GO2-85-207, Forwards Response to Notice of Violation Contained in NRC .Corrective Actions:Diesel Generator Abnormal, Operating & Surveillance Procedures Changed to Include Addl Statement Re Adjustment to Rated Voltage

Forwards Response to Notice of Violation Contained in NRC .Corrective Actions:Diesel Generator Abnormal, Operating & Surveillance Procedures Changed to Include Addl Statement Re Adjustment to Rated Voltage

ML20116M479
Person / Time
Site:	Columbia
Issue date:	04/17/1985
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
EA-85-030, EA-85-30, GO2-85-207, NUDOCS 8505060249
Download: ML20116M479 (13)

Text

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Washington Public Power Supply System P.O. Box 968 3000 GeorgeWashington Way Richland, Washington 922 (509)372-5000 Docket No. 50-397

' April 17,1985 G02-85-207 Mr. J.B. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC ENFORCEMENT ACTION EA 85-30 The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated March 19, 1985. Our reply pursuant to the provisions of Section 2.201, Title 10 Code of Federal Regulations, consists of this letter and Appendix A (attached).

In Appendix A, an explanation of the violation is presented, the cor-rective steps taken with results achieved are outlined, and the date of full compliance is specified.

Should you have any questions concerning our response, please do not hesitate to contact me.

G.C. Sorensen Manager, Regulatory Programs GCS:m Attachment 397 PDR

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APPENDIX A u

. As a L result of the inspection conducted during the period January 31 -

February 15,- 1985, and in accordance with the General Statement of Policy and

Procedure for NRC Enforcement Actions,10. CFR Part 2 Appendix C, as revised, 49 FR 8583 (March 8,1984),:the following-violations were identified:

' A .- Notice of Violation -

1 Technical : Specification - 3.8.1.1 requires three separate and independent

= diesel : generators to be operable in operational conditions 1, 2 and 3. ,

Action statement "f" . states that with DG-1 -and DG-2 inoperable, restore

- at .least one of the inoperable diesel generators to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> : or be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 4

and in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

I Contrary to the' above, during the period January 21 to 31,1985, both

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i diesel; generators - DG-1 and DG-2 were inoperable. The capability of the  ;

- generators to tautomatically assume' the essential load was defeated. The voltage regulator for each generator was set at about 3700 volts. The generator' voltage -must reach about .3910 volts . to satisfy a permissive

. relay to allow closure of the generator output breaker and thus pennit automatic loading of the electrical bus.

p This is a Severity Level III Violation (Supplement I).

I: 1. Validity of Violation The Supply System concurs with the validity of this violation.

2.. Reason for Violation

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A loss. of normal and preferred power occurred and the- Division I and Division II Standby Diesel Generator sets; received a start signal.

l .Both : diesels automatically started and accelerated to rated speed.

[ During an inspection of the diesel generators, approximately one half hour following- the scram,. a Plant engineer observed Division I and Division II diesel generator (DG). output voltages of. 3700-3800

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VAC. Rated voltage is 4,160 VAC. : Control room personnel were im-mediately notified of. this discrepancy 'and :the; generators voltages Lwere adjusted to normal values. -

- An investigation revealed : that on January 21,. 1985,. the - voltage

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adjusting motor operated potentiometers: (M0P's) had been run to .

. their lowest voltage setpoint. Following is 'a ' description' of the-l l actions leading to this. event: On January 21,1985,: Plant operators noticed:an~ illianinated voltage regulator limit indication for DG #1 in the control . room. This limit. light indicates that the MOP'is- at  ;

the high or low limit of its- travel. No' procedural guidance existed to direct operators on* required followup actions. During an invest-t l

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igation as to ' the cause of this indication, the DG #1 M0P was adjusted to its low limit point. During MOP operation, a shift electrician ' attempted to verify operation of the limit switches

!- which provided the:high/ low limit signal. Upon examination of the MOP, it . was---discovered ; that the operating can for these limit switches had slipped and .was providing an erroneous signal. The DG

1. 2 MOP was then operated and correct operation of its limit switches confimed.- It was. determined that a Maintenance Work Request (MWR)

would be required to. adjust-~the DG #1 limit switches._ It was felt that the can adjustments did .not affect MOP operability, and it was decided that the adjustment could be performed during the next planned maintenance ' outage. This decision process did not mceive further -management review. The M0P's for both DG #1 and DG #2 were

.left at - their minimum voltage adjustment positions. It was errone-

.ously believed that once the MOP control switch was released, the MOP would return to 'a position that .provided nomal voltage output 1

for the DG's. The Division III High Pressure Core Spray DG is designed with:this provision.

In summary, the MOP design allowed the potentiometers to be adjusted

while the generator was not operating. The. engineer responsible for

, the 'startup testing of these diesel generators did not provide input to the operating procedure ~ concerning the voltage adjust high and low limit lights. : The procedure did not contain a caution to Plant L  : operators concerning-the fact that voltage could. be adjusted outside

. the range which was required for automatic breaker closure. Nor was a caution present to indicate that if the voltage regulator was adjusted, while the diesel ' generator was secured, the . voltage would

not return to a preset value - upon starting. These precautions should have been included in the procedure. The . absence of these

, precautions is considered a personnel error which resulted in- deft-cient procedures.

l The condition which.made the Division 1 and Division 2 diesel gener-ators inoperable for a ten day period was not readily apparent. The voltage regulator was set at approximately 3700 Volts with no con-trol room ~ or local indication to specifically indicate this condi-tion. This- condition did not prevent the diesels from starting but-l would have prevented the diesel generator output breaker from auto-matica11y closing onto - their respective buses. - Had the condition existed requiring the diesels to provide power to their respective.

buses, the low voltage-condition would then become apparent and cor-

! mctive action would be taken. This- is not to imply ~ that tech-

'nically the. diesels were operative; but .only to state a fact that the diesel generators were available to supply. their emergency buses dependent upon operator action..

3. Cormctive Steps Taken/Results Achieved

a. Upon notification of the' voltage conditions, the control room immediately adjusted the DG MOP's. to obtain the correct ~ voltage setpoint.

n Lb. The control circuitry for both Division I 'and Divisions II diesel generators has been modified to preclude MOP operation while the DG's are shutdown.

c. Thel . diesel . generator .'abnomal, . operating and surveillance procedures have been changed to include an additional statement

. which requires MOP adjustment to obtain rated voltage after the output breaker has been opened.

d .' Operator knowledge of certain aspects of the Standby DG. opera-4

-tion was judged deficient and the training program and material were reviewed - to identify specific corrective actions. As a

' result _ the current. cycle of . operator requalification- training a - has been modified to include 1)= a briefing by the Plant engi- ,

neer detailing DG control circuit modifications to the MOP's-

. 2) a fomal session on- Licensee Event Reports (LER's) related to the event. Additionally, a deficiency was discovered in the i simulator, modeling of the 'rtPCS DG MOP circuit which will be

corrected.-

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'e. The Non-Conformance Reports (NCR's), LER's, MWR's, Plant Mod- ,

' ification Record (PMR) and NRC~' Notice of Violation Letter relating to Enforcement Action EA 85-30 ~have been placed in the required reading book- for operations personnel.

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f. Between February 28, 1985 an1 March 15,1985 the Operations

.' Manager held the following staff meetings with Operations j personnel:

1) Crews B,C,E & F between February 28 and March 6, 1985 regarding NRC enforcement conference, LER 285-008 and j- further corrective-action.

2) Crews B & -F on March 7,1985, Crews A,C & D on March 12, 1985 and Crew E. on March 15,- 1985 regarding Management philosophy on DG issue. ' This . reinforced the various administrative procedure mechanisms that ' identify ~ Plant operating problems- and which provide the - necessary feed-back ' to the Plant staff and Management- for future- review and followup action.

The results achieved:-

t. <In summary, positive corrective . action has been implemented by way of required reading, staff meetings,- training, ' design and procedural changes.- lThe control . circuit design. change prevents the possibility of this event recurring?by precluding changes to the voltage adjust-ment M0P while the DG units are shutdown.- Operators are also pro-cedurally required (by lan additional ~ statement in the - procedure) to verify . that correct fvoltage' conditions exist prior to securing the

. units. This ensures the MOP adjustment will 1 attain the correct .

- voltage conditions on both manual and automatic DGLstarts.

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4. Corrective Steps To Be Taken Operator requalification training will continue thru the full cycle covering all crews. . Additional modifications are being evaluated to provide slow start capability and an automatic reset feature for the

. MOP circuit.

5 .' Date When Full- Compliance Will be Achieved a.. Training cycle completion May 10, 1985.

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b. The evaluations to determine the design changes required to provide slow start and MOP automatic reset circuitry features .

will be' completed at a later date and is not considered neces-sary for full compliance. It is mentioned only to point out that with the - preplanned design change fully implemented, this event would not have occurred.

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- B. - Notice of. Violation 10 CFR Part > 50, Appendix B, Criterion Y requires, .in part, that for safety related - functions, activities 'affecting quality be prescribed by documented instructions, . procedures, or drawings, of a type appropriate to the circumstances and shall include appropriate quantitative or quali-tative acceptance criteria for determining that important activities have been satisfactorily accomplished. .

. Technical Specification 6.8.1 requires, in part, that written procedures

.shall be established, implemented, and maintained covering the activities referenced in

Appendix A of Regulatory Guide 1.33, Revision 2. Regula-tory Guide 1.33, Appendix A, part 4.w(2)(a), requires that instructions I for . energizing, startup,. shutdown, and changing modes of operation be '

prepared for Emergency Power Sources.

Contrary to the above, on January .21,1985, the diesel generator system  ;

. operating pmcedure, surveillance procedures, and abnormal condition pro-cedures did' not contain instructions 'and acceptance criteria for control

of the- voltage regulators on emergency electrical system diesel gener-p ators DG-1 and DG-2 to ensure sufficient voltage to enable automatic con-

. nection to the vital buses. This contributed to the violation described i in "A", above.

This is a Severity Level LIV Violation (Supplement I).

f 1. Validity of Violation It is agreed that.the procedures contained no precautions on opera-

tion of the M0P's with the diesel generators in the shutdown mode and that this was a contributing factor to the violation described

in "A".

2. Reason for Violation n The design of the MOP circuitry allowed the potentiometers to be l . adjusted while the generator was not . operating. The engineer re-sponsible. for the startup testing of these diesel generators did not

. provide . input to the operating procedures concerning the voltage adjust high and' low limit lights. However, the ' testing performed did verify generator- operability per the designed configuration.

l The procedure did not contain a caution to Plant operators concern-ing the fact that voltage could be a'djusted outside the range which

was required for automatic breaker closure. Nor was a caution pre-l sent to indicate that if the voltage regulator was adjusted, while

the diesel generator was . secured . the voltage would not return to a preset ' value upon starting.. The -absence of these precautions - is j

considered -a personnel error which resulted in deficient procedures l and this violation. '

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l However, the operating and surveillance procedures cover instruc-tions to the above stated requirements which include setting the voltage regulators.when securing the units. Specifically, each pro-cedure includes instructions to reduce the generator output to 200 KW and "0" KVAR. This . effectively sets. the generator voltage equal to line: voltage and procedurally established the required condition

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- prior to securing -the unit. The referenced voltage in the proce-dures, 4160 + 420 VAC, was in agreement with Technical Specifica-tions, but is7 inconsistent with the output breaker automatic closure

. pemissive circuit setpoint vol tage, thus potentially allowing a voltage below the point which enables automatic connection to the

, vital bus. - The procedures did not address the aspect 'of MOP opera-tion while shutdown.-

Corretive Steps Taken/Results Achieved

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a. 'The diesel generator abnormal.,- operating and surveillance . pro-cedures have been changed to include an additional statement which mquires -the MOP to be . adjusted to obtain rated generator voltage af ter the output breaker has been opened. The oper-ating and surveillance procedures were included on the required reading for all operators.

l The Results Achieved:

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In sunnary, positive. corrective action has- been implemented by way

- of pmcedural changes and required reading. Operators are pro-i cedurally required (by an additional statement in the procedure) to

verify that cormet voltage conditions exist prior to securing the

units.

Also, the actions detailed in the response - to Violation A ensure that the MOP ~ adjustment will support attaining correct volt-age conditions on.both manual and automatic DG starts.

4. Corrective Steps To Be Taken l-a)- A Technical Specification change . request'has been initiated for submittal to the NRC which makes the allowable DG . voltage band consistent with the ' output breaker closure permissive setpoint.

E b) The existing design for.the amber. warning lights used to indi-cate the voltage regulator _ position at the upper - or lower limits of MOP ' travel, .which exceed the operability range 1s being evaluated by the Nuclear Safety - Assurance Group (NSAG).

The issues of whether these-lights should be retained, and, if retained, whether annunciator response procedures are required will be addressed.

-5.1 Dates When Full Compliance Will be Achieved l ' a) Procedural changes were completed on February 27,.1985.

b) The NSAG evaluation will be completed by May 15, 1985.

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The . Technical Specification change request will_be submitted by May 23,1985.

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' !C. Notice of Violation

. Technical Specification 6.8.1 requires . that written procedures shall be

. established, implemented and maintained covering the activities refer-enced in Appendix A or Regulatory Guide 1.33, Revision 2. Regulatory Guide .1.33, Appendix. A, part 1.h requires administrative procedures to

' address " Log entries." The WPPSS WNP-2 plant . procedure 1.3.4, Revision 4

- 6, requires that - the control Roont Log include timed entries for "b".

Status changes- in ' equipment, components, or structures that affect plant operation.= Also,' plant procedure 1.3.5, Revision 3, requims that opera-tions staff; record abnonnal plant behavior, including 'Upon a- turbine i . trip / generator >1oad rejection ascertain that . . . the electrical distri-bution system realigns properly." ,

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i Contrary to the above, the control room operators failed to enter rele-vant key infomation into either the Control Room Log or. the Reactor Trip j: Record (No. 285-040). Specifically, on January 31, 1985, a reactor.oper-

, ator' became aware, subsequent to a generator trip and diesel generator i automatic start, of the unacceptable - voltage output of the diesel gener-ators DG and DG-2. Although he took inmediate corrective action, he' made' no log or reactor trip record entries regarding the identified condition.

This is a Severity Level IV Violation (Supplement I).

, 1. Validity of Violation i .

The Supply System concurs with the validity of this violation.

2. Reason for Violation

! The unacceptable voltage output from DG's 1 and 2 was- not immedi-ately recognized or brought to the attention of 'the control room l operator as abnormal plant behavior (i.e., precluding automatic DG

( output breaker closure). This oversight is the dimet cause of the '

violation.

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f - The control room operator did check the electrical' distribution sys-tem realignment after. the turbine generator trip. It was detemined to be properly aligned for a loss = of the 'startup . transformer = with the back-up transfomer supplying the vital buses 'as designed. The  :

diesel . generators were . running but not required to be closed in on the vital buses, therefore the undervoltage condition on DG's 1 and 2 went unnoticed from -the . control room. The Plant engineer at the DG ' local Econtrol panel - noticed the low voltage condition and ' noti-g fied - the control. room operatoru (CRO). It was not: brought to the attention of the CR0 that this condition inhibited automatic closure -

of the - DG output breakers nor did the -CR0 recognize this at ' the time. Therefore a judgement error was made and no entry was made into the.CR0 log cr' reactor trip records.

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- 3. Corrective Steps Which Have Been Taken

a. The Operations Department Manager has reinforced, to Operations personnel,- via a memorandum dated March 5,1985, the need to identify abnomal plant conditions. This was included as required' reading for all Plant Operators.

b. Between February 28, 1985 and March 15, 1985 the Operations Manager held the following staff. meetings with Operations

-personnel:

1) ' Crews B,C,E 8 F between February 28 and March 6, 1985 regarding NRC enforcement conference, which included a discussion on improving operating logs.

, 2) Crews B 8 F. on March 7,1985, Crews A,C & D on March 12,

- 1985 and Crew E on March 15, 1985 regarding Management philosophy on the DG issue. Emphasis on the completion of thel post trip review via PPM 1.3.T was discussed during these staff meetings.

c. Control . room panel meter green bands - for DG voltage and fre-quency have -been modified to indicate acceptable voltage

! ranges. This ' will facilitate earlier identification- of incorrect voltage levels. ,

d. Shift Engineers normally assist Operations in preparing the Reactor Trip Record. The need for improved perfomance in this j area'.was stressed by the Plant Engineering Supervisor, Reactor Systees, at a weekly staff meeting with the Shift Engineers.

e. Previously much of the data required to complete this . record was time consuming to obtain. Since this event, the - data i acquisition ~ process has been streamlined such that a process which used to require 4-5 hours now requires approximately 15 ,

i minutes. An automated special information retrieval program i for the Transient Data Acquistion System (TDAS) has been .

, developed and implemented which provides Operations and Shift '

! Engineers with Plant operation data for the Reactor Tri) Record l after a minimal effort. This enables the - Shift Eng' neer to beconie more involved in assisting Operations . personnel in identifying and assessing abnormal conditions (refer to Viola-tion D, response 3).

The Results- Achieved:

In -sunmary, positive corrective action has - been implemented by way l of required ' reading, staff meetings, training Land the. use of an automated scram report data retrieval system.

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4. Corrective Steps To Be Taken ,

A- detailed review of the effectiveness of the post trip evaluation process (i.e., PPM 1.3.5,- Reactor Trip and Recovery) will be per-

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formed by the Technical Staff and Nuclear Safety Assurance Group.

The revision will provide for a post scram participants review ses-sion and concentrate on general procedure improvements.

5. Date When Full Compliance Will .be Achieved a) With the exception of the PPM 1.3.5 review and revision, full compliance was achieved by March 15, 1985.

b) . ' The PPM 1.3.5 review and revision will be completed prior to Plant startup following our' May-June 1985 outage.

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., D. Notice of Violation'

10 CFR 50.72(b)(1)(iv) requires that the ' licensee notify the NRC Opera-tions Center within one hour of any event that results or should have

. resul ted in Emergency Core Cooling System discharge into the reactor coolant system.- -

S~ = 10 CFR ~ 50.72(b)(2) requires' that the licensee notify the NRC Operations

[ Center within four hours of certain events, including (i) any event, found while 'the reactor is shut down,' that, had it been found while the reactor was in _ operation, would have resulted in the nuclear power plant,

. including 1ts principal. safety barriers, being seriously degraded or being in an unanalyzed condition ~ that significantly compromises plant

safety, or (ii) any event or condition that results in. manual or auto-i matic actuation of any Engineered Safety Feature (ESF), including the Reactor Protection System (RPS). 4 i Contrary to these requirements:

4 i l1. More than one hour elapsed on January 31, 1985, before the licensee i notified the NRC Operations Center that the High Pressure Core Spray t . System (an ECCS system) had actuated and discharged coolant into the r ~ WNP-2 reactor vessel. . This actuation occurred at 7:57 a.m. PST on January 31, 1985, . and the licensee notified the NRC Operations Center at-10:07 a.m. PST.  ;

2. More than four hours elapsed on January 31, 1985 and February 1, ,

i 1985, after' diesel generators DG-1 and DG-2 were found to be inoper-able before the licensee reported this event to the NRC Operations Center. Diesel Generators DG-1 and DG-2 were found to be inoperable i

at about 8:00 a.m. PST on January 31, 385. The licensee notified the NRC of this event at 5:07 p.m. PST on February 1,1985.

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L 3. More than four hours elapsed on February 14, 1985, before the licensee notified the NRC Operations Center that an automatic actua-i tion of. the Reactor Protection System had occurred. This actuation occurred (while~ the reactor was shut down) at 4:20 a.m. PST, and the

. licensee notified the NRC' Operations Center at 8:35 a.m. PST. .,

These are Severity Level IV Violations (Supplement I). -

i l 1. Validity of Violation -

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i This violation addresses three separate events. The Supply- System agrees with violations'for the first and third events as stated.

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However,- the Plant had not analyzed the s::cond ev:nt as preventing automatic DG . breaker closure until the afternoon of February 1, 1985. Upon completing this analysis, the event was reported within the four -hour time limit to the NRC. The incident was therefore reported within the time limit, after the analysis of the event determined it to be reportable, and the action taken is interpreted to be in compliance with the reporting requirements.

t 2.. Reason For Violations ,

The first event-can be attributed in part to the reactor scram,~ iso-lations and electrical problems encountered during the event on

i. January 31, 1985. The Shift Manager's attention to the reactor l

~ scram recovery 'and restoration of plant electrical distribution sys-tem was a contributing factor. The scram event was known to be in the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> reportable category, however after the first hour had

passed a review determined that the HPCS injection was a one hour j reportable. category.

The second event as stated was not analyzed as preventing automatic L DG breaker closure until the afternoon of February 1,1985. This report was- thought to be within the reporting requirement based upon l

the time at which the event was declared reportable.

The third event on February 14, 1985, was an automatic actuation of the RPS while the reactor was shutdown. Initially the event was mistakenly determined to be a planned evolution during APRM surveil-i lance testing and consequently not reported at-that time.

3. Corrective Steps Taken/Results Achieved The Operations Manager has reinforced, to operations personnel, via

. a memorandum dated March 5,1985, the need to perform reportability j assessment and implement the NRC notification within the required time frame. This has 'been achieved by initially considering each event as requiring a one hour report and requesting assessment from i the Shift Engineer during. the first 1/2 ~ hour, while the operating

crew's attention may be directed towards stabilizing plant conditions.

The Results Achieved:

All reportable events have been reported in the proper time frame since the date of the violation.

4. . Corrective Steps To Be Taken Not applicable l

5. Date When Full Compliance'W111 be Achieved Full compliance was achieved on March 5,1985.

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- , - GENERAL DISCUSSION h The: Plant's first if ne of defense during abnormal . situations is with the on-duty - Operations personnel. Plant management has supported a professional environment which emphasizes a team concept that supports Operations. Efforts

' will be continued in this area with emphasis' placed on improving the process by:

1)- improving the problem identificatior) process,

2) improving communications between different groups of the Plant staff, l

3) maintaining an. active management involvement in-Plant operations, and l

. 4). continuing Plant operations with an overall attempt at improving perfor- i mance in all areas.

Our perception is that once problem areas have been identified, the resolution effort and timeliness of the correction exemplify the characteristics required j in a competent staff. The efforts outlined in this response are aimed at not only-maintaining this level of proficiency, but at improving our perfomance.

This effort will -build on identified strengths, resolve areas of weakness, complete the ' transition to a mature operating organization and improve our 4 working relationship with regulatory agencies.

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