IR 05000286/1990001
| ML20033F783 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/15/1990 |
| From: | Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20033F779 | List: |
| References | |
| 50-286-90-01, 50-286-90-1, NUDOCS 9004030057 | |
| Download: ML20033F783 (14) | |
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U. S. NUCLEAR REGULATORY COMMISSION Region I
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Report No.:
50-286/90-01
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i Docket No.:
50-286 Licensee:
New York Power Authority
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1633 Broadway L
New York, New York 10019 Facility:
Indian Point Nuclear Power Plant, Unit 3
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Location:
Buchanan, New York
Dates:
January 9,1990 to February 26, 1990 r
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Inspectors:
L. Rossbach, Senior Resident Inspector
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G. Hunegs, Reside nspector
Approved by:
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V 3-/$MO -
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/DiennW.Meyer, Chief f
Date
Reactor Projects Sectio vNo. IB (
Areas Inspected: This inspection report discusses routine and reactive inspec-I tions of plant activities in the following areas:
operations; radiological v
controls; maintenance / surveillance; security; engineering / technical suppor;;
safety assessment / assurance of quality.
This period included weekend and holiday inspections on February 12, 24 and 25,1990.
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Results:
The plant operated at 100% power throughout the inspection period.
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Inspection results are summarized in the attached executive summary, including
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a violation for failure to follow alarm response procedures and two unresolved items.
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9004030057 900320 PDR ADOCK 05000286 Q
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Executive Summary
Operations:
Operators failed to follow or change an alarm response procedure, and abnormal plant conditions were not being properly logged.
This resulted in a violation. Although site management appeared to have a proper philosophy of procedure adherence, these findings indicated that the staff has not fully adopted that policy. The inspector reviewed spent fuel pool rerack activities, an isolation of a fire sprinkler header, and a diesel breaker problem and found them to be acceptable.
Radiological Controls:
NYPA was properly implementing their radiological pro-tection program. A violation of high radiation area access requirements was previously withdrawn by NRC and is closed in this report.
Maintenance and Surveillance:
The activities reviewed were effective in meet-ing the safety objectives of the programs.
Security:
Informal communications and a lack of specific guidance contributed to a lost access badge not being properly voided.
This event was reported to NRC, and the inspector discussed it with Region I security specialists.
The event will be reviewed as an unresolved item. The fitness-for-duty training program was inspected in, accordance with NRC Temporary Instruction 2515/104.
Based on a vital area boundary concern, security took prompt but ineffective corrective action. The corrective action was improved later.
Engineering and Technical Support:
Licensee Event Reports were reviewed and found to T>e properly evaluated and reported. The component cooling weter (CCW)
heat exchanger tube plugging limit safety evaluation was reviewed after several CCW heat exchanger tubes were plugged. The evaluation provided adequate justi-fication for the tube plugging limit.
The technical support staff did a thorough review of the failure of a diesel breaker to close.
Some questions remained related to the auto start of the steam-driven auxiliary feedwater pump under blackout conditions and will be reviewed as an unresolved item.
Safety Assessment / Quality Verification:
The inspector concluded that greater attention needs to be placed on verifying that the operating staff is following NYPA's procedure policie )
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DETAILS 1.
Summary of Facility Activities The unit operated at 100% power throughout this inspection period with the exception of minor power reductions for maintenance and testing.
Tube leaks developed in a component cooling water heat exchanger; nine tubes were subsequently plugged.
Physical work on the spent fuel pool rerack modification was begun, 2.
Operations (71707,71710)
2.1 Safety System Review Using the Probabilistic Risk Analysis (PRA) inspection guidance pro-vided by the Indian Point Unit 3 PRA Inspection Guidance Appendix, and applicable drawings and checkoff lists, the inspectors performed a system walkdown on the following systems.
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Component Cooling Water
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All systems were properly aligned for the existing plant conditions.
2.2 Control Room Observations At approximately 10:00 a.m. on January 31, the inspector saw that the service water header 31, 32, 33 high pressure alarm was lit on panel SJF in the control room. Service water pumps 31 and 32 were running.
Alarm response procedure (ARP) 12, Revision 14, requires that one of the pumps be removed from service if a high pressure condition exists. This high pressure condition had existed since the previous evening.
Failure to follow the ARP or prepare a temporary procedure change is a violation (VIO 90-01-01). A second example of apparent procedural noncompliance is discussed later in this section.
The high pressure alarm could potentially indicate a low flow condi-tion under which the pumps could degrade.
The operators and shift supervisor had decided that it was not necessary to secure a pump as long as they had adequate flow rate. They had verified that the flow rate was 3000 gpm and believed that this was adequate. The inspector asked the technical services superintendent if he had any technical
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concerns with operating two service water pumps under these condi-tions. Technical services determined that both pumps could remain in service as long as pump vibretions were satisfactory whenever flow is below 2500 gpm. One pump was secured at 11:20 a.m. at the direction of plant management while this evaluation was being completed.
The operations department then prepared and issued temporary procedure change (TPC) 90-20-0P which incorporated these flow and vibration criteria into ARP-12. The inspector concluded that although the pump operation under the alarmed condition was later determined to be technically acceptable, it was unacceptable to operate in this condi-tion without a technical evaluation.
The pressure in service water header 31, 32, 33 was logged above the alarm setpoint beginning at 8:00 p.m. on January 30. The high pres-sure condition was not circled on the control room log sheets or explained in the log remarks section for the 3 to 11 and 11 to 7 shifts. The inspector concluded that it has become accepted practice for operators to not indicate that parameters logged are out of their normal range.
For example, the control room log sheet for January 30,1990 had 35 readings out of normal range, and none of them were circled or explained.
Similar omissions occurred in all loas reviewed by the inspector.
The control room shift relief and turnover checklists (00-6, Attachment 1) for the 3 to 11 and 11 to 7 shifts also did not mention or explain the high service water header pressure condition.
The control room log sheets and the turnover checklist are reviewed and initialed by supervisors, wnich indicates that supervision accepts these practices. The overpressure condition was not discussed in the SRO or shift supervisor's logs before the inspector's involvement.
Also, on January 30, an apparent leak developed in the component cooling water (CCW) heat exchanger. This is discussed in more detail below and in section 6.
The apparent CCW 1eak was not discussed in the SRO or shift supervisor's logs until troubleshooting work was underway three shif ts af ter abnormal condi-tions indicated the onset of the leak. The above practices are vio-lations of NYPA's logkeeping procedures and are the second example of procedural noncompliance.
(VIO 90-01-01)
Our Inspection Report 89-25 discussed previous example of not logging degraded equipment with the potential to affect plant operations.
NYPA management expressed their commitment to following procedures during several discussions with the inspector. Although site manage-ment appeared to have a proper philosophy of procedure adherence, the staff had not implemented that policy in the above instances.
The inspector noted that this event was not an isolated error by a single operator, since several shifts failed to respond properly to the alarm and maintain logs, i
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f NYPA finished the monthly CCW pump functional test (PT-M-46) at i
11:00 a.m.
on January 30.
At 1:00 p.m., the non-licensed operator (NPO) added water to the CCW surge tanks due to low level. Water had previously been added on January 25. At 4:10 p.m. on January 30 and 12:20 a.m.
on January 31, water was again added.
Troubleshooting
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operations and engineering evaluations performed on January 31 deter-
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mined that there was a 7 1/2 gpm leak fr 32 CCW heat exchanger. NYPA entered a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limiting condition for operation (LCO) the evening
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of January 31 to repair the heat exchanger. Nine tubes were plugged.
The tube plugging limit safety evaluation is discussed in Section 6 of this report.
The heat exchanger was returned to service on
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February 1.
2.3 Spent Fuel Pool Activities
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The inspector observed the transfer of spent fuel assemblies in pre-paration for the spent fuel pool rerack modification. The spent fuel
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pool (SFP) contained 432 fuel assemblies and eight additional
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objects.
During six sequences, all items will be transferred from the current SFP racks to new U.S. Tool and Die maximum density racks.
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The inspector verified that initial conditions, precautions and Tech-nical Specification limitations had been met. The movement of spent fuel was performed in accordance with TPC-61, " Spent Fuel Movement for Maximum Density Spent Fuel Pool Rerack."
The inspector noted
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that procedures were in use and good radiological centrols super-i visory, oversight was evident.
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From February 6-9, a Region I specialist conducted an inspection of
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the spent fuel pool rerack modification.
The results are included
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in Inspection Report 90-02.
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2.4 Fire Protection
The inspector reviewed operating order No.
001098 issued on December 25, 1989, which isolated the containment access facility deluge sprinkler header. The insoector verified by walking down that portion of the system, review of Technical Specifications, and review of Appendix R requirements that there were no adverse operationc1 impacts due to that portion of the deluge header being inoperable by automatic means.
The system status was noted on the shift super-visor's turnover sheet, and the fire protection supervisor was aware of the problem. The header protects an area which is surrounded by a three hour barrier.
No safety re'ated equipment is located in the
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area, and if necessary the system could have been manually operated.
The inspector concluded that NYPA had properly controlled the isola-tion of the sprinkler header.
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2.5 Inability to Close Emergency Diesel Generator Output Breaker During A
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Surveillance Test
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On February 3, the 32 emergency diesel generator (EDG) was started t
for the performance of surveillance test 3PT-V16, EDG functional test. When the operator attempted to synchronize 32 EDG to 480V bus
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6A, the output breaker did not close. A second attempt also failed
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to close the breaker. The shif t supervisor (SS) and operator removed and checked the continuity of the breaker control power fuses and the fuses tested satisfactorily. When the control power fuses were rein-stalled, the SS and operator heard a noise and saw a flash. This was later attributed to the fact that the breaker had cycled.
Control room operators also noted that the turbine driven auxiliary boiler feed pump had started.
This is further discussed in Section 0,3.
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Working under WR 1233. I&C personnel found no problems in the exter-nal control circuitry. Working under WR 20646, maintenance personnel performed preventive maintenance (PM) on the generator and breaker.
The generator tested satisfactory. During the breaker PM, 3 control wires were found crushed between the breaker frame and cover.
One of the 3 wires was the positive control power supply to the breaker closing coil and anti pump relay coil.
A magnifying glass
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examination detected no through holes in the insulation, but clear
impressions of the underlying conductors were visible.
The suspect wires were covered in shrink wrap. Blackening of the are chutes and pitting and melting of the breaker main contacts attested to the fact that the breaker had cycled under an overload condition. The breaker retested satisfactory on February 4, and the EDG was returned to ser-vice.
On February 7, the breaker was replaced with a space. At that time, the cause of the breaker failure had not been identified.
Later, NYPA's operating experience review group (OERG) conducted an extensive evaluation of the event.
Their conclusion was that the
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crushed wires created a ground which kept the anti pump relay coil energized and prevented the breaker from operating properly.
January 10 was the last time the breaker was tested and was found to be operable. There had been no operation of the breaker in between the tests.
The inspector concluded that NYPA evaluations and corrective actions
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were acceptable and will review the NYPA conclusions documented in i
the LER to be issued.
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3.
Radiological Controls (71707, 92701)
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3.1 NYPA's implementation of the radiological protection program was observed during periodic plant tours. The inspector also accompanied NYPA engineering staff during a containment entry at power.
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engineers were taking measurements for modifications planned for the
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next outage.
The radiological control activities inspected were
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effective in meeting the objectives of the radiological protection program.
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3.2 (Closed) Violation (50-286/89-04-01)
The violation was that workers were allowed to enter high radiation l
areas without the proper radiation monitoring devices or the proper
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radiological control technician escort as described in Technical
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Specification (TS) 6.12, High Radiation Area.
In their May 30, 1989 response to the violation, NYPA disagreed with
the violation because they felt that their program met the TS requirements. On August 3,1989, a meeting was held with NYPA and
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the NRC to discuss the violation and other health physics issues.
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Based on the results of the meeting, NRC determined that NYpA's pro-gram to control high radiation area access was acceptable and that no violation existed. On September 20, 1989, the NRC issued a letter to
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NYPA withdrawing the violation and informing NYPA that no change was required in their program to control high radiation area entries.
3.3 The insisector attended NYPA's self-monitoring training course.
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classroom instruction was very thorough. The practical factors por-tion of the course could be enhanced through the use of mockups and radiation monitoring training instruments.
The inspector communi-l cated these suggestions to training personnel, who agreed to review them.
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4.
Maintenance and Surveillance (62703, 61726)
NYPA's compliance with the maintenance and surveillance program was evalu-
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ated by observing selected activities and reviewing selected work pack-ages.
The inspector verified that the activities were conducted in ac-cordance with approved procedures Technical Specifications, and approved t
industrial codes and standards. The following activities were reviewed or witnessed by the inspectors.
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WR 20414 - Install new jacket water pump on 31 EDG
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WR 19927 - 31 EDG quarterly, semi, and annual PM
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Calibrations 1272, 2201, and 2341 - 31 EDG lube oil press, jacket
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water press, start air press indicator calibrations.
This was the first time new I&C calibration procedures were used. The procedures appeared to be well written and technicians followed them.
3PT M-62 - 480V UV and Degraded Grid Test
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3PT SA-18 - Fire Hydrant inspection
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3PT Q-1 - Station Battery Surveillance and Charging
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3PT-M-46 - Component Cooling Pump Functional Test
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The above activities were effective with respect to meeting the safety objectives of the programs.
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5.
Security (71707)
5.1 On February 6, NYPA determined that a lost access badge could have allowed unauthorized access to the control area for approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. A review of computer records showed that there were no trans-
actions while the badge was unaccounted.
The event was reported to the NRC in accordance with 10 CFR 73 Appendix G, paragraph 1(c), and the inspector discussed it with Region I security specialists.
On February 5 at 12:30 p.m., a NYPA engineer had been escorted to the access control point where he reported to a security officer that he had lost his badge. The security officer notified the badge issuing security officer, who in turn told the central alarm station operator to void the badgo. Apparently, the message was not understood and the badge was not voided. There was no written record and the super-
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visor was not informed, contrary to post instructions. At 1:49 a.m.
on February 6 during a daily audit the badge was identified as miss-ing and was appropriately voided.
This event was logged.
The event was revealed to security management when the engineer returned to the plant at 2:00 p.m. on February 6,1990 and requested a new badge.
Subsequent to the event, NYPA prepared a lost badge form and developed implementing procedures for the form. The inspector con-cluded that informal verbal communication and lack of specific guid-ance contributed to this event and that immediate corrective actions were acceptable.
This incident represents an unresolved item (UNR 90-01-02), pending NRC review of the LER to be issued and long-term corrective actions.
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5.2 Fitness for Duty Training (Temporary Instruction 2515/104)
Fitness for Duty (FFD) programs, as described in 10 CFR 26, are required to be implemented by January 3, 1990.
The inspectors observed FFD training sessions and provided NRC with the information requested by Temporary Instruction 2515/104.
The inspector also toured NYPA's specimen collection facility and observed-the process of selection of participants and specimen col-o lection.
The inspector noted that procedures were implemented to ensure an unadulterated sample was collected such as:
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Blue dye was used in toilet tanks.
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Access to water was restricted.
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Specimen containers were sealed and locked prior to use.
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Identifying information was maintained in a log.
In addition, the facility was clean and was provided with lockers and a waiting lounge. The inspector concluded that NYPA implemented its fitness for duty program adequately.
5.3 An inspection of the emergency diesel fuel oil system by a region based inspector was begun during this inspection period and will be reported under Inspection Report 90-04. On February 22 that inspec-tor questioned if a vital area boundary met the requirements of the security plan. On February 26, the inspector determined that secur-ity was not aware that concerns had been raised the previous week and consequently had not provided any additional protection.
NYPA attempted to provide additional protection for the area in question on February 26 following the inspector's discussion with security
management. This protection was ineffective, however, because it was
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not applied correctly.
This problem went undetected by security supervision and repeated security force checks until March I when the inspector identified the error.
The protection was then applied correctly.
5.4 The inspector walked down the protected area and vital area barriers. No discrepancies were identified.
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6.
Engineering and Technical Support (71707)
6.1 Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities The inspector reviewed the following LERs. to verify that the reports met the requirements of 10 CFR 50.73. The inspector determined that the LER text was sufficiently detailed and accurate and that adequate cause determination and corrective actions were adequate or in progress.
LER 89-14 - Crosswiring of Steam Generator (SG) Pressure Transmitters On October 21, 1989 during the replacement of SG pressure amplifiers, Instrumentation and Control (I&C) technicians found that Nos. 31 and 33 SG channel 2 transmitter outputs were crosswired. The error was attributed to an incorrect modification drawing and poor communica-tions during modification retest.
LER 89-15 - Manual Reactor Trip initiated when 12 control rods fully inserted.
On October 19, 1989, with the plant at 100% power, control room oper-ators inserted a trip when they observed 12 control rods fully inserted into the core.
At the time of the trip, I&C technicians were perfonning 3PT-M-62, 480V Vndervoltage and Degraded Grid Sur-ve111ance Test, which caused the 12 control rods to drop.
Since separate and independent verification of proper operability of hard-ware was performed subsequent to the event, NYPA concluded that personnel error was the cause.
These events are discussed further in NRC Inspection Report 69-22, 6.2 The 32 CCW heat exchanger was taken out of service to repair a leak as discussed in section 2.2.
Nine tubes were plugged, bringing the total to 13 tubes plugged.
Safety evaluation NSE-89-3-248 estab-lished a plugging limit of 17 tubes which is 1% of the tubes. This evaluation was based upon analyses done to support a technical spec-ification amendment-request to increase the ultimate heat sink tem-perature to 95 degrees F.
The evaluation concluded that plugging 17 tubes in each CCW heat exchanger will not create an unreviewed safety question.
The inspector concluded that evaluation NSE-89-3-248 was adequate to support the plugging limit of 17 tube :
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ing a surveillance test on February 3,1990.
Engineering reviewed the event along with maintenance and I&C.
On February 5, the OERG l
began a followup evaluation of this event.
The evaluation was very
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thorough and concluded that the breaker opened because the anti pump relay coil was energized through a ground and a crushed anti pump l
relay power supply wire. Corrective act.ons included QA checks and
preventive maintenance procedure changes to ensure that no wires are
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caught behind the breaker front panel when it is moved during future
breaker PMs.
Improved DC ground fault tracing equipment is being purchased.
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i The automatic start of the steam-driven auxiliary feedwater pump (32 AFW pump) during troubleshooting operations was determined to be pro-per because when the EDG breaker closed, it completed the non-SI blackout logic for bus 6A loads. The motor-driven bus 6A loads did
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not start because the EDG breaker reopened before the load sequencer (timer) gave a start signal.
In reviewing the 32 AFW pump non-SI blackout start logic, the inspector noticed that the start logic requires that bus 6A be energized. The inspector questioned why the blackout start of the steam driven AFW pump should be inhibited by a
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blackcut (deenergized bus).
The background document for emergency
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operating procedure (EOP) ECA-0.0 and the system description assume that this pump will start automatically on loss of all AC power.
NYPA is reviewing this issue, but noted that the low steam generator
water level automatic start and the manual start signals are not inhibited by loss of AC power, and that these signals would initiate the 32 AFW pump under blackout conditions. The acceptability of this design represents an unresolved item (UNR 90-01-03), pending NYPA determinations and NRC review.
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Safety Assessment / Quality Verification
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Several examples of failure to follow procedures were identified as dis-cussed in Section 2.2.
Adherence to p'rocedure issues have been raised in previous inspections and were resolved at the management level by adopting a policy of procedure compliance. Based on this inspection, the inspector concluded that the NYPA operating staff has not fully implemented that policy. Greater attention needs to be pieced on verifying that the staff is following NYPA's procedure policies.
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ManagementMeetings(30703)
At periodic intervals during the course of the inspection, meetings were held with senior facility management to discuss the inspection scope and findings. An exit interview was held on February 26, 1990 to discuss the findings and conclusions of this report period.
During the discussion, the licensee did not identify any 10 CFR 2.790 materia T
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U.S. NUCLEAR REGULATORY COMMISSION r
Principal Inspector:
Rossbach, Lawrence
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Reviewer:
INSPECTOR'S REPORT t
Office of Inspection and Enforcement
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Inspectors:
Transaction Type Dockets / Inspect #s/Seo#s
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hossbach, Lawrence I - Insert Oy00286 90-01
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Hunegs, Gordon M - Modify g
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Licensee / Vendor:
MAR 2 01990 New York Power Authority
P. O. Box 215 Buchanan, New York 10511 Period of Inspection:
Inspection Performed By:
Organization Code of From To Region:
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2/9/90 2/26/90 1 - Regional Office Staff Region Division Branch
- 2 - Resident Inspectors
B B
3 - Performance Appr. Team
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4 - Other Regional Action:
Type of Activity Conducted (* one only):
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1 - NRC Form 591
- 02-Safety 07-Special 12-Shipment / Export
- 2 - Reg. Ltr.
03-Incident 08-Vendor 13-Import
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04-Enforcement 09-Mat. Acet 14-Inquiry 05-Mgmt. Audit 10-Plant Sec.15-Investigation 06-Mgmt. Visit 11-Invent. Ver.
Inspection Findings:
Total No. of Enforcement Report Contains
Violations Conf. Held 2.790 Information ABCD A-1 - Clear B-t X
2 - Violations C-3 - Deviation D-4 - Viol. & Dev.
Letter of Report Transmittal Date
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C Letter Issued:
Letter or Report Transmittal Date Sent to HQ for Action:
Mod. No. Mod. Hrs. Status Mod. No. Mod. Hrs.
Status Mod. Req. Followup n
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571707 150 100%
C 530703 007 100% C 571710 014 100%
C 255104 005 562703 017 100%
C 592701 014 561726 032 100%
C Docket No. 50-286 Module No. 71707 Report No.
90-01 Violation Severity IV A.
Technical Specification 6.8.1 requires that procedures be established and impicmented for the procedures in Appendix A of Regulatory Guide 1.33.
Sections A and E.of Appendix A include procedures for procedure adherence, temporary procedure changes, shif t turnover, log entries, and for correcting alarm conditions. Administrative Procedure AP-4 requires that procedures be followed and that temporary procedure changes be implemented when an approved procedure cannot be followed. Alarm response procedure ARP-12 part 22 requires that if a high pressure condition exists in service water header 31, 32, 33 the operator is to remove one service water pump from service if more than one is in service. Operations directive OD-6 includes a shift relief and turnover checklist which requires that abnormal conditions on the control room panels be corrected or explained on the checklist. Operations directive OD-5 requires that log sheet entries that exceed normal limits be circled-and explained in the remarks section. 00-5 also requires that log book entries be made of significant operations, problems, abnormal indications or conditions.
1.
Contrary to the above, on January 30 and 31, 1990 when high pressure
'in service water header 31, 32, 33 was alarmed, the second service water pump was not secured nor was a temporary procedure change prepared to allow continued operation of two pumps.
2.
Contrary to the above, on the 3-11 shift on January 30 and the 11-7 shift on January 31, service water header 31, 32, 33 high pressure was not explained on the shift relief and turnover checklist, nor was this or any other abnormal condition circled and explained on the control room log sheets, nor was this condition and the component cooling water system leakage discussed in the senior reactor operator or shift supervisor's logs.
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Collectively, these items constitute a Severity Level IV Violation (Supplement 1).
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OUTSTANDING ITEMS FILE SINGLE DOCKET ENTRY FORM Transaction Type 1. Operations 144 7. Eng/ Tech. Spt 15 2. Rad-Con 11 8. SA/ Qual Verif M _,
2 New Item 3. Maintenance /
9. Outages Modify 4. Surveillance _49_
10. Fire Prot /Hskpg m_ Delete S. Emerg, Prep 6.Sec/SafeGrdsJ Docket Number 50-286 90-01 Rossbach
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Originator Reviewing Supervisor
_ Item # Type Salp Area Area Act. Due Date Updt/Close.Rpt# Date 0/M/Cisd 90-01-01 NC4 Operations 2/26/90 Originator Resp Sec
.Rossbach DRp Description:
Failure to follow alarm response procedure and logkeeping requirements.
Item # Type Salp Area Area Act. Due Date Updt/Close.Rpt# Date 0/M/Cisd 90-01-02 UNR 2/26/90 Originator Resp Sec Rossbach Sec Description:
Lost badge incident on 2/6; did not void access Item # Type Salp Area Area Act. Due Date Updt/Close.Rpt# Date 0/M/Cisd 90-01-03 UNR Originator Resp Sec Rossbach DRP Description: Lack of loss of AC start on 32 AFV pump i