IR 05000206/1987029
| ML13316B864 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/18/1988 |
| From: | Andrew Hon, Huey F, Johnson P, Tatum J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13316B862 | List: |
| References | |
| 50-206-87-29, 50-361-87-31, 50-362-87-31, IEB-87-002, IEB-87-2, NUDOCS 8803140206 | |
| Download: ML13316B864 (21) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No /87-29, 50-361/87-31, 50-362/87-31 Docket No, 50-361, 50-362 License No DPR-13, NPF-10, NPF-15 Licensee:
Southern California Edison Company P. 0. Box 800, 2244 Walnut Grove Avenue Rosemead, California 92770 Facility Name:
San Onofre Units 1, 2 and 3 Inspection at:
San Onofre, San Clemente, California Inspection conducted:
November 22, 1987 through January 20, 1988 Inspectors:
_. 1
________641_
F. R. Huey, Senior Resident Date Signed Inspector, Units 1, 2 and 3 J. E. Tatum, Resident Inspector Date Signed A L. Hon, Resident Inspector Date Signed App roved By:
.A P. H. Johnson, Chief Date Signed Reactor Projects Section 3 Inspection Summary Inspection on November 22, 1987 through January 20, 1988 (Report No /87-29, 50-361/87-31, 50-362/87-31)
Areas Inspected:
Routine resident inspection of Units 1, 2 and 3 Operations Program including the following areas:
operational safety verification, evaluation of plant trips and events, monthly surveillance activities, monthly maintenance activities, refueling activities, independent inspection, licensee event reports review, and follow-up of previously identified item Inspection procedures 530702, 530703, 537701, 561701, 561708, 561710, 561715, 561726, 561728, 562700, 562703, 564704, 571707, 571710, 571711, 571714, 571881, 582301, 590712, 592700, 592701, 59302 were covere Results:
Of the areas examined, one potential violation was identified involving improper reporting of plant operation under conditions prohibited by the plant technical specification PDR ADOCKf:
05000206 DCE
DETAILS 1. Persons Contacted Southern California Edison Company C. McCarthy, Vice President, Site Manager W. Moody, Deputy Site Manager
- H. Morgan, Station Manager D. Heinicke, Deputy Station Manager
- D. Schone, Quality Assurance Manager D. Stonecipher, Quality Control Manager
- R. Krieger, Operations Manager
- D. Shull, Maintenance Manager
- J. Reilly, Technical Manager
- P. Knapp, Health Physics Manager D. Peacor, Emergency Preparedness Manager P. Eller, Security Manager
- Reeder, Operations Superintendent, Unit 1
- V. Fisher, Operations Superintendent, Units 2/3 R. Santosuosso, Maintenance Manager, Units 2/3 L. Cash, Maintenance Manager, Unit 1
- M. Wharton, Assistant Technical Manager
- C. Couser, Compliance Engineer
- Denotes those attending the exit meeting on January 20, 1988.
The inspectors also contacted other licensee employees during the course of the inspection, including operations shift superintendents, control room supervisors, control room operators, QA and QC engineers, compliance engineers, maintenance craftsmen, and health physics engineers and technician. Operational Safety Verification The inspectors performed several plant tours and verified the operability of selected emergency systems, reviewed the Tag Out Log and verified proper return to service of affected component Particular attention was given to housekeeping, examinationfor potential fire hazards, fluid leaks, excessive vibration, and verification that maintenance requests had been initiated for equipment inneed of maintenanc a. Equipment Control Problems (Unit 1)
On December 23, 1987, while the Unit was in mode 1, theinspecto observed a DC ground alarm in the control roo Operations personnel implemented the appropriate procedure to locate the groun About two hours later, the operator identified that the ground was caused by a technician troubleshooting an annunciator for the east fire pump. The operators on shift were not specifically
- vvaware of the maintenance work by the technician at the tim The inspector reviewed the work order and noted the following:
The east fire pump was scheduled for maintenance with three Maintenance Orders (MOs) prepared by Equipment Control (EC).
Two of the MOs were mechanical to be performed by mechanics, and one was electrical, to be performed by test technician EC prepared a work authorization record (WAR 1-8702714) for the mechanical job (M087102412000) as a clearance. The other two jobs on the east fire pump, including a mechanical job and the electrical work on the annunciator (MO87100445000), were assigned to be worked under the same clearance as M087102421000. This practice of working more than 1 MO on a single WAR (called "buddies") is permitted under the licensee's procedure 50123-0-21, "Equipment Status Control", provided that they can be accomplished within the bounds of a single Work Authorization. When this practice is followed, the second worker obtains work clearance/approval from the primary worker, not directly from the control operator. This WAR was I
authorized for performance by the previous control room SRO and cleared for work during the next shif At the time of the inspector's observation, the east fire pump was physically cleared from the plant as far as the mechanical and power supply aspects were concerned. However, DC power to the annunciator was still energized. In accordance with the WAR, the test technician had received work clearance from the machinist holding the WAR instead of an approval directly from the control roo To respond to the inspector's concern, the licensee initiated an investigation and determined that EC should not have "buddied" the live electrical MO to the WAR, instead of calling for a separate approval from the control operator. The licensee issued an Operations Division Investigation Report for priority reading by all operators and EC personnel to further clarify the meaning and proper application of clearance, approval and "buddy" MO Procedure S0123-0-21 will also be reviewed for any warranted improvemen This item is closed (50-206/87-29-01). Problems with Control of Project Work Activities On December 23, 1987, while Unit 1 was at full power, the inspector observed an individual working in a cable tray in the 4 KV room, apparently beyond the scope of work authorized by Operations. This individual was a Bechtel employee working within the licensee's Projects division to prepare for outage related fire seal repair work. The inspector reviewed this item with the Unit Superintendent, who met with the Projects' Supervisor and Bechtel Field Construction Manager to determine the extent of the problem and its root caus II
Further review of Bechtel activities on site by the licensee and Bechtel management identified several other instances in which work practices did not meet the established standards for station personnel. A root cause evaluation indicated problems with contract construction worker sensitivity to plant operating condition Thus, the Bechtel Field Construction Manager elected to stop all physical work activities until an acceptable corrective action plan could be developed and implemente Projects and Bechtel developed and implemented an action plan including the following:
Definition of walkdown guidelines and field walkdown of the work locations in Units 1,2 and 3 for the activities to be performed in the following three week Areas of improvements were identified during this revie Implementation of a Bechtel Housekeeping/Safety Task Force Program which will include supervisors, foremen and non-manual engineers. This group will be responsible to walk down all jobs in progress daily in all units to identify and correct deficient work practices. An incentive was also built into this program to reward good performer Revised training for Bechtel workers at SONGS at all levels to ensure proper understanding of station maintenance work standard Formalized pre-job start walkdown by the non-manual workers responsible for the work activity. This will also include the licensee's cognizant engineers, the craft foremen and station operations staff. Furthermore, the Bechtel Project Superintendent and Field Construction Manager will conduct frequent walkdowns to convey management's intent and concern to identify and correct potential problems which may impact plant safet On January 4, 1988, the representatives of Projects, Station Operations and Bechtel met to review the action plan and agreed that the root cause and corrective action provided adequate assurance that Bechtel's work on site will be conducted safely. Therefore, suspended work was resume The licensee also addressed the concern of allowing workers to utilize cable trays for work access. Potential concerns included structural integrity and potential safety hazards to the plant and personnel while the unit is at power. A licensee engineering analysis determined that sufficient structural design margin existed to allow one worker on a tray. The licensee has defined specific requirements to obtain permission to step on cable trays on a case by case basis for each construction work order (CWO), after it is determined necessary and saf After reviewing the licensee and Bechtel's action plan and observing work activities in the plant after they were resumed, the inspector concluded that the licensee and Bechtel were responsive in addressing this concern. This item is closed (50-206/87-29-02). Compensatory Action Problems (1) During a review of Unit 1 plant logs on January 1, the inspector noted that the shift superintendent had identified that health physics personnel were not properly logging periodic surveys as required by a LCOAR initiated following the failure of technical specification radiation monitor R-123 The inspector discussed this issue with the Unit 1 operations superintendent, noting that the problem appeared to involve a lack of documented requirements for performing technical specification compensatory actions by health physics personne The licensee agreed that documented compensatory action requirements should be in place before a LCOAR shifts responsibilities outside of the operations department. The licensee has initiated actions to correct this proble (2) On December 28, the inspector discussed compensatory action problems involving low battery temperature on the Unit 2 battery 2D3 with the station operations and technical manager In particular, the inspector noted that the lack of proper compensatory controls, following the discovery of an inoperable battery room ventilation system heater, had allowed the inadvertent restarting of the system ventilation fan after it station cold weather procedures warrant revision with regard to attention to batteries and perhaps other areas. The licensee stated that he was in the process of defining corrective actions for both of these concern This item remains open, pending additional licensee action (50-361/87-31-01).
3) During a review of Unit 2 plant logs on January 3, the inspector noted that plant operators had not logged compensatory measures being taken to maintain diesel generator 2G003 lube oil temperature within operating limits, as required by an abnormal system alignment initiated following the January 2 failure of the automatic temperature control system. Further review identified that the proper actions had been taken, but were not logged. The licensee agreed to provide additional emphasis to plant operators regarding the importance of proper loggin Plant Material Condition Problem The inspector noted several plant material condition concerns during plant tours. In particular:
0II
5 During a January 1 tour of Unit 3, the inspector noted low levels on several cells of the non safety related Unit 3 battery 3D5. The inspector also noted that maintenance personnel had left a spare battery cell and several other disassembled battery rack parts on the floor of the room. The licensee implemented immediate corrective actio During a January 4 tour of the Units 2 and 3 ESF switchgear rooms, the inspector noted the following conditions:
(1) Numerous class 1E breaker cubicles were noted to have improperly installed or inoperable door closure bolt The licensee stated that this condition did not represent the level of plant excellence expected by plant supervision and that actions would be defined to correct this proble (2) A pair of cloth work gloves was observed on top of 1E auxiliary relay cabinet 2L-345 and a cardboard box of paint brushes was noted on the floor. A loose piece of steel pipe was observed on top of cabinet 3L-412 in the 3A ESF switchgear room. The licensee took immediate action to remove the noted item During a January 4 tour of Unit 1, the inspector noted the following concerns:
(1) A pipe cap leak on the east main feed water pump discharge line vent valve was condensing on the dust filters on the pump motors, potentially restricting proper air flow to the motor. The licensee took immediate action to repair the lea (2) Several electrical terminal box covers associated with the feed water pump HV valves were found to be unlatche This was a repetition of a similar concern raised following the 1985 Unit 1 water hammer event. The licensee agreed to define corrective actions to preclude recurrence of this proble (3) Steam from the casing and trap drains for the steam driven auxiliary feed water pump was observed condensing on the actuation solenoid for pump discharge valve AFW-CV-321 The licensee agreed that this condition did not represent the level of plant excellence expected by plant supervision and that actions would be defined to correct this proble (4) Unsecured nitrogen bottles were observed adjacent to the safety related backup nitrogen manifold for valve RCP-FCV-1115. The licensee took immediate corrective actio This item remains open, pending additional licensee actions (50-206/87-29-03).
e. Problems with Control of Temporary Plant Modifications During a January 4 tour of Unit 1, the inspector noted instances in which plant operators appeared to have implemented temporary plant modifications without obtaining the appropriate review of plant engineering personne During the exit meeting, the inspector emphasized that although the specific instances were not technically significant, the licensee may have set too high a threshold for recognition of plant modifications in the minds of the first line personnel involved with operation and maintenance of the statio The inspector discussed the following examples of apparently inadequate engineering involvement:
(1) In response to low plant temperature conditions, plant operators requested plant maintenance personnel to install a temporary enclosure around the safety related battery for safety injection valve 850C. The maintenance order was not reviewed by cognizant station technical personnel, nor were they made aware of the modification prior to notification by the inspecto (2) In response to the same low temperature conditions, plant operators installed duct tape on the main feedwater pump HV valve hydraulic unit enclosures to reduce heat losses from the enclosures. This action was done without a procedure and without the knowledge or involvement of any cognizant station technical personne The licensee stated that additional management emphasis was warranted in this area and that specific actions would be define This item remains open, pending completion of additional-licensee action (50-206/87-29-04).
f. Problem with Control of Plant Conditions and Determination of Root Cause On December 29, the station Operations Manager advised the inspector of a problem involving the failure of Unit 1 operations personnel to properly control plant conditions as provided by station procedures following a surveillance test failure of a safety injection system recirculation valve (CV518). Following failure of the valve to stroke within the specified time limit, plant operators had deenergized the valve in what they believed to be its required post accident safety position (e.g. closed).
Since the valve was closed, plant operators considered the valve to be operable in accordance with the requirements of the plant technical specification Accordingly, an equipment deficiency mode restraint (EDMR) was initiated instead of the more restrictive Limiting Condition for Operation (LCO) tracking form (LCOAR).
The Operations Manager, recognizing that CV518 has dual safety functions (e.g., it must also
open during the initial stages of safety injection), questioned the improper use of the EDMR since the valve was inoperable. Since the Operations Manager discovered the problem in a timely manner, the condition was corrected and the valve was returned to operable status within the required technical specification time limit, in spite of failure to use the proper station controls for tracking LCO The inspector complimented licensee management on their close overview of plant operation and noted the following additional comments:
(1) The licensee's system description of valve CV518 did not adequately describe the dual safety function of valve CV518 and may have contributed to improper operator understanding. The licensee committed to review the system description and correct any similar problem (2) The inspector noted that the initial failure of CV518 to properly stroke was being attributed to low valve accumulator nitrogen pressure (believed to be the result of unusually cold temperatures); however, the licensee failed to obtain accumulator "as found" pressure before recharging the accumulator with nitrogen. The licensee agreed that the as found pressure should have been documented. The inspector requested that the licensee consider this example in his review of what additional actions are needed to improve current station guidance on the performance of root cause evaluations, specifically in the area of what equipment quarantine and engineering involvement is needed at the initial stages of event developmen This item remains open, pending additional licensee action (50-206/87-29-08).
g. Problems with Control of Fire Door Impairments During a tour of Unit 2 ESF switchgear rooms on January 1, the inspector noted that technical specification fire doors for both the Train A and Train B ESF switchgear rooms were open. Although the licensee had initiated required impairment documents and was performing required compensatory inspections, the inspector noted the following concerns:
(1) The impairment form for door AC308 was improperly initiated in that it did not identify any reason for the impairment and no deficiency tag was posted on the doo (2) Both doors were apparently left open by plant personnel who were unaware of door problems or the need for special
.attention. The inspector requested the licensee to consider the need for additional measures to alert plant personnel to impaired doors requiring special attentio The licensee committed to emphasize proper completion of impairment documents and to provide additional measures to alert plant personnel to impaired fire barriers. This item is closed (50-362/87-31-01).
3. Evaluation of Plant Trips and Events a. MOV1202 Failure on November 24, 1987 (Unit 1)
On November 23 and 24, 1987, while the unit was in mode 1, the site experienced two earthquakes resulting in the need to perform operability surveillance testing of a number of safety systems, such as the auxiliary feedwater system. When the motor driven auxiliary feedwater pump (GlOS) was tested after the second earthquake, the discharge valve MOV-1202 failed to open. The licensee found that the thermal overload for the MOV had tripped. After resetting the breaker, the valve operated as designe The licensee performed testing on MOV-1202 and observed excessive current draw during the valve operation. Subsequent disassembly and inspection of the valve operator revealed some binding in the worm gear and a grease void on the gear. Some metal filings in the grease were also observed. The licensee repacked the gear with grease and restored MOV-1202 to operation, after satisfactory testin The licensee preliminarily attributed the failure to the grease being thrown away from the worm gear due to unusually frequent operation of MOV-1202 (six operations within twelve hours as a result of the two earthquakes) and high speed operation, 7200 RPM as compared to less than 2400 RPM for most MOVs. The licensee is continuing to closely monitor operation of MOV 1202, pending completion of the final root cause assessment and long term corrective actio The inspector also questioned the design basis for the use of thermal overloads in MOV 1202 and MOV 1204 (auxiliary feedwater valves).
It was the inspector's understanding that the licensee had committed to remove the thermal overload devices from all safety related MOVs. The inspector requested that the licensee identify the design basis for the use of thermal overloads on MOV 1202 and MOV 120 This item remains open, pending completion of licensee action (50-206/87-29-05).
b. Reactor Trip on December 17, 1987 (Unit 2)
On December 17, 1987, while the unit was at 75% power, main feedwater isolation valve 2HV-4048 went closed, causing the main feedwater pumps to trip on high discharge pressure. The control operator recognized that feedwater was lost to the steam generators and manually tripped the reactor. Emergency feedwater actuation occurred due to low steam generator water level, and the operator
took manual control of the auxiliary feedwater system to control steam generator water level and minimize cooldown of the reactor coolant system. No anomalies were noted in the plant respons The licensee's investigation revealed that a solenoid associated with the closing function of 2HV-4048 had failed, allowing 2HV-4048 to go closed. Moisture had accumulated around the terminal board of the solenoid and caused the solenoid to short to ground, deenergizing the solenoid and allowing the main feedwater isolation valve to go closed. The licensee inspected the solenoids that were used in similar applications and did not identify any additional problem The faulty solenoid was replaced, and Unit 2 was returned to operation on December 18, 198. Monthly Surveillance Activities During this report period, the inspectors observed the following surveillance activities:
a. Unit 1 o
S01-12.3-26 Auxiliary Feedwater Pump Operability Test o
SO1-II-1.80 Containment Channel Isolation Monthly Surveillance o
S01-12.0-2 Operating Surveillance Implementation (Program review)
b. Unit 2 o
S023-3-3.10.1 Containment Airlock Integrity Verification o
S023-V-1. Control Element Assembly Symmetry Verification o
S023-V-1. Control Element Assembly Worth by Exchange c. Unit 3 o
S023-I-9.27 Breaker - G.E. AK2-25 Reactor Trip Breaker Inspection, Adjustment and Testing o
S023-II-11.161 Reactor Trip Breakers Undervoltage and Shunt Trip Device Circuit Test No violations or deviations were identifie. Monthly Maintenance Activities During this report period, the inspectors observed maintenance activities
associated with the following maintenance orders:
10 Unit 1 o
87120831 Replace Ampertect (thermal overload device) on 480 V MCC 2-B Feeder Breaker o
87092166 Replace Crankcase Explosive Gas Relief Valve on the #2 Diesel Generator o
87041162 Replace South Screen Washing Pump Strainer Unit 2 o
87111500 Containment Emergency Sump Wide Range Level Indicator Failed Low o
87103109 Boric Acid Leak from Check Valve for Safety Injection Header to RCS Loop 2B (1204-MU-033)
c. Unit 3 o
87062523 Degraded Cable on Temperature Recorder for Containment Atmosphere No violations or deviations were identifie. Engineered Safety Feature Walkdown
- Unit 1 The inspector verified the unit's fire protection system operability by utilizing procedure S01-12.3-18 "Fire System Valve Alignment And Operability Check."
b. Unit 2 Prior to Mode 3 entry following Cycle IV refueling outage, the inspector verified that the containment penetrations were properly secured. The inspector also performed a partial walkdown of the following systems, using appropriate piping and instrument diagrams (P&IDs) to verify proper alignment: Containment Spray System (P&ID 40114)
o Component Cooling Water System (P&ID 40127)
o Main Feedwater System (P&ID 40156)
No violations or deviations were identifie. Completion of Refueling Outage (Unit 2)
a. Housekeeping Conditions
Prior to Unit 2 startup following the Cycle IV refueling outage, the inspector made several tours of the containment building and noted significant improvements in housekeeping conditions compared to previous outages. In general, significant improvements were also noted in the areas outside containment, with a couple of exception First, the safety equipment building pump rooms did not appear to be well kept in the vicinity of the safety injection pump Second, the piping penetration rooms appeared cluttered and in need of attention. These conditions were discussed with the license b. Verification of Containment Integrity The inspector verified proper isolation of all. containment penetrations and performed a partial walkdown of selected systems (as discussed in paragraph 6.b). The inspector also witnessed the containment airlock integrity verification after final containment closur Plant Startup from Refueling Outage The unit entered Mode 4 on December 2, 1987 at 6:56 p.m. following replacement of the reactor coolant pump seals. Mode 3 was entered at 11:18 p.m. on December 5 and Mode 2 entry occurred at 6:52 on December 7, 198 Following low power physics testing, the unit entered Mode 1 on December 12, 1987. The inspector observed these evolutions being conducted and verified that plant operation was conducted in accordance with the following procedures:
I5023-5-Plant Startup from Cold Shutdown to Hot Standby o
S023-3-Reactor Startup o
S023-V-1 Low Power Physics Testing o
S023-V-1. Criticality Following Refueling o
S023-V-1. Boron Endpoint Determination o
S023-V-1. Isothermal Temperature Coefficient Measurement At Hot, Zero Power o
S023-5-1. Plant Startup from Hot Standby to Minimum Load Following low power physics testing, the licensee conducted power ascension testing up to the 75% power plateau. The reactor was limited to 75% power until repairs could be completed to the motor on one circulating water pump. While holding at 75% power, the reactor was manually tripped due to loss of main feedwater, as discussed in paragraph 3 of this report. Power ascension testing was continued after the pump was returned to service, and the unit reached 100% power on December 29, 198 No violations or deviations were identifie.
Independent Inspection a. Design Review of Safety Injection Interlocks (Unit 1)
The inspector performed a design review of the safety injection interlocks associated with the Unit 1 main feed water pump These interlocks were selected on the following bases: (1) they are important to plant safety, in that their failure could either prevent engineered safety features equipment from performing accident mitigating functions or further exacerbate postulated accident consequences; (2) they had been subject to recent modification during plant outages; and (3) they presented vulnerability to single failure. The inspector reviewed the various design basis documents for these interlocks, reviewed the system descriptions and procedures for operating and testing the interlocks, discussed interlock operation with plant operators and engineering personnel and reviewed the various documents associated with maintenance and modification of the interlock This review resulted in the following findings:
(1) The safety injection interlock associated with safety injection discharge valves HV851A and HV851B were not designed or installed as described in the Unit 1 Final Safety Analysis Report (FSAR).
In particular, the FSAR states that the HV851 interlocks are designed to prevent inadvertent opening of condensate suction valves HV854A and HV854B unless the corresponding safety injection discharge valve is completely closed. The HV851 valve interlocks, as described in plant design documents, are installed in the plant such that they do not perform their interlock function until the HV851 valve is completely ope The licensee explained that the interlock was designed as installed in order to prevent significant loss of feedwater transients resulting from inadvertent drift of the HV851 valve off its closed seat. The licensee stated that such drift has not been a problem to date; however, they believe it is still prudent to design the system as installed. The licensee stated that the Unit 1 Final Safety Analysis Report contains numerous similar errors and will be completely updated by the end of the yea The inspector pursued the safety significance of this design difference with the licensee. It was concluded that this difference is of minimal significance since the interlock is backed up by a separate safety injection lock-in circuit. Once safety injection is reset (about 10 minutes into the accident),
contacts on the valve hand switch will prevent inadvertent reopening of the HV854 valve unless an operator improperly attempts to reopen the valve with the hand switch. If this
.
were to happen, one train of safety injection could be lost through the preexisting failure of a non-safety related condensate check valve; however, no condensate could be injected into the reactor coolant system since the condensate pumps are automatically tripped. The inspector requested that the licensee provide a copy of the 50.59 design review which evaluated the design change to these interlock switche This item remains open, pending additional licensee action (50-206/87-29-06).
(2) Maintenance personnel involved in replacement of safety injection interlock switches during the June 1987 mid-cycle outage apparently failed to obtain proper engineering review of design differences between the installed switches and that called out on plant design drawings. In particular, maintenance order MO 87041412001 indicated that the installed switches did not conform to the requirements for electrical lead labeling as shown on referenced design drawing Maintenance personnel appeared to have performed informal troubleshooting to define the proper switch development sequence and failed to initiate a nonconformance report as required by station procedure S0123-XV-This item remains unresolved, pending additional licensee action (50-206/87-29-07).
(3) The inspector noted that some of the interlock switches were mounted in slotted holes and that several of the switches did not appear to have proper lockwashers installed. Continuous vibration associated with normal plant operation could loosen these installation configurations resulting in improper safety injection actuation. The licensee implemented prompt action to identify and initiate repair of deficient switche (4) The HV851 interlocks were not described in the Unit 1 system descriptions and some plant operators were not familiar with their existence or function. The inspector noted that this problem appeared similar to another recent instance wherein incomplete component description in plant system descriptions may have contributed to improper operator actions associated with safety injection recirculation valve CV518 (see paragraph 2.f).
The licensee agreed to update the system descriptio. Review of Licensee Event Reports Through direct observations, discussion with licensee personnel, or review of records, the following Licensee Event Reports (LERs) were closed:
Unit 1 81-08 Fatigue Analysis of Feedwater Nozzle
The licensee is planning to complete the evaluations associated with this LER during the Cycle X refueling outag Loss of Boric Acid Flow Path The licensee is scheduled to complete modifications associated with this LER during the Cycle X refueling outag Main Feedwater Pump Failure 86-11 R1 86-14 Entry Into Technical Specification 3. RI 87-03 Trip on Loss of Generator Field 87-03 R1 The licensee submitted a revision which provided root cause information not supplied in the original LE Entry Into Technical Specification 3. R1 87-14 Battery Weekly Surveillance Not Performed Prior to Mode Change Due to Personnel Error 87-16 ASCO Solenoid Valve Failure This item is being followed as open item 50-206/87-24-0 Voluntary Entry Into Technical Specification 3. During DC Ground Troubleshooting Unit 2 86-22 Reactor Trip on Main Steam Isolation Signal 86-22 R2 This LER was previously left open pending the results of the licensee's root cause evaluation,and effective implementation of corrective action Revision 1 of the LER provided the root cause assessment, and additional information was provided in Revision 2 regarding implementation of proposed corrective action Reactor Trip Caused by Failed Control Element Assembly (CEA)
86-27 R1 Position Indication 86-29 Unit 2 Trip During Transfer of Non-IE Power Supply 86-29 R1 86-29 R2 86-31 Delinquent Deluge System Surveillance 87-04 Unit 2 Trip from Low Steam Generator Level 87-04 R1
Licensee action on this LER is complete. The inspector identified a potential generic item for NRR review. Final action on this item is still pending (50-361/87-31-02).
87-08 Entry Into Technical Specification 3.0.3 - Control Rod Position Inoperable The inspector discussed this event with the licensee and determined that the programmed time delay difficulty was not applicable to the core operating limits supervisory system (COLSS), and was only applicable to the back-up COLSS compute The licensee monitored operation of the back-up COLSS after the data acquisition time delay was increased, and there has been no recurrence of this proble Shutdown Cooling.(SDC) Valve Packing Gland Failure 87-14 R1 Additional followup activities associated with this event will be documented under unresolved item 361/87-23-0 Containment Purge Isolation System Spurious Actuations Due to Induced Noise 87-20 Health Physics Aspects of SDC System Isolation Valve 2HV-9378 Event 87-21 Spurious Fuel Handling Isolation System Train "B" Actuation During Design Change Work 87-23 Spurious Train "B" Toxic Gas Chlorine Channel Actuation 87-25 18-Month Surveillance of Snubbers Not Performed 87-27 Technical Specification Fire Door Surveillance Discrepancies 87-28 Containment Purge Isolation System Actuation Due to High Impedance 87-29 Fuel Handling Isolation System Train "B" Actuation 87-31 Manual Reactor Trip Due to Feedwater Isolation Valve Failing Closed Unit 3 84-44 Control Element Assembly Calculator Penalty Factors Not Response Time Tested Although the licensee's corrective actions appeared to be adequate, the inspector observed that the LER event date was not properly identified in block 5 and the LER was not issued within 30 days of the discovery date as required. The forwarding letter for the LER stated that the LER was delayed
in order to provide a complete response. The inspector discussed these observations with the license R2 Inoperable Purge Monitor 87-11 Reactor Trip on Low Steam Generator Water Level 87-11 R1 The licensee was continuing to evaluate the root cause of the zero offset associated with loop 2B HPSI flow transmitter, which was reported in the LER. Additional follow-up of this item will be completed under open item 50-362/87-15-0 Control Room Isolation Inadvertent Actuation During Functional Testing In discussing this event with the radiation monitoring supervisor, the inspector was told that the technician had mistakenly pushed the wrong button such that the radiation monitor was not placed in "Alarm Defeat" before the
"Reset/Bypass" switch was released. The inspector requested the licensee to evaluate the human factors aspect of this event to determine if one technician was adequate to accomplish the surveillance. The licensee stated that the technician involved with the event was inattentive, and that the surveillance can be completed successfully by a single technicia R1 Safety Injection Tank Level Instrumentation 87-16 Missed CEA Position Verification 87-17 Low Condenser Vacuum During Influx of Seaweed No violations or deviations were identifie.
Follow-Up of Previously Identified Items (Open) Open Item 50-206/87-24-01) Momentary Loss of Containment Integrity While Unit Was at Full Power Summary On August 25, 1987, while the Unit was at power, a containment entry was made. As allowed by the procedure, the inner hatch was left open after the HP technician entered the containment for an air sample survey. When the second person was prepared to enter, the hatch operator operated the door mechanism to close the inner hatc During that operation, the drive chain of the inner hatch broke. As a result, the inner hatch remained open, although the position indicator showed that the hatch was closed. Being outside the outer hatch, the operator was unaware of this condition and proceeded to open the outer hatch. The operator recognized the problem as soon as the outer hatch was partially opened, and immediately reclosed the outer hatch. As a result, containment integrity was lost only momentarily (approximately 20 seconds).
Status During this inspection, the inspector continued to review the licensee's corrective actions. The licensee revised procedure S01-4-44, "Containment Access System Operation," to conform with the Standard Technical Specification stipulation that the hatch is to be open only for the purpose of passage of personnel and equipmen This is more restrictive than the earlier practice of allowing the inner hatch to be left open for short durations (such as for taking an air sample) while containment integrity is require This item remains open pending review of other licensee corrective actions associated with troubleshooting of the alarm malfunction and replacement of interlock drive mechanism (Closed) Open Item (50-206/87-03-03) Seal-in of Low Suction Pressure Trip for Steam-driven Auxiliary Feedwater Pump Summary During a previous routine steam-driven auxiliary feedwater pump G10 monthly surveillance, the inspector observed that a low suction pressure signal was present momentarily prior to pump start, causing the G-10 Suction Low Pressure Alarm to annunciate. Upon clearing the alarm, the operator proceeded to start pump G-10 but without succes Drawing review by operations and I&C personnel revealed that the low suction trip sealed in after the signal returned above the setpoint. Clearing the alarm alone was not sufficient to clear the lockout. It was necessary to reset pump G-10 before it could start automatically. The licensee initiated Site Problem Report SPR 1U870301 and committed to revise the alarm response procedure and operator training to properly reflect the system configuratio Status The license resolved this SPR by revising procedure S01-13-19,
"Auxiliary Feedwater Annunciator".
The revision requires the operator to reset the pump lockout in addition to clearing the alarm. The relevant information was also included in the operator training progra The inspector reviewed the licensee's action and found it to be satisfactory. Therefore, this item is close (Closed) Open Item (50-361/86-19-01), Plant Conditions and Housekeeping Deficiencies The inspectors have continuously monitored housekeeping conditions, and significant improvements have been made by the licensee as documented in the following inspection reports:
o 50-361/87-20 (paragraph 2i)
50-361/87-23 (paragraph 3d)
o 50-361/87-28 (paragraph 2c)
Although additional improvements could be made, as discussed in paragraph 2.d of this report, the licensee appears to be making progress in this area. This item is close d. (Closed) Open Item (50-361/86-38-02), Steam Generator Safety Valve Setpoints Out-of-Tolerance The following additional information was provided by the licensee:
The Unit 3 steam generator code safeties were improperly set in September, 1985, during the Cycle II refueling outage. This condition was identified and corrected in March, 1987, during the unit's Cycle III refueling outage. As a result of improperly setting the steam generator code safety valves, Unit 3 operated during Cycle II with 15 safety valves failing to satisfy the specific requirements of Technical Specification L.C.O. 3.7.1.1 (i.e., the lift pressures did not correspond to the specific safety valves listed). Setting aside the requirement to associate each setpoint with a specific safety valve, four of the steam generator code safeties would have failed to satisfy the requirements for lift pressur o The Unit 2 steam generator code safety valves were improperly set in March, 1986, during the Cycle III refueling outage. The condition was identified and corrected in February, 1987, following a unit trip. As a result of improperly setting the steam generator code safety valves on Unit 2, the unit operated for approximately 1 year during Cycle III with 14 safety valves failing to satisfy the specific requirements of Technical Specification L.C.O. 3.7.1.1. Setting aside the requirement to associate each setpoint with a specific safety valve, two of the steam generator code safeties would have failed to satisfy the requirements for lift pressur The inspector requested the licensee to evaluate the safety significance of these conditions. This aspect of this item remains open, and will be assessed during review of the forthcoming LE With regard to reportability, the inspector noted that these conditions had not been reported as required by 10 CFR 50.73 (a)(2)(i)(B). The licensee stated that a report would be issued in February, 1988. Failure of the licensee to submit the reports previously as required by 10 CFR 50.73 is a violation (50-361/87-31-03). (Closed) Open Item (50-361/86-38-03), Inadequate Root Cause Assessment for LER 86-29 This item was open pending action by the licensee to address the inspector's concerns regarding insufficient information contained in a number of LERs. The licensee has taken action to focus attention
on the way in which LERs are written, giving special attention to root cause determination of events. The licensee has revised the specific LERs in question, and the inspector's concerns have been resolved. This item is close (Closed) Violation (50-362/86-08-02), Housekeeping Deficiencies The inspectors have continuously monitored housekeeping conditions and verified adequacy of the licensee's corrective actions, as discussed above. This item is close g. (Closed) Open Item (50-362/86-11-03), Policy for Verification of Estimated Critical Position (ECP) Calculations The inspector had previously observed that ECP calculations did not necessarily receive an independent review when completed by station engineering personne The inspector reviewed the licensee's revised procedure S023-3-1.1 titled "Reactor Startup" and verified that independent verification is now required for the estimated critical rod position calculations. This item is close (Closed) Violation (50-362/87-05-02), Housekeeping and Work Practice Deficiencies The inspectors have continuously monitored housekeeping conditions and have verified the adequacy of the licensee's actions, as discussed above. This item is close i. (Closed) Open Item (362/87-22-03), Safety Injection Tank T-009 Level Inconsistencies The licensee's actions with regard to this item are acceptable as discussed above, under LER 87-014, Revision 1, for Unit 3. This item is close j. (Closed) Temporary Instruction (2515-75), Environmental Qualification of Motor Operated Valves (Units 2 and 3)
Completion of the inspection effort associated with this item was documented in paragraph 10a of Inspection Report 50-361/87-04. The results of the inspection have been referred to NRR for revie Additional action with regard to this item will be completed under unresolved item 50-361/86-34-0 k. (Closed) IE Notice (86-03), Potential Deficiencies in Environmental Qualification of Limitorque Motor Valve Operator Wiring (Units 2 and 3)
As discussed above, additional follow-up action on this item will be documented under unresolved item 50-361/86-34-05. This item is close. Radiological Practices
The inspectors periodically observed radiological protection practices to determine whether the licensee's program was being implemented in conformance with facility policies and procedures and in compliance with regulatory requirements. The inspector verified that health physics supervisors and professionals conducted frequent plant tours to observe activities in progress and were generally aware of significant plant activities, particularly those related to radiological conditions and/or challenges. ALARA consideration was given maintenance activities observe No violations or deviations were identifie.
Physical Security The inspectors periodically observed security practices to ascertain that the licensee's implementation of the security plans was in accordance with site procedures. The inspector observed that the number of guards was adequate for the requirements of the security plan; that the search equipment at the access control points was operational; that the protected area barriers were well maintained without breaks; and that personnel allowed access to the protected area were badged and monitored and that monitoring equipment was functiona Night illumination inside the protected area was observed and obstructions were lighted adequatel Surveillance equipment was also observed during this inspectio No violations or deviations were identifie. Followup on IE Bulletin 87-02, Fastener Testing to Determine Conformance with Applicable Material Specifications (Units 1, 2 and 3)
The inspector reviewed the licensee's sample plan for selection of fasteners for testing. The sample selection was made from a computer print-out of fasteners in stock for use at Units 1, 2 and 3. The number of fasteners selected was based on the criteria specified by MIL STD 105D for Inspection Level S-1. The inspector observed the selection and tagging of several fasteners and found the licensee's actions to be acceptable. Additional follow-up of this item is required to review the licensee's response to IE Bulletin 87-0.
Exit Meeting On January 20, 1988, an exit meeting was conducted with the licensee representatives identified in Paragraph 1. The inspectors summarized the inspection scope and findings as described in this report. The inspectors' findings were also discussed separately with the Vice President -
Site Manage II