IR 05000316/2004011

Insp Rept 50-416/85-09 on 850316-0411.Violations Noted: Steps in Sp 06-EL-1E31-M-0001 Performed Out of Sequence Resulting in ESF Containment Isolation Valve Actuation & Causing Isolation of RCIC Sys

ML20127F096
Person / Time
Site:	Grand Gulf, Cook
Issue date:	04/24/1985
From:	Butcher R, Caldwell J, Panciera V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127F035	List: IR 05000316/2004011 ML20127F032 ML20127F042
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-2.K.3.28, TASK-TM 50-416-85-09, 50-416-85-9, NUDOCS 8505200319
Download: ML20127F096 (10)

Text

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p IET UNITED STATES

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o NUCLEAR REGULATORY COMMISSION

[ p REGloN ll y j 101 MARIETTA STREET, * 's ATLANTA, GEORGI A 30323

'+9 . . . . . ,o Report No.: 50-416/85-09 Licensee: Mississippi Power and Light Company Jackson, MS 39205 Docket No.: 50-416 License No.: NPF-29 Facility Name: Grand Gulf Inspection Conducted: March 16 - April 11, 1985 Inspectors: WY/r ^//*23/85 R. C. Butcher, Senior Kesident4nspetitor Date Signed * *

f . Cald AnAA A Resident Inspecif6r /

Wz3/8s Date Signed Approved by: .[I A w fAf y V. W.'Panc'idra, Chief, Project Section 2B

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Da'te 5'igned Division of Reactor Projects SUMMARY Scope: This routine inspection entailed 210 inspector-hours at the site in the areas of Operational Safety Verification, Maintenance Observation, Surveillance Observation, Engineered Safety Feature (ESF) System Walkdown, Reportable Occurrences, Operating Reactor Events, TMI action Items, Startup Testing, Design Changes and Modifications, and Independent Inspectio Results: Of the ten areas inspected, no apparent violations or deviations were identified'in nine areas; two apparent violations were found in one are PDR ADOCK 05000416 G PDR

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' REPORT DETAILS ' Persons Contacted

" Licensee Employees

'J.4E. Cross, General Manager

• C. R. Hutchinson,' Manager, Plant Maintenance

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R.'F. Rogers', General Manager-Technical Assistant

• J.'D. Bailey, Compliance Coordinator l'M. J. Wright, Manager, Plant Operations i t. -F. : Daughtery,- Compliance Superintendent

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D. Cupstid, Start-up Supervisor ' -

R. H. McAnulty, Electrical Superintendent

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'R. V. Moomaw, I&C. Superintendent f *

B.. Harris, Compliance Coordinator

.0ther licensee employees contacted included technicians, operators, security

force members, and office personne * Attended exit interview 1 Exit Interview

- The inspection scope .and findings were summarized on April 11, 1985, with E those persons. indicated in paragraph 1'above. The licensee did not identify as proprietary any of the materials provided to or. reviewed by the

-_ inspectors during this inspection'. The licensee had no comment on the

.following inspection ~ findings: Violation (50-416/85-09-01), Inadequate procedure when ~ placing batteries on equalize (paragraph 5). ~ Inspector Followup Item (50-416/85-09-02), update class IE direct current power system procedures (paragraph 7). Inspector Followup Item (50-416/85-09-03), Discrepancy in Final Safety Analysis Report description of standby power. supply. initiation logic (paragraph 11).

, Inspector Followup Item (50-416/85-09-04), part 21 report on TDI diesel generator air start check valves failure (paragraph 11).

~ Inspector Followup Item (50-416/85-09-06), Design change to prevent-scram on precoat filter isolations (paragraph 10).

Inspector Followup Item (50-416/85-09-06),-Part 21 report on Main Steam Isolation Valves (MSIVs) failure to remain closed (paragraph 14).

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g; Violation (50-416/85-09-07), Failure to follow procedure, by performing steps out of . sequence resulting in an actuation of an ESF' Containment

. isolation valve (paragraph 5). . Licensee Action on Previous Enforcement Matters LThis subject was not addressed in-the. inspectio . Unresol'ved Items Unresolved Items were not identified during this inspectio . Operational Safety Verification (71707)

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The : inspectors kept themselves informed on a daily basis of the overall-plant status and any significant safety matters related to plant operation Daily discussions were held with plant management and various members of the plant operating staf The Einspector made frequent visits to the control room such that it was visited . at least daily when an inspector was on recordings status -. of operating systems; tags and clearances on equipment controls and switches;

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Lannunciator alarms; adherence to limiting conditions for operation; temporary alterations in effect; daily journals and data sheet entries; control room manning; and access controls. -This inspection activity

. included numerous informal discussion with operators and their supervisor Weekly, when onsite, a . selected ESF system is confirmed operable. The confirmation is made by verifying the following: Accessible valve flow path alignment; power supply breaker and fuse' status; major component leakage,

' lubrication, cooling and general condition; and instrumentatio '"

General plant tours were conducted on at least a biweekly basis. Portions of the control building, turbine building, auxiliary building and outside areas were visited. Observations -included safety related tagout verifica-tions; ' shift turnover; sampling. program; housekeeping and general plant conditions; fire protection equipment; control of activities in progress; radiation - protection controls; physical' security; problem identification systems; and containment isolatio _ At 9:18 ' a.m. CST, on February 23, 1985, with the unit in cold shutdown, technicians were -placing the Division 2 -battery chargers on equalize per surveillance procedure 06-EL-1L 1-0-0001, to charge the battery banks :in preparation for a battery' discharge tes The chargers are adjusted by-turning a potentiometer until voltage of approximately 140 VOC is observe One charger had.been adjusted to 140 VDC and while adjusting the second charger l the inverter tripped, technicians returned the equalizing voltage back to =the normal float valve of 132 VDC. The inverter automatically reset and restored power. A relay powered from the inverter energized before the level instrumentation could recover causing the ESF systems to initiate on an erroneous reactor low water level signal. The ESF actuation raised the i

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vessel level from 83 inches to approximately 120 inches. All systems were returned to normal. A permanent design change is being pursued to prevent inadvertent ESF initiations following the loss of power to the instrument As an interim corrective action the licensee is revising applicable procedures to require only'one charger be used when equalizing to minimize the probability of recurrence. Actuation of the ESF system when placing the Division 2 batteries on equalize was the result of an inadequate procedure and is a Violation (50-416/85-09-01).

On April 4, 1985, with the plant operating at 47.5% power, the Reactor Core Isolation Cooling (RCIC) System Steam Supply line inadvertently isolate Plant personnel were performing surveillance procedure 06-EL-1E31-M-001, RCIC Main Steam Tunnel Isolation Delay Timer Channel Functional Test and Calibration, at the time of the isolation. It was determined that step 5.3.9, which returned the RCIC Isolation Bypass Test Switch to the normal position, was performed prior to the completion of steps 5.3.7 and 5. which opened and removed the test switch installed by the surveillance procedur Since the bypass switch was returned to normal prior to opening and removing the test switch, the RCIC steam supply containment isolation valve received a false isolation signal. The performance of steps 5.3.7, 5.3.8 and 5.3.9 out of sequence, which resulted in an ESF containment isolation valve actuation, will be identified as a Violation (50-416/85-09-07), failure to follow procedur . Maintenance Observation (62703)

During the report period, the inspector observed selected maintenance activities. The observations included a review of the work documents for adequacy, adherence to procedure, proper tagouts, adherence to Technical Specification, radiological controls, observation of all or part of the actual work and/or retesting in progress, specified retest requirements, and adherence to the appropriate quality control In the areas inspection, no violations or deviations were identifie . Surveillance Testing Observation (61726)

The inspector observed the performance of selected surveillances. The observation included a review of the procedure for technical adequacy, conformance to Technical Specifications, verification of test instrument calibration, observation of all or part of the actual surveillances, removal frem service and return to service of the system or components affected, and review of the data for acceptability based upon the acceptance criteri The inspector reviewed the licensee's class IE direct current power system; the following documents were reviewe EL-1L11-W-001, Rev. 23 Surveillance procedure 125 volt Battery Bank Ptiot Cell Chec _

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06-EL-1L11-Q-001, Rev. 24 Surveillance procedure,125 volt Battery Bank All Cell Check e

06-EL-1L11-R-001, Rev. 22 Surveillance procedure, 125 volt Battery Bank Physical Condition Check 06-EL-1L51-R-001, Rev. 21 Surveillance procedure, 125 volt Battery-1A3, 183, IC3 Capacity Discharge Test 06-EL-1L21-0-001, Rev. 22 Surveillance procedure, Battery 1A3, 1B3, IC3 Capacity Discharge Tes C & D Batteries Division Eltra Installation and Operating Instructions

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Cor for Stationary Batteries C & D Auto Reg. Charger Eltra Installation and Operating Instruction Cor Manua The Inspector found the following discrepancies: The criteria in procedure 06-EL-1L21-0-001 is incomplete. Technical Specification (TS) 4.8.2.1.f. in part; requires an annual capacity discharge test if any battery has reached 85% of the service life expected for the application or if capacity drops more than 10% of rated capacity from its average on previous performance tests. These criteria are not imposed in this or any other procedur Procedure 06-EL-1L11-0-001 has a statement that the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> equalizing charge may be omitted if maintenance engineering has determined that an equalizing charge is not needed at this time. The procedure does not reference the corrective action guidelines of paragraph 3.4 of IEEE Std. 450-1975 which defines criteria for when an equalizing charge is required. The statement was just recently added to the procedure and the licensee has routinely been accomplishing the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> equalizing charge every quarte The licensee is revising their procedures to correct the above discrepancies. This will be tracked as an Inspector Followup Item (50-416/85-09-02).

8. ESF System Walkdown (71710)

A complete walkdown was conducted on the accessible portions of the walkdown consisted of an inspection and verification, where possible, of the required system valve alignment, including valve power available and valve locking, where required; instrumentation valved in and functioning;- electrical and instrumentation cabinets free from debris, loose materials, jumpers and evidence of rodents; and system free from other degrading condition In the areas inspected, no violations or deviations were identifie c ,

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5 Reportable Occurrences (90712 & 92700)

The below listed Licensee Event Reports (LERs) were reviewed to determine if the information provided met NRC reporting requirements. The determination included adequacy . of event description and corrective action taken or-planned . existence of potential generic problems, and the relative safety significance of each event. Additional inplant reviews and discussions with plant. personnel, as appropriate, were conducted for the reports indicated by an asterisk. The LERs were reviewed using the guidance of the general policy and procedure for NRC enforcement action The following LERs are close LER N Report Date Event

• 85-009 March 15, 1985 Inadvertent Emergency Core Cooling System (ECCS) actuation and reactor scram while shutdow December.20, 1984 Chemistry surveillances on effluent cumulative dose calculations performed one day lat March 7, 1985 Spurious Residual Heat Removal (RHR) equipment area high temperature signal surveillance not performed 85-005 February 28, 1985 Surveillance not performed within time limit 85-061 January 28, 1985 Fire watch not performed due to disabled doo December 3, 1984 Reactor Core Isolation Cooling (RCIC) isolation on high steam flow signa November 28, 1983 Division II diesel generator fuel oil lea The event of LER 85-009 was discussed in Inspection Report 85-06 and is being tracked as violation 50-416/85-06-01. Similar events of LER 84-051 was discussed in Inspection Report 85-03 and licensee actions are being tracked as inspector followup item 50-416/85-03-0 LER 84-45 and LER 85-008 both remain open. Both LERs address a problem with the precoat filters isolating and resulting in a reactor scram on loss of instrument air. LER 84-45 was previously discussed in report 84-49 as part of scram No. 8. The event of LER 85-008 is discussed in paragraph 10 of this report in scram number 2 In the areas inspected, no violations or deviations were identifie _ _ _ _ _ . . . . _ _ . . _

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j 10. Operating Reactor Events (93702) -

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The inspectors reviewed activities associated with the below listed reactor 8:

scrams. The review included determination of cause, safety significance, _-

performance of personnel and system, and corrective action. The inspectors -

examined instrument recordings, computer printouts, operations journal

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entries, scram reports and had discussions with operations maintenance and E engineering support personnel as appropriat ii

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Scram No. 20

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On February 13, 1985, at 5:00 p.m., the plant was operating at 16% power and  ;

operators were venting the turbire building cooling water (TBCW) system i because of air in the system. The instrument air compressor tripped on low r cooling water pressure caused by the venting of the TBCW system. Approxi- .

mately three minutes later, the condensate precoat filters isolated due to low instrument air pressure which resulted in isolating condensate flo The precoat filter bypass valve did not open fast enough to prevent a trip  ;

of all operating condensate pumps, the condensate booster pumps and sub- li sequently, the reactor feed pumps. RCIC was manually initiated when reactor vessel water level reached + 20 inches. Reactor water level decreased below the scram setpoint (+11.4 inches) to approximately - 25 inches. The main -

turbine was manually tripped and reactor water level was restored to + 30 T inches. All safety systems performed as designe a The slow response of the bypass valve on a loss of air pressure was E previously addressed in LER 84-045 where the loss of instrument air resulted in a loss of the condensate feed syste The licensee has initiated a j design change request to modify the system such that the loss of instrument  ;

air will not result in a scram when the precoat filters isolat The licensee has taken some interim actions such as stationing an operator at J the bypass valve during startup when the precoat filters are in service, and =j is preparing guidance to specify the operational parameters of the i

, condensate precoat filter The licensee's corrective actions will be tracked as an Inspector Followup Item (50-416/85-09-05). _-

l 1 Independent Inspection (92706) -

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On March 11, 1985, during operational testing of Division 1 Diesel Generator '

(DG), the licensee noticed flames coming out of a flexible coupling on the

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air start header assembly. The engine was shutdown and the number 6 right -

bank air start valve was removed. A 3/8-inch diameter, 7/8-inch long non-magnetic metal piece was observed lying on top of the piston. Further _

examination by the licensee showed this piece broke off of a starting air _

check valve disc and was caught in the air start valve causing the flames -

seen coming out of the flexible coupling of the air start header assembl There are four of these check valves on each DG. The check valves were ,

supplied by the Williams Gauge Co. (Williams - Hager) of Pittsburgh, PA and "

were installed on the DG by Transamerica Delaval. The check valves at Grand i

Gulf had the CLOW CORP name and model number 329-SBSSM-300 on their

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l identification tag. The licensse replaced the disc in all four check valves on both Division 1 and Division 2 DGs with new discs. The Division 3 DG is not affecte On March 12, 1985, Transamerica Delaval Inc. (TDI) submitted a 10 CFR Part 21 report of the potential defect in the TDI DGs and listed the sites were TDI has supplied DGs with the same potential defect. The failure on the disc was along the flat surface on the smaller guide pin as shown in the sketch belo i

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I The licensee found another disc with a crack along the smaller guide pin on the Division 1 DG. This second disc appeared to be ready to fail. No evidence of cracks were found on the four discs removed from the Division 2 D The Division 1 DG had approximately 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> and the Division 2 diesel had approximately 900 hour0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> The results of the licensees investigation states that the failure was a low stress high cyclic fatique

failure and could be prevented by establishing a service life for the dis The licensee has set a service life of 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> for the check valves as an interim corrective action. This interim action will remain in affect until final corrective actions are determined and implemented. On March 25, 1985, the licensee submitted a 10 CFR Part 21 report on the same potential defect noted above. This report identified the air start header check valve deficiency as repor .able deficiency 85/02. This item wil be an Inspector Followup Item (50 ,16/85-09-04). The inspectors review of the FSAR paragraph 8.3.1.1.4.1.d, Starting Circuits and Systems for the Standby Power Supply, revealed an inaccuracy in the description of the initiation logi A Diesel Generator is actuated by reactor vessel low water level and/or drywell high pressure. If one low water level transmitter fails, either high drywell pressure or a combination of low level and drywell pressure will initiate an automatic start signal. Two reactor water level switches and two high drywell pressure switches provide a one out of two taken twice logic. The present DG description talks about four low water level switches and four drywell high pressure switches but does not state that this applies to two separate ESF divisions. The licensee is initiating an FSAR revision to correct this discrepanc This will be an Inspector Followup Item (50-416/85-09-03).

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12. Startup Testing (72530C and 72528C)

The inspector observed all or part of the conduct, or preparation for conduct, of the below listed startup procedures and operations. The observation included a review of the procedure for meeting all test prerequisites, initial conditions, test equipment, and calibration require-ments. The overall crew performance was observed to ensure that minimum crew requirements were being met, that appropriate revised procedures were in use, that crew actions appeared to be correct and timely, that all data was collected by the proper pe; sonnel for final analysis, and that quick summary analysis showed proper plant response to the test. Where test results were available, in preliminary or final form, they were verified to be consistent with observations or that overall test acceptance criteria had been me SU-25-3, Main Steam Isolation Valve In the areas inspected, no violations or deviations were identifie . NUREG-0737, Clarification of TMI Action Plan Requirement NUREG-0737, Item II. Grand Gulf Unit 1 operating license NPF-29, paragraph 2.C (33)(e),

requires the licensee to implement the NRC staffs' requirements resulting from the review of the licensee's submittals regarding TMI action items II. Generic letter 84-23 identified potential improvements regarding reactor vessel water level instrumentation in Boiling Water Reactors (BWRs). The licensees response in a letter dated December 6, 1984, was found acceptable without any required plant modifications. The staff concluded that the presently installed reactor vessel water level instrumentation satisfied the requirements of NUREG-0737, Item II.F.2 and is acceptable. Grand Gulf license condition 2.C (33)(e) is satisfied and this also completes the Generic l Letter 84-23 response.

, NUREG-0737, Item II.K.3.28 NRC letter from Mr. T. M. Novak (NRC) to Mr. J.B. Richard (MP&L) dated March 15, 1985, discussed the NRC's review of the licensee's submittal on TMI action item II.K.3.28. The NRC concluded that the licensee

, submittal satisfied the short term operability requirements for ADS valves, accumulators and associated equipment and instrumentation following an accident. However, insufficient information for verifying long term operability was provided. TMI action item II.K.3.28 remains open.

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14. Design, Design Changes and Modifications (37700)

On March 15, 1985, the inspector witnessed the removal of the Main Steam Isolation Valve (MSIV) solenoid valves in preparation for replacement with new MSIV solenoid valves that were environmentally qualified. This change was being implemented by Design Change Package (DCP) 84/3084, revision The new ASCO solenoid valves, P/N NP-8323A20E (duel solenoid valve) and NP-8320A183E (single solenoid valve) were mounted on the termination box per the DCP and an attempt to install the new assembly was unsuccessful due to interference with the MSIV structure. The installation was modified by rotating the single solenoid valve approximately 90 degrees clockwise to provide installation clearance. The inspectors verified the installation was completed on March 21, 1985, as modified above. Also, on March 21, 1985, the inspectors reviewed the preliminary test results of the seismic testing of the new solenoid valves. Testing had just been completed on March 20, 1985, and a formal report was not available. It was pointed out to the licensee that the orientation of the single solenoid valve in the seismic test did not agree with the present installation in the plant. The licensee evaluated the orientation discrepancy and determined that the installation was adequate. Subsequently, during startup testing, the MSIVs were fast closed at approximately 60% power and all test criteria were successfully me On March 26, 1985, the licensee submitted reportable deficiency 85/03, MSIV failure to remain in a closed position due to failure of the duel solenoid valve to transfer when de-energized. This was reported under the provisions of 10 CFR 21. The resolution of this reportable deficiency will be tracked as an inspector followup item (50-416/85-09-06).