-H 17, in accordance with Step 8.1.8.f of the WO, the breaker
did not close. Further review of the electrical schematics with the system
engineer revesk ; that, although a jumper had been installed to bypass the
synchro-check relay in the sivitchyard, the procedure failed to recognize that the
'
'
                synchro-check relay in the sivitchyard, the procedure failed to recognize that the
synchroscope selector switch in the control room needed to be placed in the
                synchroscope selector switch in the control room needed to be placed in the
BKR 17 position to makeup auxiliary contacts necessary to close 8-H-17. The
                BKR 17 position to makeup auxiliary contacts necessary to close 8-H-17. The
12
                                                                  12
_ _ _ _ _ _ - _
                                                  _ _ _ _ _ _ - _


      . 4 .
4 .
  .. .
.
                        WO was changed, the synchroscope selector switch was placed in the BKR 17
.. .
                          position, and 6 H 17 was closed with its control switch. The Unit 1 turbine
WO was changed, the synchroscope selector switch was placed in the BKR 17
                          torsional test was completed without further problems.
position, and 6 H 17 was closed with its control switch. The Unit 1 turbine
                          The turbine torsional test procedure was not appropriatt for the circumstances
torsional test was completed without further problems.
                          because it did not require placing the synchroscope selector switch in the BKR 17
The turbine torsional test procedure was not appropriatt for the circumstances
                          position prior to closing 8 H 17. This was a violation of 10 CFR Part 50,
because it did not require placing the synchroscope selector switch in the BKR 17
                          Appendix B, Criterion V, which required that activities affecting quality be
position prior to closing 8 H 17. This was a violation of 10 CFR Part 50,
                          prescribed by docume:ited instructions, procedures, or drawings, of a type
Appendix B, Criterion V, which required that activities affecting quality be
                          appropriate to the circumstances. However, the turbine torsional test procedure
prescribed by docume:ited instructions, procedures, or drawings, of a type
                          problem was not safety significant becauso it simply resulted in the inability to
appropriate to the circumstances. However, the turbine torsional test procedure
                          complete the test untilit was corrected. This non repetitive, licensee-identified
problem was not safety significant becauso it simply resulted in the inability to
                          and corrected violation is being treated as a Non Cited Violation, consistent with
complete the test untilit was corrected. This non repetitive, licensee-identified
                          Section Vil.B.1 of the NRC Enforcement Policy (50-282/97023-02(DRP)).
and corrected violation is being treated as a Non Cited Violation, consistent with
                  e        For WOs 9715204 and 9715218, the licrasee noted, soon after starting Unit i bp
Section Vil.B.1 of the NRC Enforcement Policy (50-282/97023-02(DRP)).
                          from a refueling cutage, metallic noise indications on detectors located on the
For WOs 9715204 and 9715218, the licrasee noted, soon after starting Unit i bp
                          reactor vessel. The licensee made recordings of the noise and sent them to
e
                          vendors for analysis and made plans to try to identify the source. However, during
from a refueling cutage, metallic noise indications on detectors located on the
                          the power reduction on Januery 9, the noise stopped as soon as operators started
reactor vessel. The licensee made recordings of the noise and sent them to
                          to insert control bank D control rods. The licansee wes unable to reestablish the
vendors for analysis and made plans to try to identify the source. However, during
                          noise by withdrawing control bank D rods while at reduced power, but the noise
the power reduction on Januery 9, the noise stopped as soon as operators started
                          recurred when reactor power was at about 95 percent and control bank D rods
to insert control bank D control rods. The licansee wes unable to reestablish the
                          were retumed to about 205 steps out. Thus, the licensee believed the noise was
noise by withdrawing control bank D rods while at reduced power, but the noise
                          associated with at least one of the control rods and did not represent en
recurred when reactor power was at about 95 percent and control bank D rods
                          immediate safety concern. At the end of the inspection period, the licensee was
were retumed to about 205 steps out. Thus, the licensee believed the noise was
                          considering further actions to identify the exact cause of the noise.
associated with at least one of the control rods and did not represent en
            c.   Conclusions
immediate safety concern. At the end of the inspection period, the licensee was
                  Operators involved with maintenance and surveillance activities displayed a good
considering further actions to identify the exact cause of the noise.
                  questioning attitude and appreciation of mdiation dose control. A procedure inadequacy
c.
                  was identified where circuit logle was :,st analyzed thoroughly enough during
Conclusions
                  devolopment of a work order procodure. System engineers frequently mor:ltored ongoing
Operators involved with maintenance and surveillance activities displayed a good
                  work and were generally responsive to maintenance staff concems: ho...for, in one
questioning attitude and appreciation of mdiation dose control. A procedure inadequacy
                  instance, during the turbine torsional testing, a system engineer did not provide adequate
was identified where circuit logle was :,st analyzed thoroughly enough during
                  support.
devolopment of a work order procodure. System engineers frequently mor:ltored ongoing
            M1.2 Low Power Physics Testina
work and were generally responsive to maintenance staff concems: ho...for, in one
            a.   Inspection Scope (71711)
instance, during the turbine torsional testing, a system engineer did not provide adequate
                  The inspectors observed the conduct of various maintenance activities for refueling
support.
                  startup physics testing on Unit 1. The following maintenance procedures and documents
M1.2 Low Power Physics Testina
                  were reviewed as part of this inspecticn:
a.
                  *          D32, " Temperature Coefficient Measurement at Hot Zero Power," Revision 6;
Inspection Scope (71711)
                  *           D34, " Boron Endpoint Measurement,' Revision 6;
The inspectors observed the conduct of various maintenance activities for refueling
                                                              13
startup physics testing on Unit 1. The following maintenance procedures and documents
were reviewed as part of this inspecticn:
D32, " Temperature Coefficient Measurement at Hot Zero Power," Revision 6;
*
*
D34, " Boron Endpoint Measurement,' Revision 6;
13
A
A
                          . _ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ _ _ _ _ _ _ _ _ _


                                                                    -______--
-______--
    o
o
.. .
.. .
          *          D30, * Post Refueling Startup Testing," Revision 27; and
D30, * Post Refueling Startup Testing," Revision 27; and
          *         ANSI /ANS (American National Standards Institute, Inc./American Nuclear Society)
*
                    19.6.1 1985, * Reload Startup Physics Tests for Pressurized Water
ANSI /ANS (American National Standards Institute, Inc./American Nuclear Society)
                    Reactors."
*
      b. Observations and Findinas
19.6.1 1985, * Reload Startup Physics Tests for Pressurized Water
          The performance of maintenance activities associated with Procedure D34 required a
Reactors."
          significant number of control rod position manipulations. The reactor operator (RO)
b.
          exercised good control over reactivity during the selected individual manipulations of all
Observations and Findinas
          the shutdown and control bank control rods. Good coordination was observed between
The performance of maintenance activities associated with Procedure D34 required a
          the reactor operator and the nuclear engineer assisting with the procedure. Good
significant number of control rod position manipulations. The reactor operator (RO)
          supervisory oversight was provided by the shift supervisor in that he provided a second
exercised good control over reactivity during the selected individual manipulations of all
          verification that the correct rod bank was selected prior to control rod movement.
the shutdown and control bank control rods. Good coordination was observed between
          The inspectors also observed test activities associated with Maintenance Procedure D32.
the reactor operator and the nuclear engineer assisting with the procedure. Good
          These activities were required to be performed twice during low power physics testing:
supervisory oversight was provided by the shift supervisor in that he provided a second
          once with all the control rods withdrawn and once with all rods withdrawn except for the     [
verification that the correct rod bank was selected prior to control rod movement.
          control bank A, which was fully inserted. The purpose of the procedure was to determine
The inspectors also observed test activities associated with Maintenance Procedure D32.
          the isothermal temperature coefficient (lTC) at an established condition below the point of
These activities were required to be performed twice during low power physics testing:
          adding heat and to verify that it was less that 5 percent millirho per degree Fahrenheit, as
once with all the control rods withdrawn and once with all rods withdrawn except for the
          required by TS 3.1.F,1.
[
          The actual performance of the test, after initial plant conditions had been ostablished,
control bank A, which was fully inserted. The purpose of the procedure was to determine
          was accomplished by performing a reactor coolant system (RCS) cooldown followed by a
the isothermal temperature coefficient (lTC) at an established condition below the point of
          heatup. During each trsasient, a plot of reactivity versus temperature was obtained
adding heat and to verify that it was less that 5 percent millirho per degree Fahrenheit, as
          during which time boron concentration and control rod position were kept essentially
required by TS 3.1.F,1.
          constant. The magnitude of the cooldown and heatup, as required by Steps 7.2 and 7.3
The actual performance of the test, after initial plant conditions had been ostablished,
          of Maintenance Procedure D32, was approximately 5 degrees Fahrenheit ('F). More
was accomplished by performing a reactor coolant system (RCS) cooldown followed by a
          specific guid1nce was contained in ANSI /ANS 19.6.1 1985 which was listed as a
heatup. During each trsasient, a plot of reactivity versus temperature was obtained
          reference for D32. Standard ANSI /ANS 19.6.1 1985 stated, as part of the test method to
during which time boron concentration and control rod position were kept essentially
          determine the ITC, that reactivity and temperature should be continuously recorded while
constant. The magnitude of the cooldown and heatup, as required by Steps 7.2 and 7.3
          RCS temperature is increased (decreased) by 3-10 *F.
of Maintenance Procedure D32, was approximately 5 degrees Fahrenheit ('F). More
          During the second test per D32, the inspectors identified that an RCS cooldown of 2.4 'F
specific guid1nce was contained in ANSI /ANS 19.6.1 1985 which was listed as a
          and an RCS heatup of 1.2 'F were used to determine the value for ITC. When the
reference for D32. Standard ANSI /ANS 19.6.1 1985 stated, as part of the test method to
          inspectors questioned the nuclear engineer conducting the test about the procedural
determine the ITC, that reactivity and temperature should be continuously recorded while
          requirement for an approximate 5 'F cooldown (heatup) while obtaining ITC data, i'.ie
RCS temperature is increased (decreased) by 3-10 *F.
          nuclear engineer said that a sufficient RCS temperature change had been performed and
During the second test per D32, the inspectors identified that an RCS cooldown of 2.4 'F
            that the data was good enough to calculate ITC. The inspectors also discovered that the
and an RCS heatup of 1.2 'F were used to determine the value for ITC. When the
            first time the ITC test was performed with all control rods out, a 2.3 'F cooldown and
inspectors questioned the nuclear engineer conducting the test about the procedural
            a 1.8 *F heatup were used. These discropancies were brought to the attention of the
requirement for an approximate 5 'F cooldown (heatup) while obtaining ITC data, i'.ie
            superintendent of nuclear engineering. He agreed that Maintenance Procedure D32 was
nuclear engineer said that a sufficient RCS temperature change had been performed and
            not followed as written. He also said that because it was difficult to maintain a steady
that the data was good enough to calculate ITC. The inspectors also discovered that the
            cooldown (heatup) over a range in excess of about 3 'F, that the cooldown (heatup)
first time the ITC test was performed with all control rods out, a 2.3 'F cooldown and
            portions of the test had usually been performed with less than an approximately 5 *F
a 1.8 *F heatup were used. These discropancies were brought to the attention of the
            temperature change for many years.
superintendent of nuclear engineering. He agreed that Maintenance Procedure D32 was
                                                      14
not followed as written. He also said that because it was difficult to maintain a steady
                                                                ___
cooldown (heatup) over a range in excess of about 3 'F, that the cooldown (heatup)
portions of the test had usually been performed with less than an approximately 5 *F
temperature change for many years.
14
___


    , , ,
, , ,
, .
,
                The inspectors detormined that sufficient temperature changes were accomplished to
.
                obtain adequate data for calculation of the ITC, so this violation was of low safety
The inspectors detormined that sufficient temperature changes were accomplished to
                significance. However, failure to perform the ITC test per Procedure D32 as written, or
obtain adequate data for calculation of the ITC, so this violation was of low safety
                revise the procedure, despite numerous opportu,nties, demonstrated a lack of
significance. However, failure to perform the ITC test per Procedure D32 as written, or
                appreciation for procedural requirerrents. There have been several cited violations for
revise the procedure, despite numerous opportu,nties, demonstrated a lack of
                failure to follow procedures documented in previous inspection reports. In addition, the
appreciation for procedural requirerrents. There have been several cited violations for
                importance of procedure adherence was one of the topics in two recent management
failure to follow procedures documented in previous inspection reports. In addition, the
                meetings Corrective actions Mr the previous violations should have prevented this
importance of procedure adherence was one of the topics in two recent management
                procedure noncompliance, in addition, this violation was identified by the NRC.
meetings Corrective actions Mr the previous violations should have prevented this
                Therefore, the event did not meet the criteria for discretion in the NRC Enforcement
procedure noncompliance, in addition, this violation was identified by the NRC.
                Policy.
Therefore, the event did not meet the criteria for discretion in the NRC Enforcement
                The failure to perform maintenance activities associated with Procedure D32 as written
Policy.
                was a violation of TS 6.5.A.4, which required that the licensee prepare and follow detailed
The failure to perform maintenance activities associated with Procedure D32 as written
                written procedures that control surveillance and testing requirements that could have an
was a violation of TS 6.5.A.4, which required that the licensee prepare and follow detailed
                effect on nuclear safety (50-282/97023-03(DRP)).
written procedures that control surveillance and testing requirements that could have an
          c.   Conclusion
effect on nuclear safety (50-282/97023-03(DRP)).
                The inspectors concluded that both the operators controlling the plant and the nuclear
c.
                engineers coordinating the performance of maintenance activities associated with
Conclusion
                Procedure D32 Jid not follow the written instructions provided in the procedure pertain'ng
The inspectors concluded that both the operators controlling the plant and the nuclear
                to the magnitude of cooldown (heatup) required forITC de armination. Even though the
engineers coordinating the performance of maintenance activities associated with
                engineers knew the proceduie requirements, they chose to do what had worked in the
Procedure D32 Jid not follow the written instructions provided in the procedure pertain'ng
                past, instead of evaluating the way they were performing the test and changing the test to
to the magnitude of cooldown (heatup) required forITC de armination. Even though the
                reflect the actual test practice. This demonstrated a lack of appreciation for strict
engineers knew the proceduie requirements, they chose to do what had worked in the
                compliance with procedural requirements.
past, instead of evaluating the way they were performing the test and changing the test to
          M3   Maintenance P.-ocedures and Documentation
reflect the actual test practice. This demonstrated a lack of appreciation for strict
          M3.1 Coo:ina Water System Walkdown and Suweillance Procedure Review
compliance with procedural requirements.
          'i . Inspection Scope (71707. 62707)
M3
                The inspectors conducted a walkdown of the Unit 1 and Unit 2 cooling water systems,
Maintenance P.-ocedures and Documentation
                included in the inspection was a review of USAR, Section 10.4, * Plant Cooling System,"
M3.1 Coo:ina Water System Walkdown and Suweillance Procedure Review
                Surveillance Procedures SP 1168.8, * Cooling Water System Operating Pressure Test,"
'i .
                Revision 9, and SP 1168.8A, * Cooling Water System Auxiliary Operating Pressure Test,"
Inspection Scope (71707. 62707)
                Revision 0, and a detailed review of the following American Society of Mechanical
The inspectors conducted a walkdown of the Unit 1 and Unit 2 cooling water systems,
                Engineers (ASME) Code drawings:
included in the inspection was a review of USAR, Section 10.4, * Plant Cooling System,"
                *       NF 39819-1,'Cooiing Water ASME Code Classification Screenhouse Unit 1,"
Surveillance Procedures SP 1168.8, * Cooling Water System Operating Pressure Test,"
                        Revision B;
Revision 9, and SP 1168.8A, * Cooling Water System Auxiliary Operating Pressure Test,"
                *      NF 39819-2, * Cooling Water ASME Code Classification - Turbine Building Unit 1,"
Revision 0, and a detailed review of the following American Society of Mechanical
                        Revision B;
Engineers (ASME) Code drawings:
                *      NF 39819 3, * Cooling Water ASME Code Classification - Auxiliary Building Unit 1,"
*
                        Revision D;
NF 39819-1,'Cooiing Water ASME Code Classification Screenhouse Unit 1,"
                                                          15
Revision B;
NF 39819-2, * Cooling Water ASME Code Classification - Turbine Building Unit 1,"
*
Revision B;
NF 39819 3, * Cooling Water ASME Code Classification - Auxiliary Building Unit 1,"
*
Revision D;
15


  - , _ - - -_-___ _,. - _ . - -                           .   - -       ..     .                 - . - - - - . . . - -       - - - . _
- , _ - - -_-___ _,. - _ . - -
              ,
.
                    . .. c
- -
      .< ,
..
                                    e       NF 39819-4," Cooling Water ASME Code Classification Containment Unit 1,
.
                                            Revision C;
- . - - - - . . . - -
                                    e       NF 39841 1, * Cooling Water ASME Code Classification Turbine Building Unit 2,*
-
                                            Revision A;
- - . _
                                    e       NF 398412," Cooling Water ASME Code Classification Auxiliary Building Unit 2,*
. .. c
                                            Revision E;
,
                                    e       NF 398413,' Cooling Water ASME Code Classification Containment Unit 2,*
.< ,
                                            Revision C;
e
                                                                                                                                              i
NF 39819-4," Cooling Water ASME Code Classification Containment Unit 1,
                                    e       NF 39822, * Prairie Island Nuclear Generating P! ant Fuel and Diesel Oil System -                 I
Revision C;
e
NF 39841 1, * Cooling Water ASME Code Classification Turbine Building Unit 2,*
Revision A;
e
NF 398412," Cooling Water ASME Code Classification Auxiliary Building Unit 2,*
Revision E;
e
NF 398413,' Cooling Water ASME Code Classification Containment Unit 2,*
Revision C;
i
e
NF 39822, * Prairie Island Nuclear Generating P! ant Fuel and Diesel Oil System -
!
!
                                            Units 1 & 2 ASME Code Classification Sheet 17," Revision A; and                                   l
Units 1 & 2 ASME Code Classification Sheet 17," Revision A; and
                                                                                                                                              )
)
                                    *      NF 39833," Lab Service Area and Chilled Water Safeguards Systems -                                 1
NF 39833," Lab Service Area and Chilled Water Safeguards Systems -
                                            Unt'.s 1 & 2 ASME Code Classification - Sheet 26," Revision D.                                     I
*
                                                                                                                                              '
I
                                b. Observations and Findinas
Unt'.s 1 & 2 ASME Code Classification - Sheet 26," Revision D.
                                    The inspectors observed the material condition of the Unit 1 and Unit 2 cooling water
'
                                    systems and did not identity any significant discrepancies. All equipment and systems
b.
                                    matched the description found in USAR Section 10.4. However, surveillance Procedures
Observations and Findinas
,                                  SP 1168.8 and SP 1168.8A contained 21 discrepancies.
The inspectors observed the material condition of the Unit 1 and Unit 2 cooling water
                                    SP 1168.8 and SP 1168.8A were required by TS 4.2 and the licensee's ASME Code
systems and did not identity any significant discrepancies. All equipment and systems
                                    Section XI Insery!ce Inspection and Testing Program. Each surveillance was performed
matched the description found in USAR Section 10.4. However, surveillance Procedures
                                    at leasi once every 3% years. The surveillance directed that personnellook for evidence
SP 1168.8 and SP 1168.8A contained 21 discrepancies.
                                    of component leakage, structural stress, and corrosion, and that they inspect hangers
,
                                    and restraints to detect any loss of support capability, missing or loose bolts, corrosion,
SP 1168.8 and SP 1168.8A were required by TS 4.2 and the licensee's ASME Code
                                    ed other problems.
Section XI Insery!ce Inspection and Testing Program. Each surveillance was performed
                                    SP 1168.8 contained the following procedural discrepancies:
at leasi once every 3% years. The surveillance directed that personnellook for evidence
                                    e        a 12" diameter section of the cooling water supply line to the 22 component
of component leakage, structural stress, and corrosion, and that they inspect hangers
                                            cooling water heat exchanger was not required to be inspected by SP 1168.8;
and restraints to detect any loss of support capability, missing or loose bolts, corrosion,
                                    e        a 24" diameter section of the Unit 1 cooling water retum header located just
ed other problems.
                                            upstream of the auxiliary building / turbine building wall penetration was not
SP 1168.8 contained the following procedural discrepancies:
                                            required to be inspected by SP 1168.8;
a 12" diameter section of the cooling water supply line to the 22 component
                                    e       two instances where SP 1168.8 listed valves not shown on the ASME Code
e
                                            drawings;
cooling water heat exchanger was not required to be inspected by SP 1168.8;
                                    e      three instances where the valve designations on the ASME Code drawings did not
a 24" diameter section of the Unit 1 cooling water retum header located just
                                            match the valve numbers included in SP 1168.8;
e
                                    e      one instance where ASME Code drawing NF 39819-3, Revision B, showed two 1"
upstream of the auxiliary building / turbine building wall penetration was not
                                            diameter cooling water is otation valves in the same line when only one existed in
required to be inspected by SP 1168.8;
                                            the plant; and
e
                                                                                16
two instances where SP 1168.8 listed valves not shown on the ASME Code
                                                                                                                          - , ..         . -
drawings;
three instances where the valve designations on the ASME Code drawings did not
e
match the valve numbers included in SP 1168.8;
one instance where ASME Code drawing NF 39819-3, Revision B, showed two 1"
e
diameter cooling water is otation valves in the same line when only one existed in
the plant; and
16
-
,
..
.
-


      4
4
        o
o
  ,. .
,. .
                                                                                                                                  O
O
I                 *        une instance where two separate steps called for inspecting the same section of
I
                            the 24* loop A cooling water header.
une instance where two separate steps called for inspecting the same section of
          .
*
                  SP 1168.8A contained 12 instances where valves named in the procedure as requiring
the 24* loop A cooling water header.
                  inspection were shown but not labeled on the referenced ASME Code drawings.
.
                  The inspectors noted that both SP 1168.8 and SP 1168.8A contained the same                                     *
SP 1168.8A contained 12 instances where valves named in the procedure as requiring
                  precaution and limitations section S'.ep 3.2 stating,"The individual sign off steps are
inspection were shown but not labeled on the referenced ASME Code drawings.
                  intended as a guide; use the Code drawings and/or isometrics to verify alllines are
*
                  inspected." In most cases, using the ASME Code drawings and carefully tracking each
The inspectors noted that both SP 1168.8 and SP 1168.8A contained the same
                  section of line inspected would preclude the inspector from missing portions of the Unit 1
precaution and limitations section S'.ep 3.2 stating,"The individual sign off steps are
                  and 1.' nit 2 cookng water system not described in SP 1168.8 or SP 1168.8A. In at least
intended as a guide; use the Code drawings and/or isometrics to verify alllines are
                  two cases, however, SP 1168.8 or SP 1168.8A included the inspection of valves not
inspected." In most cases, using the ASME Code drawings and carefully tracking each
                  described on the ASME Code drawings. By usli '; the surveillance procedures, Code
section of line inspected would preclude the inspector from missing portions of the Unit 1
                  drawings, and Isometric drawings as directed, individuals cc a orrectly perform the
and 1.' nit 2 cookng water system not described in SP 1168.8 or SP 1168.8A. In at least
                  inspection. Therefore, the procedures were not considered ... adequate.
two cases, however, SP 1168.8 or SP 1168.8A included the inspection of valves not
                  The inspectors discussed the above findings with the system engineer prior to the exit
described on the ASME Code drawings. By usli '; the surveillance procedures, Code
                    interview. The system engineer took prompt action to correct SP 1168.8, SP 1168.8A,
drawings, and Isometric drawings as directed, individuals cc a orrectly perform the
                    and the ASME Code drawings for the inspector identified discrepancies note.1 above,
inspection. Therefore, the procedures were not considered ... adequate.
              c.   Conclusions
The inspectors discussed the above findings with the system engineer prior to the exit
                    Several procedural deficiencies were identified in SP 1168.8 and SP 1168.8A. None of
interview. The system engineer took prompt action to correct SP 1168.8, SP 1168.8A,
                    the deficiencies were safety significant because the surveillance also required the use of
and the ASME Code drawings for the inspector identified discrepancies note.1 above,
                    drawings to confirm that all sections of piping were inspected. However, the deficiencies
c.
                    made the inspection task more difficult.
Conclusions
                    The cooling water system had recolved a great deal of review over the previous three
Several procedural deficiencies were identified in SP 1168.8 and SP 1168.8A. None of
                    years in a licensee self assessment and NRC inspections. The inspectors were
the deficiencies were safety significant because the surveillance also required the use of
                    concerned that a system that had received so much recent attention could still have
drawings to confirm that all sections of piping were inspected. However, the deficiencies
                    procedures containing so many errors. The inspectors considered SP 1168.8 and
made the inspection task more difficult.
                    SP 1168.8A reflective of the need to further improve pmcedures.
The cooling water system had recolved a great deal of review over the previous three
                    The licensee recently completed a pilot program to review a sampling of surveillance
years in a licensee self assessment and NRC inspections. The inspectors were
                    procedures for accuracy and compilance with the writer's guide. Errors were reportedly
concerned that a system that had received so much recent attention could still have
                    found in each of the surveillance procedures reviewed. The licensee was making plans
procedures containing so many errors. The inspectors considered SP 1168.8 and
                    to extend the scope of the procedure review in light of those findings.
SP 1168.8A reflective of the need to further improve pmcedures.
            M3.2 Procedural Weaknesses Identified Durina Auxiiiarv Feedwater Pumn Testina
The licensee recently completed a pilot program to review a sampling of surveillance
                                                                                                                                  ,
procedures for accuracy and compilance with the writer's guide. Errors were reportedly
              a.     ingoection Scope (61726)
found in each of the surveillance procedures reviewed. The licensee was making plans
                    The inspectors attended the prejob brief and observed the performance of testing per
to extend the scope of the procedure review in light of those findings.
                    SP 1301, "11 Turbine Driven Auxiliary Feedwater Pump A a Start and Function Testing "
M3.2 Procedural Weaknesses Identified Durina Auxiiiarv Feedwater Pumn Testina
                    Revision 8. The inspectors reviewed SP 1301 for procedural adequacy and compliance
,
                    with TS 4.8.A.8 and Table 4.1-1C, items 26 and 27, and USAR Section 11.9.
a.
                                                              17
ingoection Scope (61726)
                                                                                                                                    !
The inspectors attended the prejob brief and observed the performance of testing per
                                                                                                                                    l
SP 1301, "11 Turbine Driven Auxiliary Feedwater Pump A a Start and Function Testing "
                              _.                                                                 -           -_-------_--.---.---J
Revision 8. The inspectors reviewed SP 1301 for procedural adequacy and compliance
with TS 4.8.A.8 and Table 4.1-1C, items 26 and 27, and USAR Section 11.9.
17
!
l
_.
-
-_-------_--.---.---J


      ,,
,,
11 '
11 '
            b.       Observations and Findinns
b.
                    The projob brief for SP 1301 was thorough and discussed communications, impacts of
Observations and Findinns
                    ongoing Unit 2 electrical plant shifts with the surveillance, worker responsibilities, and the
The projob brief for SP 1301 was thorough and discussed communications, impacts of
                    procedural steps involved in each of the five functional areas being tested. During the
ongoing Unit 2 electrical plant shifts with the surveillance, worker responsibilities, and the
                    performance of the surveillance; however, three typographical errors were noted. Two
procedural steps involved in each of the five functional areas being tested. During the
                    errors were Identified by the inspectors observing the evolution and one by the control
performance of the surveillance; however, three typographical errors were noted. Two
                    room operator supervising the surveillance. These errors are described below.
errors were Identified by the inspectors observing the evolution and one by the control
      _
room operator supervising the surveillance. These errors are described below.
                    Stop 7.10.28 directed instrument and control personnel to positi,:a three switches in the
_
                      1 ARP5 Reactor Protection Logic Test Cabinet.1 he three switches in this cabinet were -
Stop 7.10.28 directed instrument and control personnel to positi,:a three switches in the
                    labeled 81, S2, and S3. Step 7.10.28, however, contained a typographical error and-
1 ARP5 Reactor Protection Logic Test Cabinet.1 he three switches in this cabinet were -
                    referred to the switches as S1,82, and S2. The error was so obvious that the
labeled 81, S2, and S3. Step 7.10.28, however, contained a typographical error and-
                    technicians performing the surveillance had no problems. The inspectors brought the
referred to the switches as S1,82, and S2. The error was so obvious that the
                      error to the attention of the operator who notified the control room.
technicians performing the surveillance had no problems. The inspectors brought the
                      Stop 7.11.5 verified that the AMSAC [ Anticipated Transient Without Scram Mitigation
error to the attention of the operator who notified the control room.
                      System Actuation Circuit] INACTIVE annunciator in the control room was ON. The step,
Stop 7.11.5 verified that the AMSAC [ Anticipated Transient Without Scram Mitigation
                      however, contained a typographical errnt and identified the annunciator location as
System Actuation Circuit] INACTIVE annunciator in the control room was ON. The step,
                      47074 0606 when the correct location was 47014-0606. The noun name description for
however, contained a typographical errnt and identified the annunciator location as
                      the annunciator was correct in the procedure so it did not cause a performance problem.
47074 0606 when the correct location was 47014-0606. The noun name description for
                      The operator supervising the surveillance ir, the control room identified this error,
the annunciator was correct in the procedure so it did not cause a performance problem.
                      in Step 7.15.6, an operator was directed to push the 11 turbine-driven auxiliary feedwater
The operator supervising the surveillance ir, the control room identified this error,
                      pump local stop push button Step 7.15.6 con:sined a typographical error and r.pecified
in Step 7.15.6, an operator was directed to push the 11 turbine-driven auxiliary feedwater
                      depressing the time delay reset push button PS 5101801 instead of the actuallocal stop
pump local stop push button Step 7.15.6 con:sined a typographical error and r.pecified
                      push button, PB-5101803. The noun name description in the procedure was correct so
depressing the time delay reset push button PS 5101801 instead of the actuallocal stop
                      the operator performed the correct action, even though the push button number was
push button, PB-5101803. The noun name description in the procedure was correct so
                      incorrect. The inspectors observing the surveillance noticed this error and brought it to
the operator performed the correct action, even though the push button number was
                      the attention of the operator. The operator informed the control room.
incorrect. The inspectors observing the surveillance noticed this error and brought it to
                      The control room operator supervising performance of SP 1301 submitted procedure
the attention of the operator. The operator informed the control room.
                      deviation requests to correct the errors noted above following completion of the
The control room operator supervising performance of SP 1301 submitted procedure
                      surveillance.
deviation requests to correct the errors noted above following completion of the
                  c.   Corclusions
surveillance.
                      The three typographical errors identified in SP 1301 had no safety significance and did
c.
                      r,ot prevent satisfactory performance of the surveillance. The inspectors were concemed,
Corclusions
                      however, that two of the three errors were NRC-identified and not noticed by the five
The three typographical errors identified in SP 1301 had no safety significance and did
                      licensee personnel (one electrician, one instrument and control technician, two outplant
r,ot prevent satisfactory performance of the surveillance. The inspectors were concemed,
                      operators, and one control room operator) actually conducting the surveillance, in the
however, that two of the three errors were NRC-identified and not noticed by the five
                      case of the two NRC-identified errors, the test performers did not use proper self-
licensee personnel (one electrician, one instrument and control technician, two outplant
                    = checkin2 techniques. They did not adequately check the switch numbers listed in the
operators, and one control room operator) actually conducting the surveillance, in the
                      procedure against the actval component label before completing the action.
case of the two NRC-identified errors, the test performers did not use proper self-
                      SP 1301 was reviewed by the Operations Committee on Coptember 17,1997, and
= checkin2 techniques. They did not adequately check the switch numbers listed in the
                      approved by the superintendent mechanical systems on November 29,1997. This was
procedure against the actval component label before completing the action.
                      after the licensee placed a renewed emphasis on procedural adequacy and compliance.
SP 1301 was reviewed by the Operations Committee on Coptember 17,1997, and
                                                          '
approved by the superintendent mechanical systems on November 29,1997. This was
                    - The three errors identified li. ::P 1301 highlighted the need for continued efforts in this
after the licensee placed a renewed emphasis on procedural adequacy and compliance.
                                                                            18
- The three errors identified li. ::P 1301 highlighted the need for continued efforts in this
    .
'
        .. . .. .               ..
18
                                                            .
.
                                            _ _ _ _ _ _ .     _ _ _ _ _ _ _
..
. .. .
..
_ _ _ _ _ _ .
.
_ _ _ _ _ _ _


                                                                                    . _ _ _ _ _ _ _ _ _ _ _ - -_-_-
_
  _
-_-_-
        4 ,
. _ _ _ _ _ _ _ _ _ _ _ -
    .: .
4
                    area. As noted in Section M3.1 of this report, the licensee was evaluating an expanded
,
                    surveillance review program.
.:
            M8     Miscellaneous Maintenance Activities (92700,92902)
.
area. As noted in Section M3.1 of this report, the licensee was evaluating an expanded
surveillance review program.
M8
Miscellaneous Maintenance Activities (92700,92902)
)
)
M8.1 (Closed) Inspection Followup Item (IFI) 50-282/97005 03fDRP): 50 306/97005-03(DRP):
'
'
            M8.1 (Closed) Inspection Followup Item (IFI) 50-282/97005 03fDRP): 50 306/97005-03(DRP):
Reactor Coolant System Vent and Containment Boundary Control During Integrated
                    Reactor Coolant System Vent and Containment Boundary Control During Integrated
Leakage Rate Test. This issue was previously discussed in inspection Report
                    Leakage Rate Test. This issue was previously discussed in inspection Report
No. 50-282/97005(DRP); 50-306/97005(DRP), Section M1.1. It involved a licensee-
                    No. 50-282/97005(DRP); 50-306/97005(DRP), Section M1.1. It involved a licensee-
identified procedure error in Unit 2 surveillance Procedure SP 2071.4, * integrated
                    identified procedure error in Unit 2 surveillance Procedure SP 2071.4, * integrated
Leakage Rate Test Prerequisites to the Containment Vesse! Integrated Leakage Rata
                    Leakage Rate Test Prerequisites to the Containment Vesse! Integrated Leakage Rata
Test," Revision B. The test procedure was written in such a way that the reactor coolant
                    Test," Revision B. The test procedure was written in such a way that the reactor coolant
system could be vented before containmg.t integrity was established, which would have
                    system could be vented before containmg.t integrity was established, which would have
been a violation of TSs. The inspectors verified that the Unit 1 test, SP 1071.4,
                    been a violation of TSs. The inspectors verified that the Unit 1 test, SP 1071.4,
" Prerequisites to the Containment Vessel Integrated Leakage Rate Test," Revision 6, had
                    " Prerequisites to the Containment Vessel Integrated Leakage Rate Test," Revision 6, had
been revised to eliminate the problem before it was used. The inspectors also verified
'
'
                    been revised to eliminate the problem before it was used. The inspectors also verified
that the system engineer had submitted a procedure revision form to ensure that the
                    that the system engineer had submitted a procedure revision form to ensure that the
Unit 2 procedure would be revised before its next use. The next expected Unit 2
                    Unit 2 procedure would be revised before its next use. The next expected Unit 2
integrated leakage rate test was planned to be conducted in the year 2006.
                    integrated leakage rate test was planned to be conducted in the year 2006.
Ill. Enoineerina
                                                                Ill. Enoineerina
E2
            E2     Engineering Support of Facilities and Equipment
Engineering Support of Facilities and Equipment
            E2.1   Review of Updated Safety Analysis Report (USAR) Comntitments (37551. 92903J
E2.1
                    While performing the inspections discussed in this report, the inspectors reviewed the
Review of Updated Safety Analysis Report (USAR) Comntitments (37551. 92903J
                    applicablo portions of the USAR that related to the areas inspected and used the USAR
While performing the inspections discussed in this report, the inspectors reviewed the
                    as an engineering / technical support basis document. The inspectors compared plant
applicablo portions of the USAR that related to the areas inspected and used the USAR
                    practices, procedurcs, and/or parameters to the USAR descriptions as discussed in each
as an engineering / technical support basis document. The inspectors compared plant
                    section. The inspectors verified that the USAR wording was consistent with the observed
practices, procedurcs, and/or parameters to the USAR descriptions as discussed in each
                    plant practices, procedures, and parameters. No discrepancies were noted.
section. The inspectors verified that the USAR wording was consistent with the observed
            E2.2   General Comments (37551)
plant practices, procedures, and parameters. No discrepancies were noted.
                    Throughout the inspection period, 'Se inspectors noted frequent involvement by system
E2.2
                    engineers in all aspects of plant operations, refueling, maintenance, and surveillance
General Comments (37551)
                    activities. The engineers rapidly investigated any operational abnormalities, took an
Throughout the inspection period, 'Se inspectors noted frequent involvement by system
                    active role in maintenance and troubleshooting activities, and closely followed all
engineers in all aspects of plant operations, refueling, maintenance, and surveillance
                    surveillance testing on their systems.
activities. The engineers rapidly investigated any operational abnormalities, took an
                                                                          19
active role in maintenance and troubleshooting activities, and closely followed all
                                        - - __         _ _ _ _ _
surveillance testing on their systems.
19
- - __
_ _ _ _ _


    .
..
      ..
.
  .,
.,
i         E3   Engineering Procedures and Documentation
i
          E3.1 ftilure to Test the Auto Start Feature of the Control Room Ventilation System Air
E3
              Handlers Due to Procedure Deficiency
Engineering Procedures and Documentation
          a. Inspection Scope (g2700)
E3.1
              On December 7,1997, as part of an investigation in response to NRC Generic
ftilure to Test the Auto Start Feature of the Control Room Ventilation System Air
              Letter 96 01, " Testing of Safety related Logic Circuits," the licensee discovered that the
Handlers Due to Procedure Deficiency
              automatic start of the 121 and 122 control room air handlers upon a st:rt of the
a.
              associated 121 and 122 control room cleanup fans, which was required to be tested by
Inspection Scope (g2700)
              TSs, had not been tested. The inspectors reviewed the circumstances and corrective
On December 7,1997, as part of an investigation in response to NRC Generic
              actions for the finding,
Letter 96 01, " Testing of Safety related Logic Circuits," the licensee discovered that the
          b.   Observations and Findinos
automatic start of the 121 and 122 control room air handlers upon a st:rt of the
                Technical Specification 4.14.A.2 required, in part, that once per operating cycle or once
associated 121 and 122 control room cleanup fans, which was required to be tested by
                every 18 months, whichever occurs first, the automatic initiation of the control room
TSs, had not been tested. The inspectors reviewed the circumstances and corrective
                special ventilation system be demonstrated with a simulated high radiation or safety
actions for the finding,
                injection signal. A high radiation or safety injection signalis designed to start the control
b.
                room cleanup fans and operate various dampers. Starting of the clesnop fans will
Observations and Findinos
                subsequently result In the start of the main air handler fans. Without the air handler fans
Technical Specification 4.14.A.2 required, in part, that once per operating cycle or once
                running, the cleanup fans would be ineffective in performing the function of reducing
every 18 months, whichever occurs first, the automatic initiation of the control room
                airborne radioactivity for control room operators.
special ventilation system be demonstrated with a simulated high radiation or safety
                The licensee discovered that the surveillance had normally been per4ormed with the air
injection signal. A high radiation or safety injection signalis designed to start the control
                handler fans already running in order to test the isolation function of the outside air
room cleanup fans and operate various dampers. Starting of the clesnop fans will
                dampers. Thus, one of the automatic features had not been tested.
subsequently result In the start of the main air handler fans. Without the air handler fans
                As discussed in the Licensee Event Report (LER 19718) for the finding, shortly before
running, the cleanup fans would be ineffective in performing the function of reducing
                the time of discovery, the auto start feature of both trains of control room ventilation had
airborne radioactivity for control room operators.
                coincidently been tested as part of a pre-operational test for a modification of the related
The licensee discovered that the surveillance had normally been per4ormed with the air
                power supplies. The auto start features functioned normally during those tests. While
handler fans already running in order to test the isolation function of the outside air
                this indicated that the air handler fans' automatic start feature was functional, the failure
dampers. Thus, one of the automatic features had not been tested.
                to test it as part of a formal surveillance test reflected a programmatic weakness in tha
As discussed in the Licensee Event Report (LER 19718) for the finding, shortly before
                surveillance testing program. The LER stated that the survelliance proceduret would ue
the time of discovery, the auto start feature of both trains of control room ventilation had
                revised prior to the next scheduled test to require testing of the auto start feature. The
coincidently been tested as part of a pre-operational test for a modification of the related
                LER will rema.in open pending completion of the revisions (LER 50-282/97018;
power supplies. The auto start features functioned normally during those tests. While
                50-306/97018).
this indicated that the air handler fans' automatic start feature was functional, the failure
                The failure to perform a surveillance test of the auto start feature of the control room alt
to test it as part of a formal surveillance test reflected a programmatic weakness in tha
                handlers was a violation of TS 4,14.A.2. This non-repetitive, licensee-identified and
surveillance testing program. The LER stated that the survelliance proceduret would ue
                corrected violation is being treated as a Non-Cited Violation, consistent with
revised prior to the next scheduled test to require testing of the auto start feature. The
                Section Vll.B.1 of the NRC Enforcement Policy (50-282/97023-04(DRP);
LER will rema.in open pending completion of the revisions (LER 50-282/97018;
                50-306/97023-04(DRP)).
50-306/97018).
            c.   Conclusions
The failure to perform a surveillance test of the auto start feature of the control room alt
                  This finding, and the ones discussed in Sections EB.1 and F2.1 of this report indicated
handlers was a violation of TS 4,14.A.2. This non-repetitive, licensee-identified and
                  that the licensee was conducting thorough design reviews in response to Genotic
corrected violation is being treated as a Non-Cited Violation, consistent with
                                                            20
Section Vll.B.1 of the NRC Enforcement Policy (50-282/97023-04(DRP);
                                                            - - _ - -
50-306/97023-04(DRP)).
c.
Conclusions
This finding, and the ones discussed in Sections EB.1 and F2.1 of this report indicated
that the licensee was conducting thorough design reviews in response to Genotic
20
- - _ - -


    .*e
.*e
      .
.
  ..
..
                Letter 96 01 and other concems. Licensee employees demonstrated a wil:ingness to
Letter 96 01 and other concems. Licensee employees demonstrated a wil:ingness to
                identify old design discrepancies and compliance problems and the licensee rapidly
identify old design discrepancies and compliance problems and the licensee rapidly
                resolved those issues.
resolved those issues.
        E8     t,11scellaneous Engineering issues (92700,92903)
E8
        E8.1   (Clesed) LER 50 282/97015: 50-306/97015 fi 9715h Both Trains of Control Room
t,11scellaneous Engineering issues (92700,92903)
                Special Ventilation System Simu'taneously Inoperable. This LER discussed an issue,
E8.1
                identified on November 'J,1997, in which the licensee determined that routine
(Clesed) LER 50 282/97015: 50-306/97015 fi 9715h Both Trains of Control Room
                performance of a monthly surveillance on steam exclusion dampers had resulted in both
Special Ventilation System Simu'taneously Inoperable. This LER discussed an issue,
                trains of control room sponial ventilation being inoperable because outside air dempers,
identified on November 'J,1997, in which the licensee determined that routine
                opened for the surveillance, would not have automatically closed on actuation of the
performance of a monthly surveillance on steam exclusion dampers had resulted in both
                  system on high radiation or safety injection. This could have resulted in the control room
trains of control room sponial ventilation being inoperable because outside air dempers,
                operators' dose being higher than General Design Criterion 19 limits.
opened for the surveillance, would not have automatically closed on actuation of the
                The cause of the event was the failure to properly review the control room ventilation
system on high radiation or safety injection. This could have resulted in the control room
                cystem logic and design requirements when the steam exclusion damper surveillance
operators' dose being higher than General Design Criterion 19 limits.
                was devcloped. The Feensee identified the issue as part of the development of revised
The cause of the event was the failure to properly review the control room ventilation
                  main steamline break control room dose calculations. As discussed in the LER, the
cystem logic and design requirements when the steam exclusion damper surveillance
                  condition existed for only a few minutes each month and the operators would have had
was devcloped. The Feensee identified the issue as part of the development of revised
                  ample indications and controls available to identify the problem and close the dampers if
main steamline break control room dose calculations. As discussed in the LER, the
                  an accident had occurred. The inspectors verified that all of the corrective actinns
condition existed for only a few minutes each month and the operators would have had
                  discussed in the LER had been completed.
ample indications and controls available to identify the problem and close the dampers if
                  Monthly performance of the steam exclusion damper surveillance resulted in both trains
an accident had occurred. The inspectors verified that all of the corrective actinns
                  of control room special ventilation being inoperable, contrary to the requirements of
discussed in the LER had been completed.
                  TS 3.13.A.1 which required that both trains be operable at all times. Although the TS
Monthly performance of the steam exclusion damper surveillance resulted in both trains
                  was violated, the associated action rwquirement to initiata within 1 hour the action
of control room special ventilation being inoperable, contrary to the requirements of
                  necessary to place both units in hot shutdown, and be in at least hot shutdown within the
TS 3.13.A.1 which required that both trains be operable at all times. Although the TS
                  next 6 hours and in cold shutdown within the following 30 hours and terminats core
was violated, the associated action rwquirement to initiata within 1 hour the action
                  alterations / fuel handling operations within 2 hours, was probably never exceeded.
necessary to place both units in hot shutdown, and be in at least hot shutdown within the
                  This non repetitive, licensee identified and corrected violation is being treat?d as a
next 6 hours and in cold shutdown within the following 30 hours and terminats core
                  Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy
alterations / fuel handling operations within 2 hours, was probably never exceeded.
                  (50 282/97023-05(DRP); 50 306/97023 05(DRP)).
This non repetitive, licensee identified and corrected violation is being treat?d as a
                                                    IV. Plant Suooort
Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy
          R1       Radiological Protection and Chemistry Controls (71750)
(50 282/97023-05(DRP); 50 306/97023 05(DRP)).
          During normal resident inspection activities, routins observations were conducted in the areas of
IV. Plant Suooort
          radiological protection and chemistry controls using inspection Procedure 71750. No
R1
          discrepancies were noted. The inspectors noted good involvement of radiation protection
Radiological Protection and Chemistry Controls (71750)
          personnel in job planning and execution in order to maintain doses as low as reasonably
During normal resident inspection activities, routins observations were conducted in the areas of
          achievable.
radiological protection and chemistry controls using inspection Procedure 71750. No
                                                            21
discrepancies were noted. The inspectors noted good involvement of radiation protection
personnel in job planning and execution in order to maintain doses as low as reasonably
achievable.
21
<
<
                                                .
.


                                                                        -                 _         -_
-
      ..e e
_
  .- .
-_
            P1     Conduct of Emergency Preparednees Activities (71750)
..e e
            During normal resident inspection activities, routine observations were conducted in the area of
.- .
            emergency preparedness using Inspection Procedure 71750. No discrepancies were noteo.
P1
            81     Conduct of Security and Safeguards Activities (71760)
Conduct of Emergency Preparednees Activities (71750)
            During normal resident inspection activities, routine observations were conducted in the areas of
During normal resident inspection activities, routine observations were conducted in the area of
            security and safeguards activities using Inspection Procedure 71750. No discrepancies were
emergency preparedness using Inspection Procedure 71750. No discrepancies were noteo.
            noted.
81
            F2     Status of Fire Protection Facilities and Equipment
Conduct of Security and Safeguards Activities (71760)
            F2.1   Separation of Pressurizer Level Indication Channels Not in Comollance with
During normal resident inspection activities, routine observations were conducted in the areas of
                    10 CFR Part 50. Accendix R. Section Ill.G.2
security and safeguards activities using Inspection Procedure 71750. No discrepancies were
              a.     laspection Smoe (92700)
noted.
                    On December 6,1997, the licensee reported to the NRC in accordance with
F2
                      10 CFR 50.72 that the plant was in a condition outside of the design basis because the
Status of Fire Protection Facilities and Equipment
                    licensee had discovered that the pressurizer level channel cables in Unit 1 containment
F2.1
                    were not separated as required by 10 CFR Part 50, Appendix R. The inspectors             r
Separation of Pressurizer Level Indication Channels Not in Comollance with
                    reviewed the circumstances and corrective actions for the finding,
10 CFR Part 50. Accendix R. Section Ill.G.2
              b.   Qbtervations and Findinas
a.
                      The issue was first identified during a walkdown of the containment on
laspection Smoe (92700)
                      November 14,1997, to support an Appendix R Safe Shutdown Analysis revision. The
On December 6,1997, the licensee reported to the NRC in accordance with
                      licensee noted that the pressurizer level detectors were not located as shown on plant
10 CFR 50.72 that the plant was in a condition outside of the design basis because the
                      layout drawings and that the pressurizer level channels old not have adequste separation
licensee had discovered that the pressurizer level channel cables in Unit 1 containment
                      of the detectors and the associated cables to meet the requirements of Appendix R. The
were not separated as required by 10 CFR Part 50, Appendix R. The inspectors
                      drawings indicated adequate separation but the as Lailt configuration did not match the
r
                      drawings.
reviewed the circumstances and corrective actions for the finding,
                      At first the licensee believed that an exemption from the NRC might have been grants d
b.
                      for the existing installation. As discussed in the associated Licensee Event Report
Qbtervations and Findinas
                      (LER 1-97-17), the documentation regarding various Appendix R exemptions was
The issue was first identified during a walkdown of the containment on
                      somewhat confusing and incomplete. By December 6, the licensee determined that an
November 14,1997, to support an Appendix R Safe Shutdown Analysis revision. The
                      appropriate exemption did not exist and the cabling would have to be modified to meet
licensee noted that the pressurizer level detectors were not located as shown on plant
                      Appendix R.
layout drawings and that the pressurizer level channels old not have adequste separation
of the detectors and the associated cables to meet the requirements of Appendix R. The
drawings indicated adequate separation but the as Lailt configuration did not match the
drawings.
At first the licensee believed that an exemption from the NRC might have been grants d
for the existing installation. As discussed in the associated Licensee Event Report
(LER 1-97-17), the documentation regarding various Appendix R exemptions was
somewhat confusing and incomplete. By December 6, the licensee determined that an
appropriate exemption did not exist and the cabling would have to be modified to meet
Appendix R.
Within the next few days a modification was developed and installed to provide a
'
'
                      Within the next few days a modification was developed and installed to provide a
noncombustible radiant energy shield around one channel of the cabling to satisfy
                      noncombustible radiant energy shield around one channel of the cabling to satisfy
Appendix R requirements. The inspectors walked down the installation and it appeared
                      Appendix R requirements. The inspectors walked down the installation and it appeared
that the energy shieH was adequate.
                      that the energy shieH was adequate.
The licensee issued LER 19717 on January 2,1998. The inspectors reviewed the LER
                      The licensee issued LER 19717 on January 2,1998. The inspectors reviewed the LER
and determined that it adequately discussed the beckground, safety significance, and
                      and determined that it adequately discussed the beckground, safety significance, and
corrective actions for the subject Appendix R non compliance. The LER will remain open
                      corrective actions for the subject Appendix R non compliance. The LER will remain open
pending completion of corrections to the plant layout drawings (LER 50-282/97017).
                      pending completion of corrections to the plant layout drawings (LER 50-282/97017).
_
                                _                 __ __       . _ _
__ __
                                                                    22
. _ _
          ..
22
                        .
..
                                        _ _ _ - _ - _ - _ _ _
.
_ _ _ - _ - _ - _ _ _


          , ;e; .
, ;e; .
    0*
0*
*
*
                              Sedion lll.G.2 of App 9ndix R, of 10 CFR Part 50, requires, in part, that cables and
Sedion lll.G.2 of App 9ndix R, of 10 CFR Part 50, requires, in part, that cables and
                              equipment and associated non safety circuits of redundant trains of equipnient necessary
equipment and associated non safety circuits of redundant trains of equipnient necessary
4                            to achieve and maintain hot shutdown conditions in non-inerted containments, be
to achieve and maintain hot shutdown conditions in non-inerted containments, be
4
4
                              protected from potential fire Jamage. This could be achieved through separation of
4
protected from potential fire Jamage. This could be achieved through separation of
more than 20 feet with no intervening combustibles or fire hazards or by having installed
a
a
'
'
                              more than 20 feet with no intervening combustibles or fire hazards or by having installed
fire detection tend automatic suppression, or through separation by noncombustible
                              fire detection tend automatic suppression, or through separation by noncombustible
j.
j.                           radiant energy shields. The licensee 6dentified that the redundant pressurizer level
radiant energy shields. The licensee 6dentified that the redundant pressurizer level
i                             detector cables in :he Unit 1 containment did not satisfy any of these conditions and thus
i
'!                           a violation of NRC requirements existed. As discussed in the LER, the condition had
detector cables in :he Unit 1 containment did not satisfy any of these conditions and thus
j                             M!stively low safety significance and was promptly corrected when the noncon.pliance
'!
j                             was confirmed. Thi6 non repetitive, licensee-identified and corrected violation is being--
a violation of NRC requirements existed. As discussed in the LER, the condition had
                              treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement
j
M!stively low safety significance and was promptly corrected when the noncon.pliance
j
was confirmed. Thi6 non repetitive, licensee-identified and corrected violation is being--
treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement
Policy (50 282/97023-06(DRP)).
i
i
                              Policy (50 282/97023-06(DRP)).
}
}                          c. Conclusions
c.
Conclusions
f
f
;.                            The licensee's finding was the result of a proactive voluntary review of fire protection
The licensee's finding was the result of a proactive voluntary review of fire protection
i                             issues and revision of tire protection analysis. Prompt corrective actions were taken
;.
3                             when the condition v as confirmed.
i
                                                                                                                                                                              '
issues and revision of tire protection analysis. Prompt corrective actions were taken
3
when the condition v as confirmed.
l
l
                                                                                                                                                                              '
'
i
i
l-                                                                                 V Mananoment Meetinos
'
                                                                                                                                                                              ,
l-
                      X1     Exit Meeting Summary
V Mananoment Meetinos
                      The inspectors presented the inspection retu;is to members of the licensee management at the
,
                      conclusion of the inspection on January 13,1998. The licensee acknowlectged the findings
X1
Exit Meeting Summary
The inspectors presented the inspection retu;is to members of the licensee management at the
conclusion of the inspection on January 13,1998. The licensee acknowlectged the findings
presented. The inspectors asked the licensee whether any materials examined during the
4
4
                      presented. The inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary No proprietary information was identified.
                      inspection should be considered proprietary No proprietary information was identified.
$
$
:
:
.
.
                                                                                                                                                                              i
i
1
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                                                                                        _ . - . = - - _ - - . - - - . .
_ . - . = - - _ - - . - - - . .
    *
*
  ,..,=
., . . , =
  .
0-
0-
                                  PARTIAL List OF PERSONS CONTACTED
PARTIAL List OF PERSONS CONTACTED
        Licensee
Licensee
        J. Sorontsn, Plant Manager
J. Sorontsn, Plant Manager
        K. Albrecht, General Superintendent, Engineering, Electrical / Instrumentation & Controls
K. Albrecht, General Superintendent, Engineering, Electrical / Instrumentation & Controls
        T. Amundson, General Superintendent, Engineering, Mechanical
T. Amundson, General Superintendent, Engineering, Mechanical
        J. Goldsmith, General Superintendent, Engineering, Generation Services
J. Goldsmith, General Superintendent, Engineering, Generation Services
        J. Hill, Manager, Quality Services
J. Hill, Manager, Quality Services
        G. Lon3rtz, General Superintendent, Plant Maintenance
G. Lon3rtz, General Superintendent, Plant Maintenance
        J. Maki, Outage Manager
J. Maki, Outage Manager
        D. Schuelke, General Superintendent, Radiation Protection and Chsmistry
D. Schuelke, General Superintendent, Radiation Protection and Chsmistry
        T. Silverberg, General Superintendent, Plant Operations
T. Silverberg, General Superintendent, Plant Operations
        M. Sleigh, Superintendent, Security
M. Sleigh, Superintendent, Security
                                _
_
                                                      24
24
                                                                                                                        ,
,


                  _                                   - - . .
_
    .
- - . .
      . . .; .
. . .; .
  - .
.
-
.
1
1
!
!
l                                              lNSPECTION PROCEDURES USED
l
l
                lP 07551:     Engineering
lNSPECTION PROCEDURES USED
                IP 61726:     Surveillance Observations
l
                IP 62707:     Maintenance observations
lP 07551:
                IP 71707:     Plant Operations
Engineering
                IP 71711:     Startup from Refueling
IP 61726:
                IP 71750.     Plant Support Activities
Surveillance Observations
                IP 92700:     Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor
IP 62707:
                              Facilities
Maintenance observations
                IP 92901:     Follow up - Operations
IP 71707:
                IP 92902:     Follow up - Maintenance
Plant Operations
                IP 92903:     Follow up - Engineering
IP 71711:
                                          ITEMS OPENED, CLOSED, AND DISCUSSED
Startup from Refueling
                Qllen9A
IP 71750.
                50-282/97023-01(DRP)       NCV     Failure to Perform Step in Reactor Startup Procedure
Plant Support Activities
                                                      When Called For
IP 92700:
                50-282/97023-02(DRP)       NCV     inadequate Procedure for Turtaine Torsional Testing
Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor
                50 282/97023-03(DRP)       VIO     Failure to Perform Two Steps in Reactor Physics Testing
Facilities
                                                      Procedure as Written
IP 92901:
                50-282/97023-04(CRP)       NCV     Failure to Test the / % Start Feature of the Control Room
Follow up - Operations
                50 306/97023-04(DRP)                 Ventilation System il- Handlers due to Procedure
IP 92902:
                                                      Deficiency
Follow up - Maintenance
                50-282/97023-05(DRP)       NCV     Both Trains of Control Room Special Ventilation System
IP 92903:
                50-300'97023-05(DRP)                 Simultaneously inoperable
Follow up - Engineering
                50 282/97023- 06(DRP)       NCV     Separation of Pressurizer Level Indication Channels Not in
ITEMS OPENED, CLOSED, AND DISCUSSED
                                                      Compliance with 10 CFR Part 50, Appendix R,
Qllen9A
                                                      Section Ill.G.2
50-282/97023-01(DRP)
                50 282/97017               LER       Separation of Pressurizer LevelIndication Channels Not in
NCV
                                                      Compliance with 10 CFR Part 50, Appendix R,
Failure to Perform Step in Reactor Startup Procedure
                                                      Section Ill.G.2
When Called For
                50-282/97018               LER       Failure to Test the Auto-Start Feature of the Control Room
50-282/97023-02(DRP)
                5B Gi97013                           Ventilebon System Air Handlers due to Procedure
NCV
                                                      Deficiency
inadequate Procedure for Turtaine Torsional Testing
                Closed
50 282/97023-03(DRP)
                50-282/97005-03(DRP)       IFl       Reactor Coolant System Vent and Containment Boundary
VIO
(.               50-306/97005-03(DRP)                 Control During Integrated Leakage Rate Test
Failure to Perform Two Steps in Reactor Physics Testing
                50-306/97005               LER       Sudden Pressure Lockout of No.10 Transformer Resulting
Procedure as Written
                                                      in Auto Load Rejection / Restoration on Safety-Related Bus
50-282/97023-04(CRP)
                                                                    25
NCV
Failure to Test the / % Start Feature of the Control Room
50 306/97023-04(DRP)
Ventilation System il- Handlers due to Procedure
Deficiency
50-282/97023-05(DRP)
NCV
Both Trains of Control Room Special Ventilation System
50-300'97023-05(DRP)
Simultaneously inoperable
50 282/97023- 06(DRP)
NCV
Separation of Pressurizer Level Indication Channels Not in
Compliance with 10 CFR Part 50, Appendix R,
Section Ill.G.2
50 282/97017
LER
Separation of Pressurizer LevelIndication Channels Not in
Compliance with 10 CFR Part 50, Appendix R,
Section Ill.G.2
50-282/97018
LER
Failure to Test the Auto-Start Feature of the Control Room
5B Gi97013
Ventilebon System Air Handlers due to Procedure
Deficiency
Closed
50-282/97005-03(DRP)
IFl
Reactor Coolant System Vent and Containment Boundary
(.
50-306/97005-03(DRP)
Control During Integrated Leakage Rate Test
50-306/97005
LER
Sudden Pressure Lockout of No.10 Transformer Resulting
in Auto Load Rejection / Restoration on Safety-Related Bus
25


    ~
(
(        .
~
    , ' ?. 0
.
  .
, ' ?. 0
    .
.
            50-282/97015 LER Both Trains of Control Room Special Ventilation System
.
!           50-306/97015     Simultaneously Inoperable
50-282/97015
LER
Both Trains of Control Room Special Ventilation System
!
50-306/97015
Simultaneously Inoperable
1
1
                                          26
26
                                              _ _ _ _ _ - _ - _ _ -
_ _ _ _ _ - _ - _ _ -


                                                                        .. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
,
,
    , . ',i %
..
  1*
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
                                            LIST OF ACRONYM 8 USED
, . ',i %
              AMSAC     Anticipated Transient Without Scram Mitigation System Actuation Circuit
1*
              ANSI /ANS Americcn National Standards Institute, Inc/American Nuclear Society
LIST OF ACRONYM 8 USED
              ASME     American Society of Mechanical Engineers
AMSAC
              CFR       Code of Federal Regulations
Anticipated Transient Without Scram Mitigation System Actuation Circuit
              D/F       Differential Pressure
ANSI /ANS
              DRP       Division of Reactor Projects
Americcn National Standards Institute, Inc/American Nuclear Society
              DMIMS     Digital Metal impact Monitoring System
ASME
              'F       Degrees Fahrenheit
American Society of Mechanical Engineers
              IP       inspection Procedure
CFR
              ITC       isothermal Temperature Coefficient
Code of Federal Regulations
              LER       Licensee Event 9eport
D/F
              LPE&RO   Lead Plant Equipment and Reactor Operator
Differential Pressure
              NRC       Nuclear Regulatory Commission
DRP
              PDR       Public Document Room
Division of Reactor Projects
              RCS       Reactor Coolant System
DMIMS
              RO       Reactor Operator
Digital Metal impact Monitoring System
              SP       Surveillance Procedure
'F
              SS       Shift Supervisor
Degrees Fahrenheit
              SWI       Section Work Instruction
IP
              TS       Technical Specification
inspection Procedure
              USAR     Updated Safety Analysis Report
ITC
              WO       Work Order
isothermal Temperature Coefficient
?:
LER
                                                                      27
Licensee Event 9eport
                                                    _ _ _ _ _ - _ _ -                                                   I
LPE&RO
Lead Plant Equipment and Reactor Operator
NRC
Nuclear Regulatory Commission
PDR
Public Document Room
RCS
Reactor Coolant System
RO
Reactor Operator
SP
Surveillance Procedure
SS
Shift Supervisor
SWI
Section Work Instruction
TS
Technical Specification
USAR
Updated Safety Analysis Report
WO
Work Order
? :
27
_ _ _ _ _ - _ _ -
I
}}
}}

Latest revision as of 02:22, 24 May 2025

Insp Repts 50-282/97-23 & 50-306/97-23 on 971203-980113. Violations Noted.Major Areas Inspected:Licensee Operations, Maint,Engineering & Plant Support
ML20202C058
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 01/30/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20202C041 List:
References
50-282-97-23, 50-306-97-23, NUDOCS 9802120155
Download: ML20202C058 (27)


See also: IR 05000282/1997023

Text

. _ . .

, , ,

.

  • o ,, t

+

U.S. NUCLEAR REGULATORY COMMISSION

REGIONlli

Docket Nos.

50-282; 50-306

License Nos.

DPR-42; DPR-60

Report No.

5(. 482/97023(DRP); 50-306/97023(DRP)

Licensee:

Northem States Power Company

.

Facility:

Prairie Island Nuclear Generating Plant

Location:

1717 Wakonade Drive East

Welch, MN 55089

Dates:

December 3,1997, through January 13,1998

Inspectors:

S. Ray, Senior Resident inspector

P. Krohn, Resident inspector

S. Thomas, Resident inspector

Approved by:

J. W. McCormick-Barger, Chief

Reactor Projects Branch 7

9002120155 900130

PDR

ADOCK 05000282

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PDR

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EXECUTIVE SUMMARY

Prairie Island Nuclear Generating Plant, Units 1 & 2

NRC Inspection Report No. 50-282/97023(DRP); 50-306/97023(DRP)

This inspection included aspects of licensee operations, maintenance, engineering, and plant

support. The report covers a six-week period of resident inspection.

fioerations

Management expectations and procedures for conduct in the control room, such as those

delineating the frequency and completeness of main control board walkdowns, were not

always clear, in addition, first line supervisors did not always enforce those procedures

that were clear, such as those relating to communications and control room access

(Section 01.1),

Unit i startup operations from the refueling outage were generally conducted well with no

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significant problems. Procedures were followed and operators remained attentive to

plant indications during plant mode changes (Section 01.2).

One instance occurred during the Unit 1 startup where an operator did not verify that an

annunciator (the ROD AT BOTTOM annunciator) had cleared in a timely manner.

Although this error was not safety significant, it emphasized the need for improvements in

procedure organization and for further evaluation of procedure use expectations

(Section 01.2).

Following the retum to full power operations after the Unit i refueling outage, power was

reduced to 5 percent to allow balancing of the main turbine. Control room activities for

the power reduction, turbine balancing, and retum to full power were conducted well

(Section 01.3).

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During a walkdown of the Unit 2 containment spray and caustic addition systems, the

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inspectors found the systems properly lined-up and ready for safeguards operation. No

significant material discrepancies or system deficiencies were identified that would

prevent either system from performing its intended function (Section O2.1).

Ma'ntenance

Operators involved in maintenar.ce and surveillance activities displayed a good

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questioning attitude and appreciation of radiation dose control (Section M1.1).

A good questioning attitude by an operator resulted in identification of an inadequacy in a

procedure for main turbine torsional testing. However, the initial review of the operator's

concem by engineering was poor, and the concem was not validated until the test was

started and equipment did not respond as expected (Section M1.1).

The inspectors identified that a physics testing procedure had not been followed in that

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the amount of reactor coolant system temperature change called for la the procedure was

not accomplished (Section M1.2).

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The inspectors identified several minor deficiencies in the surveillance Mures for

operational pressure test inspections of the cooling water system (Section M3.1).

Ennineerino

System engineers were heavily involved with all asper:ts of operations, maintenance, and

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testing of their systems. The engineers rapidly investigeled any operational

abnormatities, took an active role in maintenance and troubleshooting activities, and

closely followed alt surveillance testing on the',r systems; however, in one instanca, during

turt>lne torsional testing, a system enginser did net provide adequate technical support

(Section E2.2).

Recer:< findings by tne engineering orgsnization involving the control room ventilation

system and a 10 CFR Part 50, Appendix R issue regarding inadequate separation of

pressurizer level cables indicated that thorough design reviews were being conducted

and reflected a wi'lingness to Idantify and resolve old jesign and compliance issues

(Section E3.1).

Plant Sucoort

Good involvemeM of radiatk,n protection personnel in job p'- aning and execution in order -

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to rnaintain low ooses was observed, as exemplified by the involvement of radiation

protection personnel with operators during performance of a reactor coolant system

integrity test (Sections M1.1 and R1),

An old Appendix R compliance issue involving inadequate separation of pressurizer level

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cables was identified and rapidly corrected as a result of a proactive lic6nsee initiative

(Section F2.1).

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Report Details

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Summary of Plant Status

Unit 1 was restarted upon completion of a refueling outage on December 13,1997, and the

generator was placed on the grid for the first time on December 14. After extensive test 8ng of the

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newly installed turbines, the b,'.it reached full power on December 19. Power on Unit 1 was

reduced to about 5 percent on January g,1998, and the generator was taken off line in order to

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accomplish turbine balancing. The generator was placed back on line January 10 and the unit

retumed to full power on January 11. Unit 2 operated at or near full power for the entire

inspection period.

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l. Operations

01

Conduct of Operations

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01.1

General Comments

a.

inspection Scoce (71707. g2901)

The inspectors conducted frequent reviews of plant operations. The inspectors

performed observations in the control room for extended periods and focused on shift

tumovers, prejob briefs, communications, control room access control, logkeeping,

control boarc monitoring, and general control room decorum. Section 13. "P%nt

Operations," of the Updated Safety Analysis Report (USAR) was reviewed as part of the

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inspection.

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b.

Observations and Findinas

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The inspectors noted that shift tumovers were usually good, covering the status of both

units, on-going maintenance and evolutions, and other specific instructin1s for the safe

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operati sn of the units. However, on two occasions operators arrived late for the moming

control qum shift tumover briefing, missing significant portions of the information -

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presented.

The inspectors observed numerous projob briefs, including briefs for int < rated safety

injection testing, Unit i reactor startup, Unit i reactor physics testing, and Unit i turbine

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overspeed and torsional testing. Generally, the briefs were concise, but thorough. The

inspectors noted that the use of formal communications, the slow and cot trolled conduct

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of the evolution, and reactor safety were common issues stressed in each brief. No

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specific discrepancies were noted.

The inspectors observed operator commu,,ications during numerous evolutions including

both routine and noteroutine operations. While communications were deemed adequate,

they rer.ged from excellent to poor, depending on the evolution in progress and/or crew

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ob. served. Specific observations included:

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- the consistency with which formal ccmmunications were used varied from crew to

crew;

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formal communications tended to be used more frequently during planned

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evolutions, such as reactor startups, but less frequently during abnormal operaHng

situations; and

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communications in the plant were generally not ab formal as those in the

simulator.

During tl o extended periods of control room obscrvation, the inspectors monitorea how

control ri cm access was managed. Section Work Instruction (SWI) 0 2, ' Shift

Organta tion, Operatica, and Tumover," Revision 38, stated that the 'thift supervisor (SS)

  • shall be responsible for maintaining control of personnel entering the control room" and

the lead plant equipment and reactor operator (LPE&RO) shall be responsible for

" granting permission to non-operations personnel for entry Ido the control room."

Implementation of those aspects of SWI O 2 was poor. Specific discrepancies noted in

the control of controt room af4:ss were:

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on numerot.s occasions, instrument and control technicians entered the control

area boundaries within the control room and approached control panelt without

first obtaining permission and/or informing the LPE&RO of their reason for doing

so; and

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on several occasions, personnel entered the control area of the control room and

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approached control panels wecring hard hats even though there was a si-ln,

located at the entry to the control area, which stated that hard hats were not

allowed beyond that point.

The inspectors observed control room operators during the performance of routine log

taking and control board monitoring. The inspectors considered the Operations Log and

the individual Unit 1 and Unit 2 Reactor Logs to be an accurate accounting of shift events

and noted that relevaret shift information was consistently logged. The Inspectors could

find no specific uperator guidance, nor could any be provided by the poneral

superintendent of operations, on the frequency that it.e control berds should be " walked

down." Control board monitoring was considered adequate, but me time between

walkdowns varied widely from crew to crew. Specific discrepancies noted in control

board monitoring were:

the continuous monitoring of control boards exhibited by operators participating in

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graded simulator scenarios was not observed in the main control room;

during one of the inspectors' control room tours, the inspectors noted that over a

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two hour period of time, the only time the Unit 1 panels were walked down was

when the hourly logs were taken;

annunciators were frequently silenced and acknowledgod by a single operator

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without announcing to other control room personnel what the alarm was and the

reasoa for the alarm; and

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the inspectors identified tht.t incorrect work order numbers were referred to in one

reactor log entry. When identified, th SS corrected the log entry.

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The inspec* ors observed the overall control roor.1 decorum during evolutions which

ranged from complex to routine. The inspectors gens, ally categorized the overall

atmosphere as relaxed, but professional. The appropriate level of conoom and

supervisory oversight was demonstrated during complex and Infrequently performed

evo;utions. The SSs and shift managers generally handled administrative matters,

leaving the other control room operators free to monitor and t,ontrol 6ach Unit's operation.

The inspectors noted that some activities detracted from a professional control room

atmosphere, including:

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eating food and/or drinking beverages while , < rating components at a control

panel;

inappropriate screen savers on the computer monitors in the control room;

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extended discussions of toples not related to the operation of the plant; and

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inappropricte material posted on the walls of the SS's area.

c.

Conclusions

Management expectations and procedures for conduct in the control room, such as those

delinteting the frequency and completeness of main control board walkdowns, were not

always clear. In addition, first line supervisors did not always enforce those procedures

that were clear, such as those relating to communications and control room access.

inconsistencies in performance between crews indicated the need for additional guidance

and tialning in this area. The discrepancies discussed above did not lead to any unsafe

conditior,s or violations of NRC requirements. The plant manager informed the inspectors

that a revised section work instruction on control room access and other expectations

was being developed.

01.2 Unit i Retum to.100 Percent Power Operation

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a.

inspection Scope (71707)

The inspectors observed significant portions of operations leading from a refueling

shutdown to 100 percent power operation on Unit 1. Major activities observed included:

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integrated safety injection test;

transition from Mode 5 to Mode 4 (Cold Shutdown to Intermediate Shutdown);

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drawing a pressurizer bubble;

transition from Mode 4 to Mode 3 (Intermediate Shutdown to Hot Shutdown);

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reactor stanup;

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reactor physics testing;

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transition from Mode 3 to 2 to 1 (Hot Shutdown to Hot Standby to Power

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Operation); and

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turbine overspeed and torsional testing.

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included in the startup observations was a review of the appropriate USAR sections and

operating procedures regarding the activities. The inspectors verified that Jpplicablu

surveillance procedures performed as part of the startup met the requirements of the

Technical Specifications (TSF).

b.

Observations and Findinat

For most of the evolutions observed, procedures were properly used and followed.

Operations personnel demonstrated experience and knowledge during the performance

of their tasks. Noteworthy comments on specific evolutions are discussed below.

The inspectors attended the prejob brief and obse ved performance of

surveillance procedure SP 1063, * Unit 1 Irstegrated Safety injection Test With a

Simulated Loss of Offsite Power," Revision 24, from the control room and

emergency diesel generator rooms. The prejob brief was thorough and attended

by the plant manager who stressed proper command and control, personnel

safety, nuclear safety, and equipment protection.

The inspectors observed good command, control, and coordination of activities

during the integrated safety injection test. The complex test required the

coordinated effort of many operations, engineering, and maintenance personnel to

establish the required test conditions and monitor system performance as the test

was performed,

The inspectors observed the prejob brief conducted prior to the Unit i reactor

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startup. Reactivity manegement, expected indications, and personnel roles and

responsibilities were discussed. An extra reactor operator (RO) and SS, in

addition to the normal crew complement, were assigned to perform the startup.

Other plant activities and distractions were kept to a minimum. Nuclear

engineering personnel were also present and perform 3d independent verifications

of reactivity management as the startup progressed.

The inspectors observed the withdrawal of the control banks and dilution to

criticality. The SS and RO remained attentive to reactor power ievels and startup

rate iridications throughout the reactor startup. However, after control

bank A rods had been withdrawn to 129 steps, the RO noticed that tr,e ROD AT

BOTTOM annunciator had not cleared. The reactor operator drove bank A rods

to O steps and a work order was issued to investigate the cause of the

annunciator not clearing at 20 steps as expected. it was deteImined that the

pulse to-analog bistable for control bank D had failed causing the ROD AT

BOTTOM annunciator to remain energized (the position of rods in all four of the

control banks input into the logic for the annunciator).

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Operating Procedure 1C1.2, " Unit i Startup Procedure," Revision 18, Step 5.5.0,

instructed the reactor operator to startup the reactor per Appendix C18, " Appendix

- Reactor Startup," Revirion 6. Appendix C1B was intended to be an aid to the

RO for conducting the startup and was not required to be "in-hand' during the

actual startup evolution since the operator's attention should be focussed on the

control board. Step 5.2.2.C of Appendix C18, required th;; RO to verify that the

ROD AT BOTTOM annunciator (47013-0407) cleared with bank A control rods at

appro41mately 20 steps during the reactor startup. The RO did not perform that

verification until the control bank A rods had reached 129 steps.

Technical Specification 6.5.A.1 required that detailed written procedures for

normal startup of the reactor be prepared and followed. On December 12,1997,

Operating Procedure C18, * Appendix Reactor Startup," Revision 6, Step 5.2.2.C,

was not followed wnen the RO did not verify that the ROD AT BOTTOM

annunciator cleared when rod bank A was withdrawn to approximately 20 steps.

The RO later identified that the annunciator h::J not cleared when he stopped

moving bank A rods at 129 steps. The event was not stafety significant and only

resulted in an equipment problem not being identified as soon as it could have

been. The general superintendent of operations was reevaluating the reactor

startup procedure and c.onsidering adding hold points to refer to the procedure

and conduct the various verifications rather than expect the RO to remember the

entire C1B Procedure. This non-repetitive, licensee luentified and corrected

violation is being treated as a Non-C;ted Violation, consistent with Section Vll.B.1

of the NRC Enforcement Policy (50 282/97023-01(DRP)).

c.

Conclusions

Unit i startup operations were generally conducted well with no significant problems.

Procedures were followed and operators remained attentive to plant indications during

plant mode changes. The ROD AT BOTTOM annunciator cleared verification

requirement in Appendix C1B, Step 5.5.8.C, which should have been performed at

approximately 20 steps on control bank A, was not performed until 129 steps, primarily

because the procedure was not required to be in-hand during the actual startup evolution.

This error emphasized the need for improvements in pocedure organization and further

evaluation of procedure use expectations. The licensee was evaluating possible

improvements.

01.3 Unit 1 Power Reduction for Turbine Balancina and Retum to Fu!! Power Operatim

a,

Inspection Scope f71707)

The inspectors observed significant portions of the Unit 1 power reduction frura

100 percent to approximately 5 percent power, the turbine balancing evolution, and the

subsequent retum to 100 percent power operation conducted from January 9 to

January 11,1998,

b.

Observations and Findinas

The power reduction from 100 percent to 5 percent power was conducted very well. The

inspectors observed excellent communications between all operating crew personnel,

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both inside and outside the control room. The RO and LPE&RO malntained good control

of the plant and awareness of plant parameters, and frequently kept each other informed

of changes in these parameters as indicated on the control room panels. The LPE&RO

executed the require!.ients specified in the Unit 1 power reduction (101.4, " Unit 1 Power

Operation,' Revision 15) and shutdown (1C1.3, * Unit i Shutdown,' ."evision 38)

procedures without error and effectively planned ahead to begin mwntenance activities at

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the earliest appropriate opportunity The SS maintained overall cognizance of the power

reduction evolution, appropriately observing selected actions of the operators.

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A second operating crew was observed performing the turbine stariup after the balanc!ng.

Again, excellent communications and plant control were exhibited. Procedures were

property implemented and the activities were closely supervised. The LPE&RO

controlling the turbine kept the RO closely informed of any changes that could affect the

reactor. The LPE&RO was also observed correcting a system engineer when the

engineer failed to use three way communications over the radio,

c.

Conclusions

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The Unit 1 power reduction, turbine balancing, and retum to full power were conducted

well. Significant improvements were noted c.ompared to the control room etservations

desensed in Section 01.1 of this report.

02

Operational Status of Facilities and Equipment

O2.1 Engineered Safety System Walkdown

a.

Inspection Scope (71707)

The inspectors performed a walkdown of the Unit 2 containment spray and caustic

addition systems as part of the monthly inspections of the Unit 2 engineered safety

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syt,tems. Included in this inspection was a review of USA't, Section 6.4, * Containment

Vessel Internal Spray," Revision 14, and the following diagram::

NF 39252, " Flow Diagram Unit 1 & 2 Caustic Addition System," Revision N;

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NF 39824, " Containment Intemal Spray System Units 1 & 2," Revision B;

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NF 39237, * Flow Diagram, Containment Internal Spray System," Revision AB; and

NF 393331, * Reactor Safety injection ar'i Containment Spray Piping-Unit 2,"

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Revision R.

b.

Observations and Findinas

The inspectors noted that the valves in the main system f'tw paths were in the correct

position, components were properly labeled, locking devices were present and properly

installed, and that power supplies and breakers were properly aligned to support intended

system operation. No discrepancies were noted when comparing the system

components and layout with the system dese.riptions in the USAR. The material condition

of the systems was generally good, with the following exceptions:

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heavy buildup of sodium hydroxide crystals on the valve siem and packing gland

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area of valve 2 CA 20 5; and

light buildup of cheinical residue on the packing glands of valves MV 32110,

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MV 32111, CS 251, CS 40, CS 42, and 2 CA 19-4.

The discrepancies did not affect system operability.

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c.

Conclus[gnt

During system walkdowns, the inspectors found the Unit 2 containment spray and caustic

addition systems lined up and ready for safeguards operation. No significant material

discrepancies or system deficiencies were identified that would prevent either system

from performing its intended function.

08

Miscellaneous Operations issues (92700,92901)

08.1

(Closed) Licensee Event Report 50 306/97005 (2 97-05): Sudden Pressure Lockout of

No.10 Transformer Resulting in Auto Load Rejection /Restcration on Safety Related Bus.

This event was previously discussed in Inspection Report No. 50>282/97021(DRP);

50-306/97021(DRP), Section 01.3. The Licensee Event Report (LER) contained a

detailed description of the event, investigation, and restoration sequence. Despite an

extensive investigation, no cause for the actuation was detem,ined, but the sudden

pressure relay was replaced as a precautionary measure. No additional corrective

actions were initiated since the causa of the actuation was not known.

II. Maintenance

M1

Conduct of Maintenance

M1,1 General Cornments

a.

inspection Scope (61726. 62707)

The inspectors observed all or major portions of the following maintenance and

surveillance activities. Included in the inspection was a review of the surveillance

procedures (SPs) and work orders (WOs) listed as well as the appropriate Updatad

Safety Analysis Report (USAR) sections regarding the activi'ies. The inspectors verified

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that the surveillance procedures reviewed met the requirements of the TSs.

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SP 1018A

Rod Position Indication Cold Calibration, Revision 6

SP 1070

Reactor Coolant System Integrity Test, Revision 26 (400 pounds

per square inch inspection portion only)

SP 1083

Unit 1 integrated Safety injection Test with a Simulated Loss of

Offsite Power, Revision 24

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SP 1089

Residual Heat Removal Pumps and Suction Valves from the

Refueling Water Storage Tank, Revision 46

SP 1194

Cardox [Carben Dioxide) System Test, Revision 8

SP1231

121 Catalytic Hydrogen Recombiner Gas Analyzer Monthly

Functional and Calibration Test, Revision 11

LF 1301

11 Turbine Driven Auxiliary Feedwater Pump Auto Start and

Function Testing Revision 8

SP 1750

Post Outage Containment Closeout inspection, Revision 14

SP 2548

Analog Reactor Control System Calibration, Revision b

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WO 9601293 Motor Operated Valve 32077 Excessive Packing Leakage

WO 9706505 Fuel Oil Storage Tank Tightness Tests

WO 9711674 Modify Tubing for 122 Control Room Chiller

WO 9711686 Modify Tubing for 121 Control Room Chiller

WO 9712636 Turbine Torsional Test

WO 9713386 Annunciator 47013-0407 Doesn't Clear

WO 9713389 G3 and C7 Rod Bottom Bistables Will Not Clear

WO 9713491 Balance Unit 1 Turbine

WO 9715204 Possible Foreign Object Noise on DMIMS (Digital Metal Impact

Monitoring System) Channels 750/751

WO 9715218 Monitor DMIMS Channels 750 and 751 for Noise

WO 9800004 High Average Coolant Temperature Compensator Module Spiking

b.

Observationi md Findinas

For all of the work observed, procedures were properly used and followed except for one

activity discussed in Section M1.2 of this report. Maintenance personnelwere

experienced and knowledgeable of their tasks. The inspectors observed frequent

monitoring of work by system engineers. Noteworthy comments on specific work

activities are discussed below.

For SP 1070, the inspectors accompanied two operators and a radiation

protection technician on an inspection for indications of reactor coolant system

leakage in the Unit 1 containment. Two prejob briefings were held: one involved

the operators and the shift supervisor to discuss the technical aspects of the task,

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and the other involved the operators and a radiation protection superviser to

discuss the radiation protection aspects. The two operators split the areas to be

inspected and carefully planned their routes with the ascistance of the radiation

protection technician to minimize radiation exposure. The inspections were

conducted expeditiously, but thoroughly, No indications of leakage were

identified. The operators displayed a suitable approciation for maintaining their

radiation dose as low as reasonably achievable wt'lle still property conducting the

inspections.

For SP 1089, the operators identified a proceduru enhancement during the

conduct of the test. The test required the operators to record differential pressure

(D/P) in the residual heat removal pump mini-flow recirculation line. Since the D/P

gauge exhibited fluctuations around the actual reading, the procedure allowed the

option of throttling the instrument root valves to dampen the fluctuations. The

operators properly followed the procedure and throttled the root valves, but

performance of that step was quite difficult. The root valves were located in the

next room from the gauge,in a contaminated area, approximately 10 feet off the

floor. The gauge was not visible from the va'ves. Close coordination of two

operators was necessary to complete the task. The operators identif5d that it

would have been much easier to throttle the instrument isolation valves on the

manifold just under the gauge. The chift supervisor initiated action to get the

procedure revised.

Just before throttling the instrument root valves, the local operators questioned

whether there was any other indication or actuation circuitry off the same

instrument lines. They were concer,.ed that they might accidently isolate the line

by overthrottling and cause some kind of problem in other instrumentation. The

operators stopped and resolved their concem with the shift supervisor before

proceeding. The operators displayed a conservative operating philosophy and

questioning attitude during the test,

On December 15,1997, the inspectors observed activities govemed by

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WO 9712636, * Unit 1 Turbine Torsional Testing, required after the replacement

of the turbine generator low pressure rotors. The test measured the torsional

natural frequencies and response levels of the turbine generator shaft system.

Step 8.1.8.f of the turbine torsional test procedure instructed the contrei room

operator to close generator output breaker 6 H 17. The control room operator

displayed a questioning attitude by asking the system engineer if it was necessary

to place the synchroscope selector switch in the BKR 17 position prior to closing

B H 17. The system engineer responded that this was not necessary since the

synchro-check relay had been bypassed. When the control room operator

attempted to close 8-H 17, in accordance with Step 8.1.8.f of the WO, the breaker

did not close. Further review of the electrical schematics with the system

engineer revesk ; that, although a jumper had been installed to bypass the

synchro-check relay in the sivitchyard, the procedure failed to recognize that the

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synchroscope selector switch in the control room needed to be placed in the

BKR 17 position to makeup auxiliary contacts necessary to close 8-H-17. The

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WO was changed, the synchroscope selector switch was placed in the BKR 17

position, and 6 H 17 was closed with its control switch. The Unit 1 turbine

torsional test was completed without further problems.

The turbine torsional test procedure was not appropriatt for the circumstances

because it did not require placing the synchroscope selector switch in the BKR 17

position prior to closing 8 H 17. This was a violation of 10 CFR Part 50,

Appendix B, Criterion V, which required that activities affecting quality be

prescribed by docume:ited instructions, procedures, or drawings, of a type

appropriate to the circumstances. However, the turbine torsional test procedure

problem was not safety significant becauso it simply resulted in the inability to

complete the test untilit was corrected. This non repetitive, licensee-identified

and corrected violation is being treated as a Non Cited Violation, consistent with

Section Vil.B.1 of the NRC Enforcement Policy (50-282/97023-02(DRP)).

For WOs 9715204 and 9715218, the licrasee noted, soon after starting Unit i bp

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from a refueling cutage, metallic noise indications on detectors located on the

reactor vessel. The licensee made recordings of the noise and sent them to

vendors for analysis and made plans to try to identify the source. However, during

the power reduction on Januery 9, the noise stopped as soon as operators started

to insert control bank D control rods. The licansee wes unable to reestablish the

noise by withdrawing control bank D rods while at reduced power, but the noise

recurred when reactor power was at about 95 percent and control bank D rods

were retumed to about 205 steps out. Thus, the licensee believed the noise was

associated with at least one of the control rods and did not represent en

immediate safety concern. At the end of the inspection period, the licensee was

considering further actions to identify the exact cause of the noise.

c.

Conclusions

Operators involved with maintenance and surveillance activities displayed a good

questioning attitude and appreciation of mdiation dose control. A procedure inadequacy

was identified where circuit logle was :,st analyzed thoroughly enough during

devolopment of a work order procodure. System engineers frequently mor:ltored ongoing

work and were generally responsive to maintenance staff concems: ho...for, in one

instance, during the turbine torsional testing, a system engineer did not provide adequate

support.

M1.2 Low Power Physics Testina

a.

Inspection Scope (71711)

The inspectors observed the conduct of various maintenance activities for refueling

startup physics testing on Unit 1. The following maintenance procedures and documents

were reviewed as part of this inspecticn:

D32, " Temperature Coefficient Measurement at Hot Zero Power," Revision 6;

D34, " Boron Endpoint Measurement,' Revision 6;

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D30, * Post Refueling Startup Testing," Revision 27; and

ANSI /ANS (American National Standards Institute, Inc./American Nuclear Society)

19.6.1 1985, * Reload Startup Physics Tests for Pressurized Water

Reactors."

b.

Observations and Findinas

The performance of maintenance activities associated with Procedure D34 required a

significant number of control rod position manipulations. The reactor operator (RO)

exercised good control over reactivity during the selected individual manipulations of all

the shutdown and control bank control rods. Good coordination was observed between

the reactor operator and the nuclear engineer assisting with the procedure. Good

supervisory oversight was provided by the shift supervisor in that he provided a second

verification that the correct rod bank was selected prior to control rod movement.

The inspectors also observed test activities associated with Maintenance Procedure D32.

These activities were required to be performed twice during low power physics testing:

once with all the control rods withdrawn and once with all rods withdrawn except for the

[

control bank A, which was fully inserted. The purpose of the procedure was to determine

the isothermal temperature coefficient (lTC) at an established condition below the point of

adding heat and to verify that it was less that 5 percent millirho per degree Fahrenheit, as

required by TS 3.1.F,1.

The actual performance of the test, after initial plant conditions had been ostablished,

was accomplished by performing a reactor coolant system (RCS) cooldown followed by a

heatup. During each trsasient, a plot of reactivity versus temperature was obtained

during which time boron concentration and control rod position were kept essentially

constant. The magnitude of the cooldown and heatup, as required by Steps 7.2 and 7.3

of Maintenance Procedure D32, was approximately 5 degrees Fahrenheit ('F). More

specific guid1nce was contained in ANSI /ANS 19.6.1 1985 which was listed as a

reference for D32. Standard ANSI /ANS 19.6.1 1985 stated, as part of the test method to

determine the ITC, that reactivity and temperature should be continuously recorded while

RCS temperature is increased (decreased) by 3-10 *F.

During the second test per D32, the inspectors identified that an RCS cooldown of 2.4 'F

and an RCS heatup of 1.2 'F were used to determine the value for ITC. When the

inspectors questioned the nuclear engineer conducting the test about the procedural

requirement for an approximate 5 'F cooldown (heatup) while obtaining ITC data, i'.ie

nuclear engineer said that a sufficient RCS temperature change had been performed and

that the data was good enough to calculate ITC. The inspectors also discovered that the

first time the ITC test was performed with all control rods out, a 2.3 'F cooldown and

a 1.8 *F heatup were used. These discropancies were brought to the attention of the

superintendent of nuclear engineering. He agreed that Maintenance Procedure D32 was

not followed as written. He also said that because it was difficult to maintain a steady

cooldown (heatup) over a range in excess of about 3 'F, that the cooldown (heatup)

portions of the test had usually been performed with less than an approximately 5 *F

temperature change for many years.

14

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The inspectors detormined that sufficient temperature changes were accomplished to

obtain adequate data for calculation of the ITC, so this violation was of low safety

significance. However, failure to perform the ITC test per Procedure D32 as written, or

revise the procedure, despite numerous opportu,nties, demonstrated a lack of

appreciation for procedural requirerrents. There have been several cited violations for

failure to follow procedures documented in previous inspection reports. In addition, the

importance of procedure adherence was one of the topics in two recent management

meetings Corrective actions Mr the previous violations should have prevented this

procedure noncompliance, in addition, this violation was identified by the NRC.

Therefore, the event did not meet the criteria for discretion in the NRC Enforcement

Policy.

The failure to perform maintenance activities associated with Procedure D32 as written

was a violation of TS 6.5.A.4, which required that the licensee prepare and follow detailed

written procedures that control surveillance and testing requirements that could have an

effect on nuclear safety (50-282/97023-03(DRP)).

c.

Conclusion

The inspectors concluded that both the operators controlling the plant and the nuclear

engineers coordinating the performance of maintenance activities associated with

Procedure D32 Jid not follow the written instructions provided in the procedure pertain'ng

to the magnitude of cooldown (heatup) required forITC de armination. Even though the

engineers knew the proceduie requirements, they chose to do what had worked in the

past, instead of evaluating the way they were performing the test and changing the test to

reflect the actual test practice. This demonstrated a lack of appreciation for strict

compliance with procedural requirements.

M3

Maintenance P.-ocedures and Documentation

M3.1 Coo:ina Water System Walkdown and Suweillance Procedure Review

'i .

Inspection Scope (71707. 62707)

The inspectors conducted a walkdown of the Unit 1 and Unit 2 cooling water systems,

included in the inspection was a review of USAR, Section 10.4, * Plant Cooling System,"

Surveillance Procedures SP 1168.8, * Cooling Water System Operating Pressure Test,"

Revision 9, and SP 1168.8A, * Cooling Water System Auxiliary Operating Pressure Test,"

Revision 0, and a detailed review of the following American Society of Mechanical

Engineers (ASME) Code drawings:

NF 39819-1,'Cooiing Water ASME Code Classification Screenhouse Unit 1,"

Revision B;

NF 39819-2, * Cooling Water ASME Code Classification - Turbine Building Unit 1,"

Revision B;

NF 39819 3, * Cooling Water ASME Code Classification - Auxiliary Building Unit 1,"

Revision D;

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NF 39819-4," Cooling Water ASME Code Classification Containment Unit 1,

Revision C;

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NF 39841 1, * Cooling Water ASME Code Classification Turbine Building Unit 2,*

Revision A;

e

NF 398412," Cooling Water ASME Code Classification Auxiliary Building Unit 2,*

Revision E;

e

NF 398413,' Cooling Water ASME Code Classification Containment Unit 2,*

Revision C;

i

e

NF 39822, * Prairie Island Nuclear Generating P! ant Fuel and Diesel Oil System -

!

Units 1 & 2 ASME Code Classification Sheet 17," Revision A; and

)

NF 39833," Lab Service Area and Chilled Water Safeguards Systems -

I

Unt'.s 1 & 2 ASME Code Classification - Sheet 26," Revision D.

'

b.

Observations and Findinas

The inspectors observed the material condition of the Unit 1 and Unit 2 cooling water

systems and did not identity any significant discrepancies. All equipment and systems

matched the description found in USAR Section 10.4. However, surveillance Procedures

SP 1168.8 and SP 1168.8A contained 21 discrepancies.

,

SP 1168.8 and SP 1168.8A were required by TS 4.2 and the licensee's ASME Code

Section XI Insery!ce Inspection and Testing Program. Each surveillance was performed

at leasi once every 3% years. The surveillance directed that personnellook for evidence

of component leakage, structural stress, and corrosion, and that they inspect hangers

and restraints to detect any loss of support capability, missing or loose bolts, corrosion,

ed other problems.

SP 1168.8 contained the following procedural discrepancies:

a 12" diameter section of the cooling water supply line to the 22 component

e

cooling water heat exchanger was not required to be inspected by SP 1168.8;

a 24" diameter section of the Unit 1 cooling water retum header located just

e

upstream of the auxiliary building / turbine building wall penetration was not

required to be inspected by SP 1168.8;

e

two instances where SP 1168.8 listed valves not shown on the ASME Code

drawings;

three instances where the valve designations on the ASME Code drawings did not

e

match the valve numbers included in SP 1168.8;

one instance where ASME Code drawing NF 39819-3, Revision B, showed two 1"

e

diameter cooling water is otation valves in the same line when only one existed in

the plant; and

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une instance where two separate steps called for inspecting the same section of

the 24* loop A cooling water header.

.

SP 1168.8A contained 12 instances where valves named in the procedure as requiring

inspection were shown but not labeled on the referenced ASME Code drawings.

The inspectors noted that both SP 1168.8 and SP 1168.8A contained the same

precaution and limitations section S'.ep 3.2 stating,"The individual sign off steps are

intended as a guide; use the Code drawings and/or isometrics to verify alllines are

inspected." In most cases, using the ASME Code drawings and carefully tracking each

section of line inspected would preclude the inspector from missing portions of the Unit 1

and 1.' nit 2 cookng water system not described in SP 1168.8 or SP 1168.8A. In at least

two cases, however, SP 1168.8 or SP 1168.8A included the inspection of valves not

described on the ASME Code drawings. By usli '; the surveillance procedures, Code

drawings, and Isometric drawings as directed, individuals cc a orrectly perform the

inspection. Therefore, the procedures were not considered ... adequate.

The inspectors discussed the above findings with the system engineer prior to the exit

interview. The system engineer took prompt action to correct SP 1168.8, SP 1168.8A,

and the ASME Code drawings for the inspector identified discrepancies note.1 above,

c.

Conclusions

Several procedural deficiencies were identified in SP 1168.8 and SP 1168.8A. None of

the deficiencies were safety significant because the surveillance also required the use of

drawings to confirm that all sections of piping were inspected. However, the deficiencies

made the inspection task more difficult.

The cooling water system had recolved a great deal of review over the previous three

years in a licensee self assessment and NRC inspections. The inspectors were

concerned that a system that had received so much recent attention could still have

procedures containing so many errors. The inspectors considered SP 1168.8 and

SP 1168.8A reflective of the need to further improve pmcedures.

The licensee recently completed a pilot program to review a sampling of surveillance

procedures for accuracy and compilance with the writer's guide. Errors were reportedly

found in each of the surveillance procedures reviewed. The licensee was making plans

to extend the scope of the procedure review in light of those findings.

M3.2 Procedural Weaknesses Identified Durina Auxiiiarv Feedwater Pumn Testina

,

a.

ingoection Scope (61726)

The inspectors attended the prejob brief and observed the performance of testing per

SP 1301, "11 Turbine Driven Auxiliary Feedwater Pump A a Start and Function Testing "

Revision 8. The inspectors reviewed SP 1301 for procedural adequacy and compliance

with TS 4.8.A.8 and Table 4.1-1C, items 26 and 27, and USAR Section 11.9.

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b.

Observations and Findinns

The projob brief for SP 1301 was thorough and discussed communications, impacts of

ongoing Unit 2 electrical plant shifts with the surveillance, worker responsibilities, and the

procedural steps involved in each of the five functional areas being tested. During the

performance of the surveillance; however, three typographical errors were noted. Two

errors were Identified by the inspectors observing the evolution and one by the control

room operator supervising the surveillance. These errors are described below.

_

Stop 7.10.28 directed instrument and control personnel to positi,:a three switches in the

1 ARP5 Reactor Protection Logic Test Cabinet.1 he three switches in this cabinet were -

labeled 81, S2, and S3. Step 7.10.28, however, contained a typographical error and-

referred to the switches as S1,82, and S2. The error was so obvious that the

technicians performing the surveillance had no problems. The inspectors brought the

error to the attention of the operator who notified the control room.

Stop 7.11.5 verified that the AMSAC [ Anticipated Transient Without Scram Mitigation

System Actuation Circuit] INACTIVE annunciator in the control room was ON. The step,

however, contained a typographical errnt and identified the annunciator location as

47074 0606 when the correct location was 47014-0606. The noun name description for

the annunciator was correct in the procedure so it did not cause a performance problem.

The operator supervising the surveillance ir, the control room identified this error,

in Step 7.15.6, an operator was directed to push the 11 turbine-driven auxiliary feedwater

pump local stop push button Step 7.15.6 con:sined a typographical error and r.pecified

depressing the time delay reset push button PS 5101801 instead of the actuallocal stop

push button, PB-5101803. The noun name description in the procedure was correct so

the operator performed the correct action, even though the push button number was

incorrect. The inspectors observing the surveillance noticed this error and brought it to

the attention of the operator. The operator informed the control room.

The control room operator supervising performance of SP 1301 submitted procedure

deviation requests to correct the errors noted above following completion of the

surveillance.

c.

Corclusions

The three typographical errors identified in SP 1301 had no safety significance and did

r,ot prevent satisfactory performance of the surveillance. The inspectors were concemed,

however, that two of the three errors were NRC-identified and not noticed by the five

licensee personnel (one electrician, one instrument and control technician, two outplant

operators, and one control room operator) actually conducting the surveillance, in the

case of the two NRC-identified errors, the test performers did not use proper self-

= checkin2 techniques. They did not adequately check the switch numbers listed in the

procedure against the actval component label before completing the action.

SP 1301 was reviewed by the Operations Committee on Coptember 17,1997, and

approved by the superintendent mechanical systems on November 29,1997. This was

after the licensee placed a renewed emphasis on procedural adequacy and compliance.

- The three errors identified li. ::P 1301 highlighted the need for continued efforts in this

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area. As noted in Section M3.1 of this report, the licensee was evaluating an expanded

surveillance review program.

M8

Miscellaneous Maintenance Activities (92700,92902)

)

M8.1 (Closed) Inspection Followup Item (IFI) 50-282/97005 03fDRP): 50 306/97005-03(DRP):

'

Reactor Coolant System Vent and Containment Boundary Control During Integrated

Leakage Rate Test. This issue was previously discussed in inspection Report

No. 50-282/97005(DRP); 50-306/97005(DRP), Section M1.1. It involved a licensee-

identified procedure error in Unit 2 surveillance Procedure SP 2071.4, * integrated

Leakage Rate Test Prerequisites to the Containment Vesse! Integrated Leakage Rata

Test," Revision B. The test procedure was written in such a way that the reactor coolant

system could be vented before containmg.t integrity was established, which would have

been a violation of TSs. The inspectors verified that the Unit 1 test, SP 1071.4,

" Prerequisites to the Containment Vessel Integrated Leakage Rate Test," Revision 6, had

been revised to eliminate the problem before it was used. The inspectors also verified

'

that the system engineer had submitted a procedure revision form to ensure that the

Unit 2 procedure would be revised before its next use. The next expected Unit 2

integrated leakage rate test was planned to be conducted in the year 2006.

Ill. Enoineerina

E2

Engineering Support of Facilities and Equipment

E2.1

Review of Updated Safety Analysis Report (USAR) Comntitments (37551. 92903J

While performing the inspections discussed in this report, the inspectors reviewed the

applicablo portions of the USAR that related to the areas inspected and used the USAR

as an engineering / technical support basis document. The inspectors compared plant

practices, procedurcs, and/or parameters to the USAR descriptions as discussed in each

section. The inspectors verified that the USAR wording was consistent with the observed

plant practices, procedures, and parameters. No discrepancies were noted.

E2.2

General Comments (37551)

Throughout the inspection period, 'Se inspectors noted frequent involvement by system

engineers in all aspects of plant operations, refueling, maintenance, and surveillance

activities. The engineers rapidly investigated any operational abnormalities, took an

active role in maintenance and troubleshooting activities, and closely followed all

surveillance testing on their systems.

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E3

Engineering Procedures and Documentation

E3.1

ftilure to Test the Auto Start Feature of the Control Room Ventilation System Air

Handlers Due to Procedure Deficiency

a.

Inspection Scope (g2700)

On December 7,1997, as part of an investigation in response to NRC Generic

Letter 96 01, " Testing of Safety related Logic Circuits," the licensee discovered that the

automatic start of the 121 and 122 control room air handlers upon a st:rt of the

associated 121 and 122 control room cleanup fans, which was required to be tested by

TSs, had not been tested. The inspectors reviewed the circumstances and corrective

actions for the finding,

b.

Observations and Findinos

Technical Specification 4.14.A.2 required, in part, that once per operating cycle or once

every 18 months, whichever occurs first, the automatic initiation of the control room

special ventilation system be demonstrated with a simulated high radiation or safety

injection signal. A high radiation or safety injection signalis designed to start the control

room cleanup fans and operate various dampers. Starting of the clesnop fans will

subsequently result In the start of the main air handler fans. Without the air handler fans

running, the cleanup fans would be ineffective in performing the function of reducing

airborne radioactivity for control room operators.

The licensee discovered that the surveillance had normally been per4ormed with the air

handler fans already running in order to test the isolation function of the outside air

dampers. Thus, one of the automatic features had not been tested.

As discussed in the Licensee Event Report (LER 19718) for the finding, shortly before

the time of discovery, the auto start feature of both trains of control room ventilation had

coincidently been tested as part of a pre-operational test for a modification of the related

power supplies. The auto start features functioned normally during those tests. While

this indicated that the air handler fans' automatic start feature was functional, the failure

to test it as part of a formal surveillance test reflected a programmatic weakness in tha

surveillance testing program. The LER stated that the survelliance proceduret would ue

revised prior to the next scheduled test to require testing of the auto start feature. The

LER will rema.in open pending completion of the revisions (LER 50-282/97018;

50-306/97018).

The failure to perform a surveillance test of the auto start feature of the control room alt

handlers was a violation of TS 4,14.A.2. This non-repetitive, licensee-identified and

corrected violation is being treated as a Non-Cited Violation, consistent with

Section Vll.B.1 of the NRC Enforcement Policy (50-282/97023-04(DRP);

50-306/97023-04(DRP)).

c.

Conclusions

This finding, and the ones discussed in Sections EB.1 and F2.1 of this report indicated

that the licensee was conducting thorough design reviews in response to Genotic

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Letter 96 01 and other concems. Licensee employees demonstrated a wil:ingness to

identify old design discrepancies and compliance problems and the licensee rapidly

resolved those issues.

E8

t,11scellaneous Engineering issues (92700,92903)

E8.1

(Clesed) LER 50 282/97015: 50-306/97015 fi 9715h Both Trains of Control Room

Special Ventilation System Simu'taneously Inoperable. This LER discussed an issue,

identified on November 'J,1997, in which the licensee determined that routine

performance of a monthly surveillance on steam exclusion dampers had resulted in both

trains of control room sponial ventilation being inoperable because outside air dempers,

opened for the surveillance, would not have automatically closed on actuation of the

system on high radiation or safety injection. This could have resulted in the control room

operators' dose being higher than General Design Criterion 19 limits.

The cause of the event was the failure to properly review the control room ventilation

cystem logic and design requirements when the steam exclusion damper surveillance

was devcloped. The Feensee identified the issue as part of the development of revised

main steamline break control room dose calculations. As discussed in the LER, the

condition existed for only a few minutes each month and the operators would have had

ample indications and controls available to identify the problem and close the dampers if

an accident had occurred. The inspectors verified that all of the corrective actinns

discussed in the LER had been completed.

Monthly performance of the steam exclusion damper surveillance resulted in both trains

of control room special ventilation being inoperable, contrary to the requirements of

TS 3.13.A.1 which required that both trains be operable at all times. Although the TS

was violated, the associated action rwquirement to initiata within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the action

necessary to place both units in hot shutdown, and be in at least hot shutdown within the

next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> and terminats core

alterations / fuel handling operations within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, was probably never exceeded.

This non repetitive, licensee identified and corrected violation is being treat?d as a

Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy

(50 282/97023-05(DRP); 50 306/97023 05(DRP)).

IV. Plant Suooort

R1

Radiological Protection and Chemistry Controls (71750)

During normal resident inspection activities, routins observations were conducted in the areas of

radiological protection and chemistry controls using inspection Procedure 71750. No

discrepancies were noted. The inspectors noted good involvement of radiation protection

personnel in job planning and execution in order to maintain doses as low as reasonably

achievable.

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Conduct of Emergency Preparednees Activities (71750)

During normal resident inspection activities, routine observations were conducted in the area of

emergency preparedness using Inspection Procedure 71750. No discrepancies were noteo.

81

Conduct of Security and Safeguards Activities (71760)

During normal resident inspection activities, routine observations were conducted in the areas of

security and safeguards activities using Inspection Procedure 71750. No discrepancies were

noted.

F2

Status of Fire Protection Facilities and Equipment

F2.1

Separation of Pressurizer Level Indication Channels Not in Comollance with

10 CFR Part 50. Accendix R. Section Ill.G.2

a.

laspection Smoe (92700)

On December 6,1997, the licensee reported to the NRC in accordance with

10 CFR 50.72 that the plant was in a condition outside of the design basis because the

licensee had discovered that the pressurizer level channel cables in Unit 1 containment

were not separated as required by 10 CFR Part 50, Appendix R. The inspectors

r

reviewed the circumstances and corrective actions for the finding,

b.

Qbtervations and Findinas

The issue was first identified during a walkdown of the containment on

November 14,1997, to support an Appendix R Safe Shutdown Analysis revision. The

licensee noted that the pressurizer level detectors were not located as shown on plant

layout drawings and that the pressurizer level channels old not have adequste separation

of the detectors and the associated cables to meet the requirements of Appendix R. The

drawings indicated adequate separation but the as Lailt configuration did not match the

drawings.

At first the licensee believed that an exemption from the NRC might have been grants d

for the existing installation. As discussed in the associated Licensee Event Report

(LER 1-97-17), the documentation regarding various Appendix R exemptions was

somewhat confusing and incomplete. By December 6, the licensee determined that an

appropriate exemption did not exist and the cabling would have to be modified to meet

Appendix R.

Within the next few days a modification was developed and installed to provide a

'

noncombustible radiant energy shield around one channel of the cabling to satisfy

Appendix R requirements. The inspectors walked down the installation and it appeared

that the energy shieH was adequate.

The licensee issued LER 19717 on January 2,1998. The inspectors reviewed the LER

and determined that it adequately discussed the beckground, safety significance, and

corrective actions for the subject Appendix R non compliance. The LER will remain open

pending completion of corrections to the plant layout drawings (LER 50-282/97017).

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Sedion lll.G.2 of App 9ndix R, of 10 CFR Part 50, requires, in part, that cables and

equipment and associated non safety circuits of redundant trains of equipnient necessary

to achieve and maintain hot shutdown conditions in non-inerted containments, be

4

4

protected from potential fire Jamage. This could be achieved through separation of

more than 20 feet with no intervening combustibles or fire hazards or by having installed

a

'

fire detection tend automatic suppression, or through separation by noncombustible

j.

radiant energy shields. The licensee 6dentified that the redundant pressurizer level

i

detector cables in :he Unit 1 containment did not satisfy any of these conditions and thus

'!

a violation of NRC requirements existed. As discussed in the LER, the condition had

j

M!stively low safety significance and was promptly corrected when the noncon.pliance

j

was confirmed. Thi6 non repetitive, licensee-identified and corrected violation is being--

treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement

Policy (50 282/97023-06(DRP)).

i

}

c.

Conclusions

f

The licensee's finding was the result of a proactive voluntary review of fire protection

.

i

issues and revision of tire protection analysis. Prompt corrective actions were taken

3

when the condition v as confirmed.

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V Mananoment Meetinos

,

X1

Exit Meeting Summary

The inspectors presented the inspection retu;is to members of the licensee management at the

conclusion of the inspection on January 13,1998. The licensee acknowlectged the findings

presented. The inspectors asked the licensee whether any materials examined during the

4

inspection should be considered proprietary No proprietary information was identified.

$

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0-

PARTIAL List OF PERSONS CONTACTED

Licensee

J. Sorontsn, Plant Manager

K. Albrecht, General Superintendent, Engineering, Electrical / Instrumentation & Controls

T. Amundson, General Superintendent, Engineering, Mechanical

J. Goldsmith, General Superintendent, Engineering, Generation Services

J. Hill, Manager, Quality Services

G. Lon3rtz, General Superintendent, Plant Maintenance

J. Maki, Outage Manager

D. Schuelke, General Superintendent, Radiation Protection and Chsmistry

T. Silverberg, General Superintendent, Plant Operations

M. Sleigh, Superintendent, Security

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lNSPECTION PROCEDURES USED

l

lP 07551:

Engineering

IP 61726:

Surveillance Observations

IP 62707:

Maintenance observations

IP 71707:

Plant Operations

IP 71711:

Startup from Refueling

IP 71750.

Plant Support Activities

IP 92700:

Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor

Facilities

IP 92901:

Follow up - Operations

IP 92902:

Follow up - Maintenance

IP 92903:

Follow up - Engineering

ITEMS OPENED, CLOSED, AND DISCUSSED

Qllen9A

50-282/97023-01(DRP)

NCV

Failure to Perform Step in Reactor Startup Procedure

When Called For

50-282/97023-02(DRP)

NCV

inadequate Procedure for Turtaine Torsional Testing

50 282/97023-03(DRP)

VIO

Failure to Perform Two Steps in Reactor Physics Testing

Procedure as Written

50-282/97023-04(CRP)

NCV

Failure to Test the / % Start Feature of the Control Room

50 306/97023-04(DRP)

Ventilation System il- Handlers due to Procedure

Deficiency

50-282/97023-05(DRP)

NCV

Both Trains of Control Room Special Ventilation System

50-300'97023-05(DRP)

Simultaneously inoperable

50 282/97023- 06(DRP)

NCV

Separation of Pressurizer Level Indication Channels Not in

Compliance with 10 CFR Part 50, Appendix R,

Section Ill.G.2

50 282/97017 LER

Separation of Pressurizer LevelIndication Channels Not in

Compliance with 10 CFR Part 50, Appendix R,

Section Ill.G.2

50-282/97018

LER

Failure to Test the Auto-Start Feature of the Control Room

5B Gi97013

Ventilebon System Air Handlers due to Procedure

Deficiency

Closed

50-282/97005-03(DRP)

IFl

Reactor Coolant System Vent and Containment Boundary

(.

50-306/97005-03(DRP)

Control During Integrated Leakage Rate Test

50-306/97005

LER

Sudden Pressure Lockout of No.10 Transformer Resulting

in Auto Load Rejection / Restoration on Safety-Related Bus

25

(

~

.

, ' ?. 0

.

.

50-282/97015

LER

Both Trains of Control Room Special Ventilation System

!

50-306/97015

Simultaneously Inoperable

1

26

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,

..

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, . ',i %

1*

LIST OF ACRONYM 8 USED

AMSAC

Anticipated Transient Without Scram Mitigation System Actuation Circuit

ANSI /ANS

Americcn National Standards Institute, Inc/American Nuclear Society

ASME

American Society of Mechanical Engineers

CFR

Code of Federal Regulations

D/F

Differential Pressure

DRP

Division of Reactor Projects

DMIMS

Digital Metal impact Monitoring System

'F

Degrees Fahrenheit

IP

inspection Procedure

ITC

isothermal Temperature Coefficient

LER

Licensee Event 9eport

LPE&RO

Lead Plant Equipment and Reactor Operator

NRC

Nuclear Regulatory Commission

PDR

Public Document Room

RCS

Reactor Coolant System

RO

Reactor Operator

SP

Surveillance Procedure

SS

Shift Supervisor

SWI

Section Work Instruction

TS

Technical Specification

USAR

Updated Safety Analysis Report

WO

Work Order

? :

27

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I