IR 05000280/1989020

Insp Repts 50-280/89-20 & 50-281/89-20 on 890604-0701. Violations Noted Re Failure to Provide Adequate Procedure to Establish Initial Plant Conditions for Testing.Major Areas Inspected:Operation,Maint & LER Review

ML18153B831
Person / Time
Site:	Surry
Issue date:	07/21/1989
From:	Fredrickson P, Holland W, Larry Nicholson, York J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18153B829	List: IR 05000280/1989020 ML18153B828
References
50-280-89-20, 50-281-89-20, NUDOCS 8908010103
Download: ML18153B831 (20)

Text

Report Nos. :

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA ST., ATLANTA, GEORGIA 30323 50-280/89-20 and 50-281/89-20 Licensee:

Virginia Electric and Power Company Glen Allen, VA 23060 Docket Nos. :

50-280 and 50-281 Facility Name:

Surry 1 and 2 License Nos.:

DPR-32 and DPR-37 Inspection Conducted:

June 4 - July 1, 198 Inspectors:

0-, ~~---- ~~

W. E. Holland, S~esidentlnspector

~~~

Accompanying Approved by:

Scope:

J. W. York, Resident

>7~

L. E.. Nicholson, P. E. Fredrickson, Section Chief Division of Reactor Projects SUMMARY 7/z//f7 Date Signed 7/-z, /P'1 Date Signed 7/z11P1 Date s'i gned

i

>t/J.-7 D eSigned This routine resident inspection was conducted on site in the areas of plant operations, plant maintenance, plant surveillance, licensee event report review, and followup on inspector identified item Certain tours were conducted on backshifts or weekend Backshift or weekend tours were conducted on June 4, 5, 10, 11, 13, 17, 18, 20, 21, 22, 24, 25, 26, 27, 28, 29, 30, and JuJy Results:

During this inspection period, one violation and two inspector followup items were identifie The violation (paragraph 6.a) was identified for failure to provide an adequate procedure to establish initial plant conditions for testin The violation meets NRC Enforcement Policy for not issuing a Notice of Violation and is not cite In addition, an IFI was identified (paragraph 5.c)

for followup on MCR envelope pressurization improvement Finally, an IFI was identified (paragraph 5.d) for followup on licensee evaluation of maintenance activities associated with the repair of 1-SI-P-l **

• - Persons Contacted Licensee Employees REPORT DETAILS

• W. Benthall, Supervisor, Licensing R. Bilyeu, Licensing Engineer R. Blount, Superintendent of Technical Services

• D. Christian~ Assistant Station Manager D. Erickson, Superintendent of Health Physics

• E. Grecheck, Assistant Station MaDager

• M. Kans1er, Station Manager

~- McCarthy, Superintendent of Operations G. Miller_, Licensing Coordinator, Surry

• J. Ogren, Superintendent of Maintenance

• T. Sowers, Superintendent of Engineering A. _Price, Site Quality Assurance Manager Other licensee employees contacted included control room operators, shift technical advisors, shift supervisors and other plant personne *Attended exit intervie Acronyms and initialisms used throughout this report are listed in the last paragrap On June 7, 1989, the NRC Region II Director, Division of Reactor Projects, L. Reyes visited the residents at the Surry Power Statio During the visit, Mr. Reyes conferred with the residents, was given a plant tour, and met with station managemen * * Plant Status Unit 1 began the reporting period' in cold shutdow Maintenance 'and testing activities were completed and the unit co1T111enced heatup above 200F on June 30, 198 At the end of the inspection period, the unit was in intermediate shutdow~ with a slow heatup in progres Unit 2 began the reporting period in cold shutdow The unit remained in cold shutdown for the duration of the inspection period while substantial operational reviews and maintenance activities were being conducte.

Operational Safety Verification (71707) Daily Inspections The inspectors conducted daily inspections in the following areas:

contra 1 room staffing, access, and operator behavior; operator adherence to approved procedures, TS, and 1 imiting conditions for

operations; examination of panels containing instrumentation and

~

other reactor protection system elements to determine that required channels are operable; and review of control room operator logs, operating orders, plant deviation reports, tagout logs, jumper logs, and tags on components to verify compliance with approved proc'edure The inspectors specifically focused on Unit 1 restart activities during the latter ~art of the inspection perio Twenty-four hour monitoring coverage of the Unit 1 restart activities by the resident staff co1T111enced on June 24, 198 Weekly Inspections The inspectors conducted weekly inspections in the following areas:

verification of operability of selected ESF systems by valve alignment, breaker positions, condition of equipment or components, and operability of instrumentation and support items essential to system actuation or performanc Plant tours were conducted which included observation of general plant/equipment conditions, fire protection and preventative measures, control of activities in progress, radiation protection controls, physical security controls, plant housekeeping conditions/cleanliness, and missile hazard The inspectors routinely moni.tored the. temperature of the AFW pump discharge piping to ensure steam binding is prevente The inspectors devoted a considerable amount of time to plant tours during this inspection perio These tours included several extensive walkdowns with licensee management of the Unit 1 containment as well as various remote locations throughout the plan The overall condition of Unit 1 has improve Housekeeping inside the containment was_ observed to be much improved over previous startup The number of work request tags hanging on plant equipment appeared to be minima The inspectors verified that temporary staging and services had been remove No outstanding discrepancies were identified as a result of these walkdown Biweekly Inspections The inspectors conducted biweekly inspections in the following areas:

verification review and walkdown of safety-related tagouts in effect; review of sampling program (e.g., primary and secondary coolant samples, boric acid tank samples, plant liquid and gaseous samples);

observation of control room shift turnover; review of implementation of the plant problem identification system; verification of selected portions of containment isolation lineups; and verification that notices to workers are posted as required by 10 CFR 19.

• Areas Inspected Inspections included areas in the Unit 1 and 2 cable vaults, vital battery rooms, steam safeguards areas, emergency switchgear rooms, diesel generator rooms, control room, auxiliary building, Unit 1 and 2 containments, cable penetration areas, independent spent fuel storage facility, low level intake structure, and the safeguards valve pit and pump pit area Reactor coolant system leak rates were reviewed to ens~re that detected or suspected leakage from the system was recorded, investigated, and evaluated; and that appropriate actions were taken, if require The inspectors routinely independently calculated RCS leak rates using the NRC Independent Measutements Leak Rate Program (RCSLK9).

On a regular basis, RWPs were reviewed and specific work activities were monitored to assure that they were being conducted per the RWP Selected radiation protection instruments were periodically checked, and equipment operability and calibration frequency were verifie Physical Security Program Inspections In the course of monthly activities, the inspectors included a review of the 1 icensee' s physical security progra The performance of various shifts of the security force was observed in the conduct of daily activities to include:

protected and vital areas access controls; searching of personnel, packages and vehicles; badge issuance and retrieval; escorting of visitors; and patrols and compensatory post During annua 1 rebadgi ng of one of the resident inspectors, it was noted that the licensee's security staff has implemented a special briefing of all persons who are badged for unescorted access to the statio This briefing addressed all required duties and responsibilities associated with being granted unescorted acces The inspector believes that this new briefing concept is a positive training attribute with regards to implementation of personnel awareness of security requirements at the statio Licensee 10 CFR 50.72 Reports (1)

On June 5, 1989, the licensee made a report in accordance with 10 CFR 50.72 regarding an inadvertent ESF actuation of feedwater system components on Unit The unit was in cold shutdown at the time of the actuatio The ESF actuation occurred during preparation for CLS/Logic testing of the Unit 1 118 11 train ESF component The actuation was a result of removal of a SG level durrrny signal on one channel of one of the SG Another channel was already in trip due to actual SG level being below the low-low level setpoin This condition made up the 2 out of 3 matrix that would normally result in auto start of AFW pumps, i

opening of AFW supply valves, and isolation of SG blowdow Al\\

components which were operab 1 e for the test performed as designe The licensee stopped testing preparation and critiqued the even This issue is addressed in more detail in paragraph (2)

On June 15, 1989, the licensee made a report in accordance with 10 CFR 50.72 regarding an inadvertent ESF actuation of portions of the auxiliary building ventilation syste The actuation occurred as a result of returning to service l-VS-F-58A (Auxiliary Building CAT I Filtration Fan).

The starting of the fan resulted *in a reduced IA pressure to the ESF components resulting in ESF actuatio The reduced IA pressure was attributed to the installation of special test equipmen No ESF signal was present when the actuations occurre (3)

On June 22, 1989, the licensee made a report in accordance with 10 CFR 50.72 regarding an inadvertent ESF actuation of portions of the ventilation system damper The actuation occurred as a result of electrical arcing that was generated while inserting a fuse into a vital bus circui The circuit tripped and the resulting loss of power on that circuit caused the dampers to realign to their ESF positio The licensee is continuing to troubleshoot the cause of the arcing and circuit tri No ESF signal was present when the actuation occurre Restart Readiness Assessment Review - Unit 1 During this inspection period, the inspectors monitored the licensee's management review of all functional areas associated with the return to operation of Unit These functional areas included operations, maintenance, surveillance, engineering, radiological controls, safety assessment, and quality verificatio The management team involved in these reviews included the Station Manager, the two Assistant Sta ti on Managers, the Quality Assurance Manager, and the Assistant Vice President, Nuclear Operation The initial reviews of each functional area were held on June 12 and 13, 198 Each review consisted of the superintendent of each functional area discussing why their area of responsibility was ready for restar The discussions focused on items that had not been completed at that time and which were required for unit restart. The following items were reviewed in each functional area:

Operations -

Material condition walkdowns, housekeeping walkdowns, safety system lineups. chemistry control readiness, annunciator review, system status log requirements, action statement log requirements, temporary*modification log status, post maintenance testing, selected critical valve third checks, and required startup trainin **

• *

Maintenance - Material condition walkdowns, work order backlog?

MOV issues, check valve issues, steam generator issues, preven-tative maintenance status, and electrical 4160V and 480V breaker Surveillance -

Periodic testing program, ASME Section XI program, erosion/corrosion program, and Type Band C testin Engir.eering -

EWR backlog review, Type 1 backlog review, technical reviews of DCPs and EWRs, MOV issues, snubbers, root cause evaluations, applicable JCOs, electrical terminations, ESF testing, control room habitability, instrument air system, drawing update, and cable separatio Radiclogical Controls - Contaminated area reduction, personnel contamination reports, exposure evaluation, hot spot reduction, contamination controls, lead shielding, HP tech availability and effectiveness, and radiological engineering control Safety Assessment -

NRC commitments, CTS items, opera ti ona 1 even:s, HPES recommendations, industry experience, North Anna Power Station startup issues review for applicability, TS changes, and SNSOC reviews of deviation report backlog.

After the completion of each review area, a listing of questions was generated and each superintendent was required to address these questions in the continuation of restart assessment meetings on June 18, 19, and 21, 198 After the meeting on the 21st, a restart issues "punch list" was generate This listing required that each outstanding issue be satisfactorily resolved prior to the indicated startup mod In addition, on June 22, station management reviewed all outstanding. safety-related work orders and deviation reports that were associated with Unit The inspectors monitored the licensee's meetings and noted that the reviews were detailed and appeared to adequately address all outstanding issue Overview of Licensed Operator Training for Restart On June 14, 1989, an inspector attended an information and training session fer ROs and SRO The meeting covered the following:

(1)

Superintendent of Operations discussion of startup and operating philosoph (2)

A summary of all the modifications performed during this extended outage.

(3)

The n~w MOV program and the role of the licensed operators in this progra i.

(4)

(5)

A review the changes in AP 37.01, Abnonnal Environmental~-

Conditions, with' regar,ds to actions to be taken_ during hurricane condition A surrnnary of the changes to the fo*llowing emergency procedures and an explanation of why the changes were made:

(a)

EP 1.00, Reactor Trip/Safety Injection (b)

EP 2.00, Loss of Reactor or Secondary Coolant (c)

EP 2.04, Transfer to Hot Leg Recirculation (d)

Other minor changes to emergency procedures The inspector observed the presentations by the training staff and the response of the operators and considered the training session to be adequat On June 26, 1989, the inspectors attended a training session for one of the operations shifts, which included the shift STA and licensed operator The purpose of the training was to provide for startup '

practice on the plant simulator and to review recent industry events related to reactivity mismanagemen The inspectors believe that the classroom training session was conducted in an excellent manner and the preparation by the instructor was c00111endabl The inspectors also monitored the simulator startup training and believe that it was

_adequat The inspectors also discussed with the Operations Superintendent, the licensee*s* method for preventing unqualified operators from assuming a license dut The licensee does not have an established program to administratively prevent a licensed operator from assuming the controls if the operator fails to requalify. The current philosophy that is used_ at Surry is to rely primari'lY on the integrity of the operator, coupled with good corrnnunications between the Training Center and the Operations Superintenden System Status Inspection During this inspection period, the inspectors conducted a verification of the status of equipment identified as important by the Surry PR The inspector utilized the NRC draft report EEG-REQ-7746, dated July 1987, 11 PRA Applications Program for Inspection at the Surry Nuclear Power Station, 11 as a guioe to identify components that comprise significant contributions to risk during an acciden The inspector then determined the status of these components by reviewing the plant status logs, open work orders, open station deviations, outstanrling retests and field walkdown *

While perfonning a field walkdown on the backshift, the inspector~

encountered a contractor employee sleeping while on firewatch dut This particular firewatch was established in Unit 2 safeguards after discrepancies were discovered regarding the area cable tray cover Both units were in cold shutdown with no work in progress in this fire are The inspector notified the control room and the firewatch was relieved of his dutie This particular firewatch was not required by TS; however, a station deviation report was submitted which will require resolutio The licensee corrective action for this occurrence was to terminate the employee; however, they are also reviewing the program to ensure that all necessary additional steps will be taken to assure proper firewatch attentiveness is maintaine Although this occurrence did not violate any regulations, the resident inspectors expressed their concern of this matter to station management and will continue to closely monitor the licensee 1s program for implementing an effective firewatch progra Within the areas inspected, no violations or deviations were identifie.

Operational Readiness Program Review - Unit 2 {71710)

The inspectors met with the Manager of Nuclear Engineering and the Manager of Licensing for a discussion about the licensee's plan for reducing the scope of the inspections for Unit 2 system walkdown The licensee stated that the areas where significant discrepancies were identified on Unit 1 are being evaluated for Unit ColTITion systems for both units are complete and 30 percent of the Unit 2 walkdowns have been complete After the inspection period ended, the licensee sent a letter to the NRC dated July 7, 1989, requesting that the scope of the remaining system walkdowns and electrical testing prior to Unit 2 restart be reduced based on the limited findings during the Unit 1 walkdowns and testin The NRC is reviewing that reques The residents will monitor all required licensee actions in the system walkdown area.prior to Unit 2 restart..

Within the areas inspected, no violations or deviations were identifie.

Maintenance Inspections (62703 and 42700)

During the reporting period, the inspectors reviewed maintenance activities to assure compliance with the appropriate procedure Inspection areas included the following: EWR 89-458, MCR Air Bottle System Modification Durirg the performance of periodic test 1-PT-33.1, dated June 1, 1989, using the air bottle bank in MER3, insufficient air flow was obtained through the pressure regulators to maintain a positive pressure in the MCR envelop The regulators were determined to be undersized for their intended functio An air

flowrate of approximately 300 scfm is required to maintain the..,,

pressure in the MCR envelop The installed regulators provide a maximum flowrate of 100 scf The licensee initiated the subject EWR to install regulators of sufficient rating to ensure the satisfactory completion of l-PT-3 The EWR was reviewed by the inspector and was determined to be acceptabl Work was performed under _work request 636730 and was monitored by the inspector No discrepancies were note After unsuccessfully running PT-33.1 on June 28 (see paragraph 6.i. ), the licensee modified the trim of the valves to provide a more consistent air flow throughout the tes The valves performed satisfactorily during the test on June 2 EWR 89-462, Evaluate Ventilation System MCR Air Bottle System Capacity Calculations by the licensee's engineering staff indicated that there was not sufficient capacity in the existing 72 air bottles to provide the required amount of air to the MCR for one hou The calculations indicated that ten additional bottles per bank were requite EWR 89-462 was initially written to install the extra air bottles to provide the necessary volume of air and was subsequently revised to allow for the inspection/repair of the dampers for the MCR emergency ventilation fan The licensee elected to start with damper 1-VS-104 This damper was removed and inspected on June 2 inches were found between the damper and the were gaps along the inner edge of the dampe the seating surface not extending completely dampe Gaps up to 0.75 duc Also noted The.e were due to (360) around the The damper was taken to the shop for repair The repairs consisted of fabricating a new section of duct that would fit snugly around the damper with a neoprene gasket between the dawper and the duc The licensee then sealed the junction with silicone sealant to minimize leakage between the damper and the duc The seating surfaces were refurbished ~i th new rubber gaskets and extended to provide sealing for 180 on each half of the dampe After the repairs were completed, the damper was placed back in the syste The licensee then performed PT-33 to check if the repairs would be acceptable to allow for performance of PT-3 using the MER3 air bottle This test was not satisfactor The licensee then commenced work on damper 2-VS-204A.

• Prior to completing work on 2-VS-204A, the licensee decided to-~

attempt to run PT-33.1 using 72 air bottles in MER3 (see paragraph 6.i.). This test was unsatisfactory, and the licensee recorrmenced work on 2-VS-104A and began work on l-VS-1048 and 2-VS-204 During the time of repair on the above dampers, the licensee performed helium leak testing on penetrations in the cable vault rooms for both unit Unit 1 had ten leaking penetrations, and Unit 2 had eight. The inspector observed the sealing on some of these penetration The 1 icensee used d.evi ated procedure EMP-C-FP-23, Sealing of Fire Stops with Fire Resistant Silicone Foam, dated July 17, 1987, which was reviewed by the inspector It was noted that all of the fire resistant silicone foam containers examined had Category 1 tags which designated the purchase order and stock numbe On June 29, work o~ the dampers was completed as ~ell as further repair of lea*ks in the boundarie PT-33 was performed satisfactorily after the above mentioned repairs were complet PT-33.1 was th~n performed satisfactorily using 82 bottles in MER3 (see paragraph 6.i.).

.

After reviewing the EWR data and the test results, the inspectors questioned the licensee as to how testing was being accorripl ished satisfactorily in the past based on present known problem areas and the necessary corrective actions that had to be accomplished to successfully pass the tes The 1 icensee reviewed this area and concluded that testing in the past with the use of the air bottles as the pressure source had onl~ been performed twice; once in 1986 and once in 198 Testing prior to these d9-tes was performed using one of the emergency ventflation fans as the air supply as allowed by T The recorded results of the past.tests appeared to be satisfactor However, during the present testing, the licensee assured that appropriate initial conditions were required to be recorded prior to commencing the tes Also, the present test requires that a 0.05 inches of water differential pressure be maintained for the test duratio In the past, only a positive pressure of 0. 05 inches of water from the O reference on the gages was require Since ventilation alignments could easily allow for the starting of the test with an initial positive reading, past testing may not have provided for a true test to verify 0.05 inches of water differential pressur This conclusion was considered appropriat~ by the inspector However, this issue is again identified as a weakness in the licensee's original design and testing programs, which were discussed in the enforcement actions issued on May 18, 1989.

• EWR 89-472, Evaluation of the Air Bottle Dump Test After completing PT-33.1 on June 29 (see paragraph 6.i.), the licensee initiated this EWR to evaluate the results of the tes The stated purpose of the EWR was "to document the physical modifications to the MCR bottled air subsystem and document the justification for acceptance of the test results from PT-33.1.

Although the test was completed satisfactorily, the licensee determined that the margin of acceptance was not as good as it could have bee Because of this, engineering recommended that the pressure setpoints on l-VS-PCV-531 and 532 be changed to obtain a higher air flowrat Since the fan orifices used during the performance of PT-33 provided approximately 310 scfm, the pressure setpoints for the PCVs needed to be increased to provide 310 scfm in order to validate the future results of PT-3 Engineering a 1 so recommended that current efforts to identify and further seal electrical penetrations into the MCR envelope should continu The inspectors also believe that additional evaluations of the capacity of the air banks are warrante The tracking of these efforts to improve the integrity of the MCR envelope and determine if further modifications are warranted is identified as IFI 280, 281/

89-20-01, MCR envelope pressurization improvement Repairs to 1-SI-P-lA, Unit 1 Low Head Safety Injection Pump.

The inspector continued the review of maintenance activities associated with the return to service of the subject pum Initial maintenance activities were discussed in NRC Inspection Report Nos. 280,281/89-08 and 89-13. The licensee experienced additional difficulties with this pump after correcting the original parts proble The pump was subsequently disassembled several times due to the following:

- Mechanical seal problem Level indicator rod in seal head tank ben Pump binding after reassembl Seismic support modification Bolt torquing specification problem The inspector monitored the licensee's efforts over the past three months regarding the repair of this pump, and discussed the problem areas with station supervision and managemen The inspector was. informed that a post maintenance evaluation will be conducted to review lessons learned in this are The inspector will review the licensee's evaluation of the above maintenance activities and identifies this effort as IFI 280/89-20-02, followup on licensee evaluation of maintenance activities associated with the repair of 1-SI-P-l *

Within the areas inspected, no violations or deviations were

~

identifie.

Surveillance Inspectio_ns (61726 and 42700)

During -the reporting period, the inspectors reviewed various surveillance activities to assure compliance with the appropriate procedures as follows:

Test prerequisites were me Tests were performed in accordance with approved procedure Test procedures appeared to perform their intended functio Adequate coordination existed among personnel involved in the tes Test data was properly collected and recorde Inspection areas included the following: l-ST-239, ESF Actuation with Instantaneous UV - J Bus On June 5, 1989, the inspectors witnessed selected portions of the performance of special test l-ST-23 The purpose of the test was to verify the sequencing of loads onto the lJ electrical bus following the injection of an ESF signal along with a simultaneous UV condition on the emergency bu This test was conducted to verify that the required actuations take place, the required loads are tripped off the emergency bus, and that the appropriate loads are re-sequenced back onto the bu During preparation for the test, the operators attempted to close the reactot trip breakers in a~cordance with step 5.14 of the procedure; however, the breakers would not close due to a reactor trip signal locked in from 11C 11 SG channel 2 low level in coincidence with a steam flow/feed flow mismatch conditio The steam flow/feed flow mismatch condition was an instrumentation problem which had been previously ideritified for corrective actio It should be noted that SG level simulators had been install~d on channels 1 and 3 for each SG in order to simulate a narrow range level of greater than 33%.

This simulation would eliminate the SG low-low level trip signals so that the reactor trip breakers could be closed for the test. After the operators recognized the problem, a decision was made to remove the level simulators from channel 3 of the SG level instruments and reinstall these simulators on channel This change would eliminate the steam flow/feed flow mismatch problem on channel 2 and allow for closing of the reactor trip breaker *

A change to the test procedure was submitted and approved by the station safety committee to accomplish this switchove However, as soon as the instrument technicians removed the level simulator from channel 3 on the first SG, an ESF actuation occurred due to the protection circuitry sensing a low-low level condition in 2 of 3 chan~els on the respective steam generato This condition caused the 118 11 train AFW pump breaker to close, the AFW isolation valves to open, and the SG blowdown isolation valves to clos The above ESF actuations occurred because the equipment had been positioned earlier to respond as part of the special tes At this point, the unit SRO suspended additional test preparations and a critique was called for by the O~eration~ Superintendent to review the even The critique was conducted by the Station Manager and the above event was discussed in detai At each point in the review process, the individuals were queitioned as to why they did not recognize the pofential problem that did occur when the level simulator was removed from channel All personnel involved in the critique including the test director, instrumentation supervisors, operations supervisors, and the technical. services superintendent, who presented the procedure change to the safety corrmittee, stated that they understood the protection logic and consequences; however, a lack of attention to detail on the part of all involved led to the inadvertent ESF actuatio The Station Manager agreed with the conclusions of the personnel involved in the event and concluded that testing could resume; however, taking the time to do things right and attention to detail as the first orders of business was emph~s1ze Testing preparations resumed, and after the day shift turnover and appropriate briefings, the actual test was conducte The inspector independently verified that initial conditions, and selected steps in the performance section of the procedure were completed as require The inspector*also attended the critique meeting after the ESF actuation and agrees with the licensee's assessment that taking the time to do the job correctly and attention to detail were contributors to the even The inspector monitored the actual performance of the test on the afternoon shift and observed that the test director was controlling test activities in a good manne The inspector also noted that the problems identified during testing were properly documented with deviation reports and that test restoration was progressing in a satisfactory manne The inspector specifically reviewed the problem associated with the ESF actuation and considers that the procedure and/or instructions to swap the level simulators from channel. 3 to channel 2 werp ina.dequate in that they did not prevent the

• inadvertent ESF actuatio However, the actual event had no ~

adverse safety impact on the uni Also, the fact that all involved recognized that they contributed to the problem because of their lack of attention to detail allowed for a conclusion on the part of the inspector that personnel sensitivity to problems of this nature was appropriate. The licensee did report the event to the NRC as required by 10 CFR 50.7 Failure to pro-vide an adequate procedure to establish initial plant conditions for testing is a violatiqn ( NCV 280/89-20-03); however, the violation is not b~ing cited because the criteria specified in Section V.A of the Enforcement Policy were satisfie l-ST-232, Load Sequenc~ Test - lJ Bus On June 8, 1989, the inspectors witnessed selected portions of special test l-ST-23 The purpose of the test was to functionally verify sequencing of loads onto emergency bus lJ following the injection of an ESF signal along with an UV on the emergency bu The UV was injected after the outside recirculation spray pump had started fro_m the initial ESF signal, which tripped required loads off the emergency bus, realigned the bus to the EOG, and re.-sequenced the required emergency loads back onto the emergency bu The inspectors verified that selected initial conditions and testing prerequisite steps were performed as required, witnessed the pretest brief of personnel involved in the test, and whnessed the actual performance of testing from ESF s i gna 1 initiation through UV signal initiation and finally through test restoration to a point where all safety-related pumps had been secure The inspectors also noted that proper identification and documentation of test deficiencies were being accomplishe No discrepancies were note Auxiliary Feedwater Testing On June 15, the inspectors witnessed testing of the AFW system in accordance with test procedure 1-PT-15.9, Verification of '

Auxili_ary Feedwater Flow to Each Steam Generato The specific test evolutions witnessed by the inspector started AFW pump 1-FW-P-38 and verified that flow could be established to each S No discrepancies were note Instrument Air Compressor Test On June 20, the inspectors witnessed testing of the refurbished IA compressor l-IA-C-1 in a_ccordance with periodic test procedure STP-30, Instrument Air Compressor Surveillanc The purpose of this test was to ensure that the compressors can

perform their design function of supplying station instrument~

air loads during the loss of offsite power or loss of normal IA suppl The overall performance of the compressor was observed to be satisfactory, although minor adjustments were required for the control circuitry that loads and unloads the compresso No outstanding discrepancies were identifie Control Room Envelope Chiller Test The inspectors continued to monitor testing of the control room envelope ventilation system in accordance with special test ST-235, Control Room Chiller Equipment Performance Tes This test provides baseline data on the performance of equipment necessary to maintain design temperatures in the control room and emergency switchgear roo The inspector expressed concern after observing indications that this equipment was still being operated and mainta,ned in a manner similar to a non-safety related support syste This action contributed to at least two 10 CFR 50.73 reportable events during this inspection perio The licensee agreed with the observation and initiated steps to increase awareness of the importance of this syste The inspector reviewed the final test results for the entire system and considers the results adequat This review included several tests and evaluations from both the licensee and outside engineering firms and concluded with a June 24, 1989 memorandum from the system engineer to station management stating that the system was fully operabl The inspectors will continue to closely monitor this marginal system until an upgraded system is installed during the next refueling outag No outstanding discrepancies were identifie Differential Pressure Testing of 1-FW-MOV-151F (ST-270) On June 17, 1989, the inspectors witnessed the d/p testing of one of the AFW MOVs (1-FW-MOV-151F).. The test was conducted in accordance with special test ST-27 The inspectors verified that the test was being conducted in accordance with.the procedure to include initial conditions, proper cormiunications, and appropriate recoroi ng of test condition The inspectors also noted that the lead MOV engineer was present during testing to provide necessary assistance if neede The test appeared to have demonstrated successful d/p operation of the valv No discrepancies were note Outside Recirculation Spray Pump Test The inspectors reviewed the results of periodic test 1-PT-17.3, Containment Outside Recirculation Spray Pumps, performed on June 23 on l-RS-P-2 Data collection appeared to be adequate and the pump performed as desire No discrepancies were note ~.

15 CSD Test of the LHSI Lines to the Charging Pumps (1-PT-18.3E)

On June 20, the inspector witnessed functional testing of the flowpath from the A low head safety injection pump discharge piping to the suction piping of the high head safety injection/charging pumps in accordance with periodic test procedure l~PT-18.3 The test that was conducted did confirm that the appropriate flowpath was available as evidenced by an increase in pressurizer leve The inspector reviewed the completed test procedure after th~ testing was complete No discrepancies were note Control Room Pressure Test The inspectors closely monitored the licensee actions to troubleshoot and perform a control room pressurization test as required by T This test, PT-33.1, requires the control room envelope to m-aintain a 0.05 inches of water differential pressure for a minimum of one hou After performing maintenance on various door seals, dampers, and penetrations, the licensee successfully d~monstrated a positive seal using a fan to simulate a bottle dump, which was accomplished by PT-33, yet could not achieve similar results with an independent train of bottles. Troubleshooting was complicated due to the duration (approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />) to recharge a bottle bank after each trial ru On June 26, after locating and repa1r1ng many leaking

• penetrations, the licensee ran PT-33 in an attempt to verify that the leakage had been reduced to an acceptable rat The simulation with the fan did not indicate an improvement and further searching was done to locate leaking penetration Leaks were identified in the seals for the MCR envelope doors and were taped to reduce the leakag This did not significantly improve the indicated pressur Additional leakage was identified in the dampers-from the MCR emergency ventilatidn fans (see paragraph 5.b.).

After some doors were repaired and the suctioni to each of the MCR emergency ventilation fans were taped closed, the results of the testing using the 82 air bottle bank located in the Unit 1 cable vault indicated that a 0.05 inches of water differential pre~~ure could be achieved and maintained for one hour in this configuratio The air bottles had 425 psig remaining at the end of the tes The licensee then opened and closed doors to the MCR envelope five time Each time the differential pressure dropped off to zero and recovered to above 0.05 inches of water within thirty second After the door operations were completed, the air bottle pressure was at 300 ps-ig and the MCR differential pressure was above 0.05 inches of wate *

On June 28, the licensee attempted to perform PT-33.1 using the->-

72 bottles in MER3~

The test was unsatisfactory after the first set of data was taken and the values indicated less than 0.05 inches of water differentia The regulating valves were adjusted to increase.the differential pressures to an atceptable leve When a differential pressure of greater than 0.05 inches of water was obtained, the regulating valves were adjusted to detennine what effect they had on the pressur The manipulation of the valves continued throughout the test until they were fully open with no effect on the pressur After approximately 45 minutes the valves were fully open and the required flowrates began to decreas As a result of this test, the licensee decided to adjust-the trim of.the valves in order to obtain a more consistent flowrate throughout the tes In parallel, the licensee searched for and repaired several more leaks in the MCR envelop The dampers for _the MCR emergency ventilation fans wefe also repaire On June 29, PT-33 was completed satisfactorily prior to performing PT-33.1 using 82 bottles in MER PT-33.1 was then performed and after engineering evaluation of the results was declared a satisfactory test (see paragraph 5.c). Surveillance Testing for Emergency Diesel Generator No. 3 The inspector reviewed periodic test 2-PT-22.3 C, Diesel Generator No. 3 Test, dated June 21, 1989, and witnessed part of the test for returning the diesel to service on June 25, 198 Engineering had instrumented the diesel. to test the frequency because of a high value in the previous test. After fast starting the diesel, the instrumentation indicated that the frequency was in the acceptable rang Several other adjustments were made to improve the diesel performance, none of which would affect the frequenc The diesel was then run for two hours and loaded onto the gri The periodic test was completed in a satisfactory manner.

. Within the areas inspected, one non-cited violation was identified.

. Licensee Event Report Review (92700)

The inspectors reviewed the LER's listed below to ascertain whether NRC reporting requirements were being met and to determine appropriateness of the corrective action The inspector's review also included followup on implementation of corrective action and review of licensee documentation that all required corrective actions were complete.

• LERs that identify violations of regulations and that meet the criteria o~

10 CFR, Part 2, Appendix C,Section V shall be identified as NCV in the following closeout paragraph NCVs are considered first-time occurrence violations which meet the NRC Enforcement Policy for exemption from issuance of a Notice of Violatio These items are identified to allow for proper evaluations of corrective actions in the event that similar events occur in the futur (Closed) LER 280/88-16, Pressurizer safety valve setpoints outside of allowable limit The issue involved the drifting of the subject valves outside of the two percent operating band during the last cycle of operatio Corrective action included refurbishment and resetting of the lift setpoints to the proper ban The inspector reviewed the LE This issue is further discussed in paragraph 8 of this report. This LER is close.

Action on Previous Inspection Findings (92701) (Closed) IFI 280,281/88-45-01, Followup on weaknesses identified in the licensee's corrective action progra The issues involved repeated wetting of AF'w pump motors during periods of heavy ra i nfa 11, and inadequate evaluation of the failure mechanism of a containment isolation valve during repai The issues were reviewed and determined to be applicable to the enforcement package that was issued to the licensee on May 18, 198 Therefore, corrective actions associated with that package will address the issues identified in this area. This item is close (Closed) IFI 280/89-06-05, Followup on licensee cormnitment to refurbish all 4160 volt safety-related circuit breakers prior to restart. The issue involved verification of completion of the subject co1T111itmen The inspectors have monitored the refurbishment schedule for the past few months and have verified that the 1 icensee has completed the subject action for Unit 1 as of June 19, 198 This item is close (Closed) IFI 280,281/89-13-01, Followup on resolution of pressurizer safety relief valve setpoint drif The issue involved the possibility that the subject valves would drift out of their required TS setpoint tolerance during operatio The inspector dis~ussed the issue with the licensee and determined that a TS change would be submitted to allow for a larger tolerance due to expected drift. The inspector also discussed the technical aspects of the amount of drift that has been experienced to date with Region II and NRR and has concluded that the amount of drift is not a concer This item is close Ex it Interview The inspection scope and findings were surmnarized on July 5, 1989, with those individuals identified by an asterisk in paragraph The following new items were identified by the inspectors during this exit:

,.

One violation was identified (paragraph 6.a) for failure to provide~

adequate procedure to establish initial plant conditions for testing (280/89-20-03).

However, this violation meets NRC Enforcement Policy for not issuing a Notice of Violation and is not cite One IFI was identified (paragraph 5.c) for followup on MCR envelope pressurization improvements (280,281/89-20-0l).

One IF! was identified (paragraph 5.d) for followup on licensee evaluation of maintenance activities associated with the repair of 1-SI-P-lA (280/89-20-02).

The licensee acknowledged the inspection findings with no dissenting comment The l1censee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio.

Index of Acronyms and Initialisms AFW ANSI AP ASME CAD ccw CFR CLS CSD DP!

DR EOG EMP EP ESF EWR HP HPES HPSI IA I FI ISI JCO LER LHSI LOCA MER3 MOV MCR NCV NRC NRR OP PCV AUXILIARY FEEDWATER AMERICAN NATIONAL STANDARDS INSTITUTE ABNORMAL OPERATING PROCEDURE AMERICAN SOCIETY OF MECHANICAL ENGINEERS COMPUTER AIDED DESIGN COMPONENT COOLING WATER CODE OF FEDERAL REGULATIONS CONTAINMENT LOGIC SYSTEM COLD SHUTDOWN DELTA PRESSURE INDICATORS DEVIATION REPORT EMERGENCY DIESEL GENERATOR ELECTRICAL MAINTENANCE PROCEDURE EMERGENCY PROCEDURE ENGINEERED SAFETY FEATURE ENGINEERING WORK REQUEST HEALTH PHYSICS

.

HUMAN PERFORMANCE EVALUATION SYSTEM HIGH PRESSURE SAFETY INJECTION INSTRUMENT AIR INSPECTOR FOLLOWUP ITEM INSERVICE INSPECTION JUSTIFICATION FOR CONTINUED OPERATION LICENSEE EVENT REPORT LOW HEAD SAFETY INJECTION LOSS OF COOLANT ACCIDENT MECHANICAL EQUIPMENT ROOM 3 MOTOR OPERATED VALVE MAIN CONTROL ROOM NON-CITED VIOLATION NUCLEAR REGULATORY COMMISSION NUCLEAR REACTOR REGULATION OPERATING PROCEDURE PRESSURE CONTROL VALVE

'

"

PRA PSI PSIG PT QA RCS RO RPS RWP RWST SCFM SER SG SI SNSOC sov SRO STA SW TS UFSAR URI UV

PROBABILISTIC RISK ANALYSIS POUNDS PER SQUARE INCH POUNDS PER SQUARE INCH GAUGE PERIODIC TEST QUALITY ASSURANCE REACTOR COOLANT SYSTEM REACTOR OPERATOR REACTOR PROTECTION SYSTEM RADIATION WORK PERMIT REFUELING WATER STORAGE TANK STANDARD CUBIC FEET PER MINUTE SAFETY EVALUATION REPORT STEAM GENERATOR SAFETY INJECTION STATION NUCLEAR SAFETY AND OPERATING COMMITTEE SOLENOID OPERATED VALVE SENIOR REACTOR OPERATOR SHIFT TECHNICAL ADVISOR SERVI CE WATER TECHNICAL SPECIFICATIONS UPDATED FINAL SAFETY ANALYSIS REPORT UNRESOLVED ITEM UNDERVOL TAGE