IR 05000245/1988017

Insp Rept 50-245/88-17 on 880830-1017.No Violations Noted. Major Areas Inspected:Previously Identified Items,Plant Operations,Physical Security,Loss of Emergency Svc Water Sys & Loss of Standby Gas Treatment Sys

ML20206M233
Person / Time
Site:	Millstone
Issue date:	11/18/1988
From:	Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206M230	List: IR 05000245/1988017 ML20206M225
References
50-245-88-17, NUDOCS 8811300495
Download: ML20206M233 (14)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION I

Report N /88-17 >

Docket N License N OPR-21 Licensee: Northeast Nuclear Energy Company i Facility: Millstone Nuclear Power Station, Unit 1 Inspection At: Waterford, Connecticut ,

Dates: August 30 to October 17, 1988 _

Inspectors: William Raymond, Senior Resident Inspector Lynn Kolonauski, Resident Inspector  ;

Reporting i Inspector: Lynn Kolonauski

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Approved by: AQMIv E. C. McCabe, Chief,' Reactor Projects Section IB se lir/ PP Date

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1 Inspection Summary: Inspection from August 30 to October 17,1988 (Report No.

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5tF2B/83-17)

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Areas Inspected: This inspec+ ion included routine NRC resident inspection of pre-

) viously identified items, pisnt operations, physical security, the loss of the Emergency Service Water (ESW) system due to the loss of both self-cleaning strainers, the loss of the Standby Gas Treatment System (SGTS) due to the instal- l 1ation of uncertified charcoal filters, the simultaneous loss of the emergency 1 diesel generator (EDG) and the "D" ESW pump, maintenance, surveillance, licensee  !

, event reports and committee activities, j i

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Results: The inspection identified no unsafe plant conditions, and involved 194 '

direct inspection hours, including seven hours of backshift and four hours of deep  !

backshift coverage. Further followup is planned on: (i) classification of the ESW '

.: system as an engineered safety feature on Emergency Plan Implementing Procedure I

(EPIP) Form 4701-7 and the Millstone 1 and 2 Emergency Action Level (EAL) classi- t fication tables for loss of redundant safety equipment (Section 5.1), (ii) evalu- i ation of the quality assurance standards for ESW strainer components (Section 5.1). L and (iii) identification and correction of the cause for installing uncertified  !

charcoal filters in the SGTS (Section 5.2). l I

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f TABLE OF CONTENTi PAGE i 1.0 Persons Contacted.................................................... 1 l

r 7.0 S u mma ry o f Fa c i l i ty Ac t i v i t i e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , 1 :,

3.0 Status of Previous Inspection Findings............................... 2 3.1 (Closed) UNR 88-05-01, "Potential Fouling of ECCS Torus Suction ,

Strainers".................................................... 2 L 3.2 (Closed) IFI 84-25-01, "MEPL Equipment Classification".......... 2 4.0 Facility Tours and Operational Status Reviews........................ 2 i f

4.1 Safety System Operability....................................... 3 I 4.2 Review of Plant Incident Reports................................ 4 4.3 Re v i ew o f Bypa s s J ump e r s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 5.0 Engineered Safety Feature Outages Requiring Shutdown per Technical I Specifications..................................................... 5 5.1 Loss of the ESW/ Containment Cooling System...................... 5 5.2 SGTS System Declared Administratively Inoperable................ 7 i 5.3 Simultaneous Loss of the EDG and "0" ESW Pump................... 9 i i Maintenance.......................................................... 10

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7.0 Surveillance.. ...................................................... 11 8.0 Licensee Event Reports............................................... 12 f

9.0 Plant Operations Review Committee.................................... 12 E 10.0 Management Meetings.................................................. 12 i

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DdTAILS 1.0 Persons Contacted J. Stetz, Unit 1 Superintendent

, R. Palmieri, Operations Supervisor N. Bergh, Maintenance Supervisor W. Vogel, Engineering Supervisor M. Bigiavelli, Assistant Engineering Supc. visor J. Quinn, Assistant Engineering Super isor The inspectors also contacted other members of the Operations, Health physics, Instrumentation and Control, Production Test, Maintenance, and Engineering Department .0 Summary of Facility Activities Millstone 1 operated at fuli power except for short power reductions for routine surveillances and corrective maintenance. On September 2, 23, 30, and October 6 and 13, reactor power was reduced to 80% to corduct turbine stop valve (TSV) testing and main condenser backwashin On September 8 at 3:00 a.m., a controlled reactor shutdown commenced per Technical Specification (TS) 3.5.B.6 in response to the loss of the emergency service water (ESW) system (Report Detail 5.0). Minimum recirculation pump

, speed, which corresponds to approximately 60% power, was reached by 8:24 The "B" ESW strainer was returned to service at 11:30 a.m., placing the unit in a four day TS action statement per TS 3.5.B.S. The operators began in-creasing power at 1:38 p.m. and reached full power by 4:00 p.m. The "A" ESW strainer was returned to service by 4:16 p.m. on September 1 On September 14 at 9:24 a.m., power was reduced to 45% to allow tube plugging in the "0" main condenser bay and replacement of the #2 turbine stop valve test solenoid. Full power was restored by 7:15 On September 23 at 5:00 p.m., both trains of the standby gas treatment system (SGTS) were declared administrative 1y inoperable due to the installation of

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chars:=1 filtars that had inadequate certification documentation (see Report Detail 5.z). Tha int: of the SGTS requires the reactor to be in cold shutdown

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, in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per TS 3.7.B.3; a controlled shutdown began at 5: 40 p m. The "A" i SGTS train was returned to service by 4: 55 a.m. on September 24. A power increase from 97% began at 4:f3 a.m., and the unit was at full power by 5:05 a.m. The "B" SGTS train was returned to service by noon on September 2 On October 7, reactor power was reduced to 80% to backwash the "0" main con-denser bay. On October 10, reactor power was again reduced to backwash and plug tubes in the "0" ba _ - - _ -

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On October 12 at 2:00 p.m., a controlled shutdown was commenced per TS 3.S. !

l due to the simultaneous loss of the emergency diesel generator (EDG) and the !

"0" ESW pump. The pump was returned to service by 4:03 p.m., when reactor power was 964. Full power was restored by 4:30 p.m. and the EDG was returned to service by 7:30 ,

3.0 Status of Previous Inspection Findings (93702)

l 3.1 (Closed) UNR 88-0,5-01, "Potential Fouling of ECCS Torus Suction Strainers" l

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The NRC staff reviewed the Millstone 1 Justification for Cortinued Opera-

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tion (JCO) for the potential post-accident insulation fouling of the i Emergency Core Cooling System (ECCS) torus suction strainers, and found t that the JC0 adequately addressed the issue. The staff also found that l

, the administrative limit imposing a 2% decrease in the Maximum Average i

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l Planar Linear Heat Generation Rate (MAPLHGR) thermal limit is conserva-tive and appropriate to ensure that adequate net positive suction head >

(NPSH) will be available to enable adequate ECCS pump performance. This item is close r 3.2 (Closed) IFI 84-25-01, "NEPL Equipment Classification" l 1 i j This inspector follow-up item was initiated to track the licensee's de- !

i velopment of the computer-based Produ: tion Maintenance Management System (PMMS) and, in particular, its status in replacing the hard copy Mite-

. rials Equ!oment and Parts List (MEPL). PMMS stores information on com-i ponents installed in Northeast Utilities (NU) generating plants. For

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a quality assurance (QA) indicator. Millstone 1 has used PMMS to gene- ;

i rate automated work orders (AW0s) since October 1,1904, and is now re- ,

l placing the MEPL with the data stored in the PKMS Most Millstone 1 l

! components have been entered into PRMS with their respective QA status; f l those components without a MEPL evaluation of the applicable QA standards I

have a "U" in their QA field to indicate their undetermined status. The [

! inspectors will continue to review the PMMS QA classification of selected ,

l components periodicall This item is close [

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4.0 Facility Tours and Operational Status Reviews (71707)

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Control instrumentation was inspected for preper functioning, correlation [

I between channels, and conformance with Technical Specifications (TSs). Alarm :

conditions in effect and alarms received were discussed with the operators; [

) the inspector found the operators to be cognizant of plant conditions and in- (

i dications. The inspector observed prompt and appropriate operator response ,

j to changing conditions. Shift turnovers were found to be thor */p, and in !

conformance with ACP 6.12. "Shift Relief Procedure." Operating logs and Plant !

j Incident Reports (PIRs) were reviewed for accuracy and adherence to station .

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Posting, control, and the use of personnel monitoring devices for radiation,

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contamination, and high radiation areas were inspected. Plant housekeeping controls were observed, including control of flammable and other hazardous

, materials. During station tours, the inspectors verified proper implementa- ,

tion of selected aspects of the station security program. These included fite '

access controls, personnel searches, compensatory measures, adequacy of  !

physical barriers, compensatory measures, and guard force response to alarms :

and degraded conditions. No inadequacies were identifie ;

, The inspectors conductec' backshift inspections of the control room; all shift ;

personnel were found to be alert and attentive to their duties. No unaccept- l able conditions were identified. The inspectors also addressed the following l activitie ,

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4.1 Safety System Operability (71707) [

I Standby emergency systems were reviewed to determine system operability ;

and readiness for automatic initiation. The following systems were re- l q viewed: feedwater coolant injection, automatic pressure relief, low

pressure coolant injection, core spray, and standby gas treatment. The ;

status of the control rod drive hydraulic control units, emergency diesel ,

1 generator, gas turbine, and isolation condenser was also inspected. The (

1 reviews considered proper positioning of major flow path valves, operable !

j normal and emergency power sources, proper operation of indications and [

j controls, and proper cooling and lubrication. References used included .

I the Updated Final Safety Analysis Report, system diagrams, and operating !

procedure No inadequacies were identified. The following item re- i l quired further inspector revie ;

I Low Pressure Coolant Injection (LPCI) Minimum Flow Valves  :

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] While performing a routine tour of the Millstone 1 control room on August !

29 at approximately 10:00 a.m., the inspector noted a closed indication l for the "A" LPCI loop minimum flow valve (1-LP-26A). The normal, standby -

), position for 1-LP-26A is ope The inspector discussed the problem with !

) the shift supervisor, who acknowledged and corrected the condition. The i

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inspector was unable to determine the cause of the closed valve after

{ discussion with the operator The inspector also noted that, if LPCI

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had automatically initiated, the operator could have opened the valve j

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from the control room handswitch in order to protect the pump. However, ,

pending review of the conditions which resulted in the valve being closed, j i this is an unresolved item (UNR 50-245/88-17-04). '

Inspector follow-up determined that the LPCI minimum flow valves have I i cycled periodically over the last several years due to degraded LPCI pump l

discharge flow switches. Each switch is a stainless steel paddle hort- I zentally mounted in the discharge piping of each LPCI pump. Paddle dis- !

placement by LPCI flow is detected by limit switches which provide the i t

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26A and B control signals. In order to prevent cycling, the usual prac-

tice was to manually close the valves when sufficient LPCI flow had de-d veloped and then open the valve power supply breakers. Upon securing the system, the breaker would then be reclosed ar.d the valve reopened to return the system to its normal standby lineup.

. The inspector reviewed circuit wiring diagrams (CW0s) 760, 769, 785, and 794. These indicate that flow switches (FSs) 1501-81A through 0 cause 26A/B to open via relays 1501-120/121 and 220/221 on a low flow condition with the handswitch in automatic. Both FSs are required to actuate to

open the valves; if either FS indicates adequate flow the minimum flew l valves will close. This arrangement makes closure of the valve single failure proof for the loss of one FS and protects against reduction of LPCI flow through the open minimum flow valv ,

Replacements for the degraded flow switches, manufactured by Precision i Engineering and Equipment Company (PEECo), were unavailable. The licen-

see examined a PEECo FS that had been removed in 1980 to determine the

, material and dimensions of the FS. The licensee fabricated and installed j replacements for all four switche The inspector noted, through dis-

cussions with operations perscnnel and review of operatior<s logs, that

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cycling problems have persisted in spite of the replacements. The lic-

ensee is now considering permanent blocking open of the 26A and B valves i

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because the flow diverted through the minimum flow line to the torus is limited to 250 gpm via a restricting orific This orifice sliews the

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T5 surveillance flow requirement of 15,000 gpm with three operating LPCI i pumps to be met: the pump curves indicate a maximum pump capacity in excess of 5250 gpm; and recent LPCI pump flow test data indi:ates indi-vidual pumps flows in excess of 5273 gpm, No unacceptable condit. ions were identified. The inspector will follow the licensee's actions re-J lating to the proposed design change, f 4.2 Plant Incident Reports (71707)

) Selected plant incident reports (PIRs) were reviewed to (1) determine the significance of the events, (11) review the licensee's evaluation

of the events, (iii) verify the licenswe's response and corrective ac-

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tions, and (iv) verify whether the licensee reported the events in ac-

! cordance with requirements. The following PIRs were reviewed (signifi-cant events are described elsewhere in this report, as referenced): 1-88-45 and 46 (Section 5.1), 1-83-47 to 1-88-50, 1-68-51 (Section 5.2),

1-88-52,1-88-53 (Section 7.0), and 1-88-54 (Section 5.3). No inade-quacies were identifie .3 Review of Bypass Jumpers The inspector reviewed the bypass / jumper log to verify that requests were processed per the requirements of ACP-QA-2.068, "Station Bypass Jumper Control," Revision 8, 5/19/87 (N00 3.04 - Jumper, Lif ted Lead and Bypass Control). The audit covered twelve requests open as of October 193 __ _ _ - _ _ _ - _ _ _ _

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The audit confirmed that: jumpers were installed (or removed) per ad-ministrative requirements, including the completion of technical / safety assessments and evaluations as required by ACP 2.06B; approvals by operations personnel were granted as required and independent verifica-tions were completed; review and approval by the Plant Operations Review Committee (PORC) was accomplished, as required; and, completion of periodic audits by the Operations Supervisor and justification was pro-vided for those requests in place for greater than sir month Technical /

Safety assessments for 1-88-11 (cleanup system pipe plug) and 1-88-20 (Refuel Bridge Travel Limit Switches) were reviewed and found acceptable for given plant conditions. No unsatisfactory conditions were note .0 Engineered _ Safety Feature Outages Requiring Shutdown per Technical Specifi-cations (71707, 93702)

5.1 Loss of the ESW/ Containment Cooling System

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While cooling the torus water with both loops of the containment cooling system (using the "C" and "0" low pressure coolant injection (LPCI) and the "C" and "0" ESW pumps) on September 7 at 4:50 p.m., control room personnel noted momentary 480 volt bus ground alarms. Subsequent opera-tor investigation revealed that the strainer pit, which houses the ESW and the service water (SW) system strainers, had flooded to a level that partially submerged both ESW strainer drive motors. A packing leak on the "A" ESW strainer was identified as the leakage source. The operators secured torus cooling, declared the "A" ESW system inoperable, and placed the unit in a four day TS limiting condition for operation (LCO) per TS 3.5.B.5. The strainer pit was pumped down with a portable sump pum On September 8 at 2:50 a.m., the Millstone 1 Shift Supervisor was per-forming a routine tour of the intake structure and discovered the "B" ESW strainer drive motor breaker in the tripped position. When the tripped breaker would not reset, the "B" ESW system was declared inoper-able. This placed the unit ir, a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LCO per TS 3.5.B.6 due to the loss of both containment cooling systems. The licensee began a con-trolled shutdown at 3:00 a.m. The licensee also declared a "general interest event" and notified the resident inspecto On September 8 at 11:30 a.m., the "B" ESW system was returned to service af ter "baking out" and testing the strainer drive motor. This returned the unis te the original four-day TS LCO (3.5.B 5). The shutdown was halted and a reactor power increase was commenced at 1:38 p.m.: full power was achieved at 4: 00 p.m. TS LCO 3.5.B.5 was exited on September 10 at 4: 16 p.m. when the "A" ESW system was returned to service follow-ing strainer drive motor rewinding, strainer repacsing, and a successful system retes _ _ _ _ _ _ _ _ _ _ _ _

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a The inspectors noted the licensee's conservatism in declaring the ESW system inoperable due to the loss of the strainer cleaning functio ESW flow was available at the time and would have remained until the

strainers became fouled by debris from Long Island Soend. The licensee

has taken action to prevent recurrence, including revising OP-322,

"Emergency Service Water System", to include direction for manual service i water strainer rotation in the event of a future strainer drive motor failure. The licensee has also installed a level switch in the strainer l pit to alert the control room operators of pit flooding. The inspector i had no further question The inspector identified two concerns after review of licensee action , These concerns have been discussed with licensee management, who agreed

to evaluate and respond to each one. The first concern involved the declaration of a general interest event vice an unusual event (UE). The second involved an apparent inaccuracy in the Emergency Plan Emergency Action Level (EAL) classification scheme. These concerns are further

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ESW Classification as ESF System and QA Category I Components The operators did not classify the loss of ESW as a "loss of equipment" EAL because ESW is not defined as an Engineered Safety Feature (ESF) in Emergency Plan In.plementing Procedure (EPIP) Form 4701-7, which lists the Millstone 1 ESF systems. This appears inappropriate because ESW provides the heat sink for post accident containment cooling and residual heat removal via the LPCI heat exchanger Inspector review concluded that the licensee's cltssification of the EtW system conflicts with the Millstone 1 Updated Final Safety Analysis Re-port (UFSAR). UFSAR Sections 6.2.2, 6.3.1, 6.3.2, and Table 6.3-1. Table 6.3-4, and Table 3.2-1 define the ESW pumps as an integral part of the LPCI/ containment cooling system, whose function is required to assure successful core and ccatainment cooling is achieved following design basis accident The licensee recently upgraued the ESW strainer component power supplies in response to NRC Inspection Report 50-245/87-03. The ESW strainer motors are powered from the same 480 volt Motor Control Center (MCC-CO-5);

the loss of this MCC would secure both strainer motors and eventually cause the loss of ESW finw in both trains due to excessive strainer fouling. No strainer ifpass is availabl In addition, this power sup-ply is shed during a maximum credible accident (MCA) upon a loss of nor-mal power (LNP) signal. The licensee implemented plant design change request (PDCR) 1-87-87 to provide separate, safety-related power supplies to the ESW strainer motors anc their respective backwash solenoid The licensee's action in implemen;ing this PDCR shows responsiveness to the

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NRC concern. However, the classification of certain ESW strainer com-ponents in the Millstone 1 Material Equipment and Parts List (MEPL) re-mains questionable. For example, the inspectors found that the strainer blowdown solenoids are not classified as QA Category I. This indicates an inconsistency in the licensee's treatment of the ESW strainer functio The adequacy of the licensee's classification of the ESW system as an ESF and as QA Category I, and the correction of EPIP Form 4701-7, is unresolved (UNR 50-245/88-17 01).

EAL Classification Form 4701-1 The second issue involves an apparent error in the Millstone 1 Emergency Action level classification for Emergency Plan Implementing Procedure (EPIP) Form 4701-1 requires the declaration of an unusual event if an engineered safety feature (ESF) is lost. Inspector review found that the Millstone 1 and ? EAls require the declaration of a UE for the loss of an ESF only after the TS LCO is exceeded. In contrast, the Millstone 3 EAL form requires the declaration of a UE for the loss of an ESF if the plant is committed to shut down for failure to meet the TS action statemen The Millstone 1 EAL table was found to be inconsistent with Table 4-1A of the Millstone Emergency Plan, which was developed in accordance with the guidance provided in NUREG 0654, "Criteria fo. Preparation and Eva'uation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." The NUREG calls for declaration of an UE for "a loss of ESF requiring a shutdown by the technical specifi-cations". The intent of this NUREG guidance is to provide early noti-fication to the NRC of a significant degradation in plant protection, such as a total loss of a safety functions (e.g., loss of redundant ESW subsystems) that require the initiation of remedial reasures to assure plant safety (e.g., place the plant in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

In addition, EPIP 4701-1 classifies "conditions requiring plant shutdown under TS" as an unusual evant. Follow-up discussions revealed that the operators interpreted this requirement as applicable only when a shutdown, and not merely a power reduction, had been achieved, or when the LCO had been violated. The inspectors discussed this issue with Unit 1 manage-ment and the onsite Energency Plan Coordinator. The adequacy of the Millstone 1 and 2 EAL tables for loss of ESF and for a shutdown required by TS is unresolved (UNR 50-245/S3-17-02).

5.2 SGTS System Declared Administrative 1y Inoperable The Unit 1 Superintendent inforned the inspector at 3:00 p.m. on Septem-ber 23 of a problem identified on both trains of the standby gas treat-ment system (SGTS). The licensee had replaced charcoal for both trains (one at a time) after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of run time per TS 4.7.B.2.a. During a maintenance package closecut review, a maintenance supervisor dis-covered that the replacement charcoal was unacceptable, since it was uncertified (non-Q) material left in the warehouse from a 1931 non-QA

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purchase order. Since the documentation was not requested as a condition

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of the purchase, the licensee did not have the certified chemical an- i alysis for methyl iodide (MI) removal efficiency on file, i

Licensee enginearing review concluded that the installed charcoal was most likely satisfactory since: (1) although not required by the 1981  :

Purchase Order, the vendor routinely perfortred the required perfcrmance l tests as part of his program to supply such material in accordance with i industry standards; (ii) when contacted on September 23, the vendor con-  !

firmed the charcoal was manufactured and tested to Mine Safety Admini- i stration/American National Standards Ir. titute (MSA/ ANSI) standards that l would assure proper MI removal efficiency. However, as st.ted above,  ;

this certification was not supplied with the original purchase order and l

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would take some time and expense to retrieve from archive files; and, j l (iii) the post replacement tests performed in situ at Millstone for L

! dioctyl phthalate high efficiency particulate (DOP-HEPAs) and halogenated  !'

hydrocarbon removal were satisfactory, indicating that MI remr.a1 ef-ficiency also would be satisfactor !

l The licensee tchred the SGTS inoperable and entered TS LCO 3.7.B.3 as i j of 5 p.m. on Septen,ber 23, which required that the plan'. be placed in  !

! cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless at least one of the redundant trains I was woner made operable. The licensee considered both SCTS trains as administratively inoperable but available for service and peoceeded ex-  ;

peditiously with sequential charcoal bed replacement for both trains, j

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Licensee stores had qualified replacemen charcoal with the *equired  ;

l chemical certifications supplied by a qualified vendor, Char:oal Service [

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The inspector verified the chemical certifications for the replacement unit At 5:35 p.m. on September 23, the licensee declared an unusual event and j made the radio pager announcements required by the cmcrgc.. y plan for

! notification of the state and the licensee's emergency organizatio [

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A controlled shutdown was initiated with the plant initially at 100* ;

! At 5:57 p.m., the licensee made the required ENS cell to the NRC Duty e

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Officer to report the UE and event classification ptr 50.72(b)(1)(1)  !

j (shutdown per TS LCO) and 50.72 (a)(1)(i) (Emergency Plan activation).  !

) Post-repair testing of the replacement cells required the services of j a vendor, who was brought to the site in the early morning of September 24. Maintenance and testing of the "A" SGTS train was completed at 4:55 l

a.m. on September 24, which removed the plant from tha 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> shutdown

! LCO and allowed termination of the UE. The power decrJase was stopped

! at 5:05 a.m. at 97?e power. Work on the "B" SGTS train was finished by

! noon on September 24. The charcoal filters were replaced under Work I' Orders M1-88-07597A and 75998. The licensee sent the charcoal offsite for analysis of MI removal efficiency, and the licensee subsequently j informed the inspector that the test results for the non-Q charcoal j showed acceptable values, i

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k In a September 26 meeting with the Unit 1 Superintendent and the Opera- t

'; tions Supervisor, the inspector expressed concern regarding the power !

decrease while in the 24-hour shutdown LCO. That decrease was limited !

I to 3% for the first 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the action statement. The licensee :

stated that the full 24-hour period was available for completing a con- I trolled shutdown and, since a controlled cooldown can be completed in !

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, more deliberate action to shutdown the unit would have been taken at 5:00 a.m. on September 24 had the "A" train not been returned

, to service. The inspector acknowledged that the licensee can make full l use of the 24-hour action statement from the point it is determined that !

a situation requiring a shutdown exists. However, the "A" train was !

inoperable since 7

30 a.m. on September 21 and the "8" SGTS was inoper- 4

able starting at 9:30 a.m. on September 22 because of the questionable (

) charcoal. When this status was determined at 5:00 p.m. on September 23, '

l the availability of the safety function was deemed questionable enough i l

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to declare the SGTS technically inoperable. The inspector questioned !

the basis for delaying the controlled power reduction. The licensee !

stated that, in the future, the operators would be directed to reduce i j power further when in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> shutdown action statemen ;

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The inspector had no further comments on the licensee's short term ac- ;

i tions. The inspector also requested the licensee to address how non-Q ;

i charcoal was put into the SGTS. The licensee stated that a Controlled ;

i Routing (#7188) had been initiated at the request of the Vice President 4 of Engineering and Operations to address this and other qucstions on the -

event. The inspector noted from discussions with Maintenance and Stores personnel that the event was in part caused by: a failure to separate i l and positively identify non-Q from QA charcoal stored in the warehouse; !

i a failure by stores personnel to assure material issued from stores i i matched the quality level indicated on the material issue forms submitted ,

t by maintenance personnel; and, a failure by maintenance personnel to i j assure material received from stores had the required green tags indica- l l tive of QA material. This natter is unresolved penoing completion of j the licensee's review and subsequent review by the NRC (UNR 88-17-03). ~

. t l 5.3 Simultaneous Loss of the EDG and the "0" ESW pump f

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On October 12 at 8:00 a.m., the Millstone 1 EDG was removed from service to repiece the fuel injection nozzles for the #1 and #7 cylinder This f corrective maintenance activity placed the unit in a seven-day TS LCO per TS 3.5.F.2. At 2:00 p.m., while using the containment cooling system t to cool the torus water, an excessive packing leak developed on the "0" i

} E5W pump. The licensee removed the pump from service to determine the

{

extent of the packing failure and entered a 24-hour shutdown action !

j statement per TS 3.5.F.4. An unusual event was declared due to the shut- i j down being required by T The ESW pump was returned to service by 4:03 j p.m., returning the unit to the original seven day action .catement.

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d i A power increase from 964 commenced at 4:06 p.m., and the EDG was re- t turned to service by 7:30 The inspectors verified that the appro-priate declarations and notifications were mad The inspectors had no further questions, j 6.0 Maintenance (62703)

l The inspector observed and reviewed selected aspects of the following safety-related maintenance including procedural adherence, obtainin,' required ad- '

ministrative approvals and tagouts prior to work initiation, proper QA/QC '

involvement and personnel protection, and verification of systen restoration and retest prior to return to service. No inadequacies were note '

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Retorquing of the Emergency Diesel Generator (EOG) fuel punp assembly '

hold-down bolts on August 30, 31 (described below). l

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ESW strainer repairs on September 8, [

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Lubrt:4 tion of the #1 turbine bypass valve linkage on Octeber ,

r,epair of SGTS charcoal trains on September 2 ,

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Replacement of the fuel injection nozzles for the #1 and #7 EDG cylinders ,

on October 1 )

l The Millstone 1 EDG was removed from service at 6:40 a.m. on August 30 and I a seven-day TS LC0 per 3.5.F.2 was entered. During a routine maintenance l investigation of oil leakage identified during a monthly EDG surveillance run, ;

the licensee discovered loose hold-down bolts in three of the twelve fuel i injection pump assemblies. The inspector observed maintenance personnel re- I torquing the bolts in accordance with Fairbanks Morse manual specification !

The repair activities were conducted per AWO 88-6537 and approved station

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procedure MP 743.1 Licensee personnel coverage of the job was appropriate, with mechanical main- I tenance supervisors, a maintenance engineer, and quality control (QC) inspec- !

tors presen Diesel fuel pump repair procedure MP 743.12 was used to dis- I assemble the fuel pumps on the governor side of cylinders #3, 4, and 5 to '

allow torquing of the tappet assembly stud nuts to 100 ft-lbs. QC coverage !

of the activity was appropriate to verify housekeeping / cleanliness conditions {

(using SF 201, QC Inspection #88-347) and to verify satisfactory completion i of critical elements of the repair plan as specified on the Inspection Plan I (SF 207) for AWO 83-653 The QC inspection included satisfactory completion I of torqui99 the fuel pump stud nuts, torquing the tappet stud nuts, verifying ;

the proper fuel pump as-lef t stroke, and torquing of the delivery valve yoke [

nuts. MP 743.12 was changed when QC jetermined an inspection attribute on the valve stroke could not be verified within the specified tolerance of 0.005 :

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inches. The alternate measurement method for the valve stroke was taken from .

the vendor's instruction manual. Tappet nuts on all fuel pumps were checked ,

for tightness and found to be satisfactor ,

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The inspector reviewed the maintenance activities, including the operations and maintenance personnel actions in restoring and retesting the diesel, and

, found the activities to be completed satisfactorily. The activities were d

completed by qualified personnel, knowledgeable of their duties and procedural 3 requirements. Operations and maintenance provided effective oversight. The

, EDG was returned to service by 2:51 p.m. on August 3 The inspector had no i

further questions.

Licensee review concluded that the problem was not related to routine main-tenance and that the tappet nuts loosened over years of diesel operation,

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The licensee plans to consider adding a locking device to the tappet nuts to

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prevent recurrenc The inspector reviewed the licensee's evaluation which concluded that, in the as-found condition with the tappet nuts loose on the

! #3, 4,. and 5 cylinders, no adverse inpact on diesel operability occurre ; The inspector had no further questions.

J j 7.0 Surveillance (61726)

The inspector observed portions of the following surveillance tests for con-

duct in accordance with current approved procedures, for test result comp 11-l ance with technical specification and administrative requirements, and for deficiency correction in accordance with administrative requirements. The inspector noted that the surveillance teams displayed thnrough coordination

and rigorous procedural adherence. No inadequacies were identified.

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SP 681.1,"EDG Operational Readiness Demonstration " on August 31

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SP 411B, "Main Steam Line High Flow Functions) Test" on October 4

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SP 408F, "Turbine Stop Valve Closure Functional Test" on October 6 A --

SP 408R, "Turbine Bypass Valve Functional Test" on October 6

l Tvc surveillance activities which received further inspector follow-up are i described below.

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EDG Operational Readiness Demonstration on August 31

) The inspector noted no abnormal conditions during the diesel run except for

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a small amount of oil leakage from #4 cylinder (governor side) and an annun-j ciation on high lubricating oil (LO) temperature. A Plant Equipment Operator

! (PEO) noted and tagged the oil leaks for follow-up. The PE0 stated the LO j alarm st. point should be 225 degrees F and the highest recorded temperature J was 209 degrees F. This condition has been noted and reported to I&C for

{ repai The inspector observed the pEO complete the post-shutdown checks per l SP 683.1. All actions and conditions were satisfactor Inspector indepen-i dent verification of removal of tags for clearance 1-814-83 showed the activity

] was completed satisfactorily. The diesel was properly returned to service.

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The PEOs were very knowledgeable of the equipment and their duties; they had

. procedures at the work area and followed them.

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Turbine Bypass Valve (BPV) Functional Test on October 6

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While conducting the BPV functional test, the #1 BPV remained approximately

] 10% open in spite of repeated operator attempts to close the valve. The in-l spector observed as licensee personnel greased the accessible BPV linkage fitting The inspector noted a well-coordinated effort by the repair team

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and adherence to procedures for maintaining radiation exposures as low as 1 reasonably achievable. The valve retested satisfactorily, and the inspector j had no further questions.

8.0 Licensee Event Reports (92700)

The following Licensee Event Reports (LEh) were reviewed to assess LER ac-

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curacy, the adequacy of corrective actions, compliance with 10 CFR 50.73 re-

porting requirements and to determine if there were generic implications or

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if further information was required, i

LER 50-245/88-06-00: "SGTS Initiations." Unexpected standby gas treatment system initiations on August 6 and 11 were originally addressed in NRC In-spection Report 50-245/88-11, and were reported by the licensee per 10 CFR i E0.73 (a)(2)(iv). The inspector found that the report contained thorough l

detail concerning the licensee's investigation and identified no deficiencies.

] LER 50-245/88-07-00: "Loss of Both Containment Cooling Subsystems." This

• event is described in Report Detail The inspector identified no inade-I quacie .0 Plant Operations Review Committee __(40700)

) The inspector attended Plant Operations Review Committee (PORC) meetings on August 31, September 21, 28 and October 13. Technical Specification (TS) 6.5.1 requirements for committee quorum wert met. The meeting agenda included reviews of Plant Incident Reports, plant des'gn modifications, procedure re-visions, and new proccdures. The inspector nited that the committee dis-charged their functions in accordance with TS 5.5.1. No inadequacies were j identified.

! 10,0 h gement Meetings _(_30703)

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Periodic meetings were held with station management to discuss inspection I

findings during the inspection period. A summary of findings was also dis-I cussed at the conclusion of th: inspection. No proprietary information was

, covered within the scope of the inspection. No written material was provided 1 to the licensee by the inspector I

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