IR 05000321/1989001

Insp Repts 50-321/89-01 & 50-366/89-01 on 890121-0224. Violations Noted Re Deficient RHR Valve Operability Procedure.Major Areas Inspected:Operational Safety Verification,Maint Observation & Diesel Generator Fuel Oil

ML20247E642
Person / Time
Site:	Hatch
Issue date:	03/16/1989
From:	Menning J, Randy Musser, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247E623	List: IR 05000321/1989001 ML20247E619
References
50-321-89-01, 50-321-89-1, 50-366-89-01, 50-366-89-1, NUDOCS 8904030194
Download: ML20247E642 (18)

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NUCLEAR P4GULAM*W COMMISSION REGION :

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• [ 101 MARIETTA S'. , ATLANTA, GEORGIA 30323 Report Nos.: 50-321/89-01 and 50-366/89-01 Licensee: Georgia Power Company P.O. Box 1295 Birmingham, AL 35201 Docket Nos.:- 50-321 and 50-366 License Nos.: DPR-57 and NPF-5 Facility Name: Hatch 1 and 2 Inspection Dates: January 21 - February 24, 1989 Inspection at Hatch site near Baxley, Georgia Inspectors: M4 Jo W f.~ Menning, Senior Resident Inspector J #-P/

Date Signed WAL

.Randail A. Musser, Residdnt Inspector 3-A'-27 Date Signed 8 << _j L- 3//c/8<r Approved p,by: . Marvin V. Sinkule, Chief, Projects Section 3B Date Signed V Division of Reactor Projects i

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SUMMARY Scope: This routine inspection was conducted at the site in the areas of Operational Safety Verification; Maintenance Observat i; Surveillance Testing Observation; Reportable Occurrences; Drawing System vuification; Review of Licensee's Receipt, Storage, and Handling of Emergency Diesel Generator Fuel '

011 (TI 2515/100); 10 CFR Part 21 Report Followup; and Action on Previous Enforcement Matter Results: In the areas inspected, no deviations were identifie However, three licensee identified violations, which are not being cited, were ,

identified (paragraph 6). These licensee-identified violations involved a j deficient RHR valve operability procedure, deficierd LSFT and time response testing surveillance procedures, and an inadequate procedure for SRM channel checks. Additionally, three inspector followup items (paragraph 7) were opened to track the development of new requirements for the bottom sampling of emergency diesel generator fuel oil day and storage tanks, a procedure for the periodic cleaning cf emergency diesel generator fuel oil storage tanks, and a method for removing weter from emergency diesel generator fuel oil storage i tank No specific strengths or weaknesses of licensee programs were identified based on the inspectors findings and observations in the areas inspecte PDR *

O ADOCK 05000321

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REPORT DETAILS

, PersonscContacted

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Licensee Employees-C. Coggin,. Training and Emergency Preparedness Manager

• D. Davis, Manager. General Support-J. Fitzsimmons, Nuclear Security Manager

• P. Fornel, Maintenance Manage *0. Fraser, Site Quality Assurance Manager M..Googe, 0utages and Planning Manager

• Kirkley, Acting Health Physics and Chemistry Manager

• J. Lewis,. Acting Operations Manager

• C.. Moore, Plant Support Manager

• H. Nix, General Manager

• T. Powers, Engineering Manager

• H. Sumner, Plant Manage *S. Tipps, Nuclear Safety and Compliance Manager Other licensee employees contacted included techniuans, operators, mechanics, security force members, and office personne .

NRC Resident Inspectors

• Menning-

• Musser

• Attended exit interview Acronyms .and initialisms used throughout this report are listed in the last paragrap . Operational Safety Verification (71707) Units 1 and 2 The inspectors kept themselves infomed on a daily basis of the overall plant status and any significant safety matters related to plant p operations. Deily discussions were held with plant management and various y members of the plant operating staff. The inspectors made frequent visits to the control room.. Observations included instrument readings, setpoints and , recordings, status of operating systems, tags and clearances on equipment, controls ard switches, annunciator 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 discussions with cperators and their supervisors. Weekly, when on site, selected ESF systems were confirmed operabl The confirmation was made by verifying l

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accessible valve flow path alignment, power supply breaker and fuse status, instrumentation, major component leakage, lubrication, cooling, and general condition.

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General plant tours were conducted on at least a weekly basi Portions '

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of the control building, turbine building, reactor building, and outside are6s were visite Observations included general plant / equipment conditions, safety-related tagout verifications, shift turnover, sampling program, housekeeping and general plant conditions, fire protection l equipment, control of activities in progress, radiation protection '

controls, physical security, problem identification systems, missile i hazards, instrumentation and alarms in the control room, and containment  !

isolatio In the area of housekeeping, one discrepancy was observed by the inspector -

on January 26, 1989, and was brought to the attention of licensee l personne Materials and debris that apparently had been lef t from  !

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maintenance in the area were observed on elevation 106 in the Unit 1 reactor building southeast diagona The materials included boards,  ;

pieces of metal banding and insulation, and tool i During the inspection period, the inspectors attended operations shift turnover briefings on the following dates and shifts: January 27,  !

1989 - day, February 8, 1989 - day, February 9, 1989 - day, February 13, {

1989 - night, February 14, 1989 - night, February 15, 1989 - night, and i February 19, 1989 - night. Each briefing was conducted by the oncoming OS0 Each OSOS discussed the status of both units, ensuring that his team was well ware of all pertinent problems that had developed or had been resolved since the team had last been on shift. Safety and good radiological work practices were generally stresse On February 14, 1989, the inspector performed a review of the Unit 2 illuminated and inoperable annunciator The administrative control procedure for inoperable / problem annunciators is 30AC-0PS-009-05, " Control l Room Instrumentation." At the time of the review, there were 16 inoperable / problem annunciators in the control room,10 of which were greater than 6 months old. The inspector verified that the annunciator control log accurately reflected the status of all 16 inoperable / problem annunciators in the control roo As required by procedure 30AC-0PS-009-0S, monthly administrative reviews of the inoperable / problem annunciators were being performed. As a part of this review, the Manager <

of Operations is required to notify the Manager of Engineering of all problem annunciators older than three months, and additionally, the Manager of Operations is required to notify the Plant Manager of problem annunciators older than six months. The inspector observed that these requirements were being me However, paragraph 7.9.3 of procedure 30AC-0PS-009-05 requires that the Engineering Department provide an evaluation to operations management detailing the permanent resolution, actions taken, schedule for completion, and any other pertinent actions ,

taken for each problem annunciator reported. By reviewing the annunciator l control log, the inspector determined that four inoperable / problem annunciators, ACS 2-88-047, ACS 2-88-059, ACS 2-88-060, and ACS 2-88-063 had not received engineering reviews as required by paragraph 7.9.3 of procedure 30AC-0PS-009-0 The Engineering Department was made aware of the need for the evaluations in Operations Department memoranda dated

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November 23, 1988; January 9, 1989; and February 3, 1989. The inspector informed the Manager 'of Engineering of the need for the reviews. -The Manager of Engineering subsequently informed the inspector that the engineering reviews on -the subject annunciators had previously bee performed; however, the engineering reviews had been placed in the TMM log book only and not in both the TMM and annunciator control logs. The Manager of-Engineering indicated that a copy of the engineering reviews would be placed in the annunciator control log as required by procedure 30AC-0PS-009-0 The inspector conducted a ' detailed review of the. licensee's equipment clearance records on February 15, 1989. Equipment clearance program requirements are specified in procedure 30AC-0PS-001-OS, " Control of -

Equipment Clearances and Tags." Index/ Audit Sheets ' were initially compared with individual Clearance Sheets, and'the inspector verified that the Index/ Audit Sheets accurately reflected the status of active clearances. The -inspector observed that monthly reviews of equipment clearance records had been performed in accordance with Section 8.13.1 of procedure 30AC-0PS-001-0S. The equipment clearance records showed that 37 clearances were active in Unit 1.. Of these active clearances,'15 were placed in 1988 and 22'were placed in 1989. The records also showed that 42 clearances were active in Unit 2. Of these active clearances, I was placed in 1985, 3 were placed in 1987, 23 were placed in 1988, and 15 were placed in 198 Individual Clearance Sheets were reviewed to determine if quarterly reviews had been conducted on clearances that have been in effect greater than 3 months. Section 8.13.2 of procedure 30AC-0PS-001-0S requires that such reviews. involve the physical verification of proper tag placement and of the proper positioning of equipment. The inspector determined that quarterly reviews had generally been performed as required. However, one discrepancy was noted in Unit The records showed that Clearance 2-88-945 had not been reviewed during the period July 6,1988, to January 4, 198 This clearance was placed on April 14, 1988. This discrepancy was brought to the attention of the Unit 2 Shift Superviso The discrepancy is not being cited as a violation since it is an isolated case and is not indicative of a general failure to conduct quarterly equipment clearance review The inspector also walked down Clearance 1-88-487 (Unit 1) and Clearance 2-88-580 (Unit 2) . The walk downs involved verification of proper selection and placement of tags on equipment, of proper positioning of tagged equipment, and of the accuracy and completeness of information on tags. No discrepancies were noted during the clearance walk down No violations or deviations were identifie . Maintenance Observation (62703) Units 1 and 2 During the report period, the inspectors observed selected maintenance activities. The observations included a review of the work documents for adequacy, adherence to procedure, proper tagouts, adherence to technical

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specifications, radiological controls,f observation of. all -or part ofithe

. actual work :and/or retesting in progress, specified. retest requirements. .

y , and ' adherence' to the appropriate quality control The. primary

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maintenance observations during this month are summarized below:

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4 .SLC System Pump Relief. Valve 01/22/89 Test, Oil Change, and Lubrication per procedure 52PM-C41-102-2S and MW0s 2-88-4374.and 2-88-4398-(Unit.2)- Standby Gas Treatment System .

01/25-26/89 Modification per DCR 87-117 and MWO;2-89-138 (Unit 2) ' One Year Preventive Maintenance- 01/30-31/89 on Diesel- Fire Pump C002A per MWO 1-88-6920 an procedure 52SV-X43-002-15 (Units 1 and 2).

d.- Repair of CRD Pump 1B per 02/15-22/89 MW0s 1-89-767 and 1-89-769 (Unit 1)

No violations or deviations were identifie . Surveillance Testing Observation (61726) Units 1 and 2 The inspectors observed the performance of selected . surveillance. Th 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 surveillance, removal from service and return to service of the system or comp; nerts affected, and review of the data for acceptabi_lity based upon the acceptance criteria. The primary surveillance testing observations during this month are summarized below:

Surveillance Testing Activity Date Diesel Generator Monthly 01/25/89 Test per procedure 345V-R43-002-2S(Unit 2) MSIV Exercise Testing per 01/26/89 procedure 34SV-821-003-I (Unit 1) HPCI Pump Operability 02/08/89 Testing per procedure 345V-E41-002-1S (Unit 1)

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L RCIC Turbine Governor ~ L02/09/89 Contrcl-System Functional Test'per procedure 57SV-SUV-003-IS (Unit 1)

Primary. Coolant Conductivity 02/16/89 e. . ' Testing per procedure 64CH-GCL-006-0S (Unit 2)

No violations 'or deviations were : identifie . Reportable Occurrences (90712 and 92700) Units 1l and 2 A number of LERs were reviewed for.' potential generic impact, to detect trends, and to determine whether corrective actions appeared' appropriat Events which were reported immediately were also reviewed as.they occurred to determine that technical specifications 'were' being met ant @at the public health and safety were of utmost consideratio Unit 1: -88-19 Procedure Error Could Cause Technical Specifications:

Violation-This LER concerns a . deficient RHR valve operabilit surveillance procedur More specifically, the allowable stroke times specified in Rev. 4 of procedure 34SV-Ell-002-1S, "RHR Valve Operability,"

for two system valves were greater than~the technical specification limit The procedural acceptance criterion for the stroke time of valve 1E11-F011B was a maximum of 24 second Unit 1 Technical Specification Table 3.7-1 specifies a maximum time of 22 second Similarly, the procedural acceptance criterion for valve IE11-F049 was 49 seconds, and the i limit specified in Unit 1 Technical Specification l Table 3.7-1 is 20 seconds. This matter was identified by the licensee and properly reported pursuant to 10 CFR Part 50.73. The inspector noted during the review of this LER that stroke times obtained during actual testing were less than the technical specification limit Corrective action involved temporarily revising Rev. 4 of procedure 345V-E11-002-1S to properly reflect the technical specification stroke time limit The inspector reviewed Temporary Change 89-5 to this procedure and verified that this corrective act1on had been completed. Additionally, a permanent revision to the procedure was scheduled for implementation by February 28, 1989. Unit 1 Technical Specification 6.8.1.c requires that written procedures be esta-b1:shed, implemented , and mairtained for the surveillance and test activities of safety-related

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i equipmen The deficiencies in' Rev. 4 of procedure 34SV-E11-002-1S are. a' violation of Technical Speci-fication 6.8.1.c. -This licensee-identified violation meets the criterion specified in Section V of the NRC Enforcement Policy for not issuing a Notice of Violation and is not being cite This matter, identified as LIV 321/89-01-01, is closed. . Review of the LER is also close Unit 2: 88-02 Personnel Errors Cause Procedure Errors Leading to Violations of Technical Specifications This LER relates to two -instances in .which surveillance test procedures did not fully meet related technical specification requirements. ~In the first instance, plant procedures did not provide for a LSFT on the non-coincidence trip mode ' of RPS as required by Technical Specification Section 4.3. In the second instance, procedure 575V-011-004-25,

" Time Response Testing of Reactor Building ard Refueling Floor Area Radiation Monitors," did not fully test the isolation system response time for the actuation instrumentation listed in Technical .

Specification Table 3.3.2-1, items 2a and 2d. There procedural deficiencies were identified by the licensee during the PUP process and were properly reported pursuant to 10 CFR Part 50.73 Corrective action for the first instance involved developing and performing- special purpose procedure 34SP-021988-CS-1-2S to satisfy the requirements of Technical Specification Section 4.3.1.2. Provisions for performing a LSFT on the non-coincidence trip mode of RPS were subsequently incorpu7 ted into permanent plant procedure 34SV-C51-001-2S, "SRM Functional Test." The inspector reviewed Rev. 2 of procedure 34SV-051-001-25, which become effective on February 18, 1989, and noted that the LSFT test provisions had been incorporated as Section 7.3 of the procedur Corrective action for the second instance involved developing and performing special purpose procedure 57SP-0-22-388-IF-1-25 to satisfy the technical specification time response testing requirement Four permanent procedures

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(57SV-D11-024-2S, 57SV-D11-025-25, 57SV-D11-026-25, and 57SV-011-027-25) were subsequently developed to provide for the required time response testing. On

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February 6,1989, the inspector reviewed these four procedures and noted that they had been approved by the Maintenance Manger on August 12, 1988, and were awaiting validatio Technical Specification 6.8.1.c requires that written procedures be established, implemented, and maintained for the surveillance and test activities of safety-related equipmen These two instances of deficient surveillance procedures are a violation of Technical Specification 6.8.1.c. This violation meets the criteria specified in Section V of the NRC Enforcement Policy for not issuing a Notice of -

Violation and is not being cite This licensee-identified violation, identified as LIV 366/89-01-02, is close Review of the LER is also close Inadequate Procedure Results in Missed Technical Specification Surveillance This LER concerns the failure of plant procedures tn -

fully support the surveillance requirements of Technical Specification 4.3.6. Plant procedure 34G0-SUV-002-2S, " Surveillance Checks," only required SRM channel checks when in operating conditions 2 and 4 Technical Specification 4.3.6.5.a also requires such channel checks in operating conditions 3 and Corrective action involved replacing procedure 34G0-SUV-002-2S with a new procedure that had been through the licensee's PUP process. The new procedure (34SV-SUV-019-2S) became effective on November 15, 198 The inspector reviewed Rev. O of procedure 34SV-SUV-019-2S and concluded that the SRM channel check requirements of Technical Specification 4.3.6.5.a had been incorporate Technical Specification 6.8.1.c requires that written procedures be established, implemented, and maintained for surveillance activities of safety-related equipmen The failure of procedure 34G0-SUV-002-2S to fully address the SRM channel check requirements of Technical Specification 4.3.6.5.a is a violation of Technical Specification 6.8.1.c. However, this matter was identified by the licensee and properly reported pursuant to 10 CFR 50.73. Corrective action was completed in a timely manner. This violation meets the criteria specified in Section V of the NRC Enforcement Policy for not issuing a Notice of Violation and is no+ being cite This l

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licensee-identified violation,. identified as LIV 366/89-01-03, is close Review ; of 'the LER

.is also close ,- 88-24 ' Component Failure Causes Both_ Recirculation Pumps;to Trip Requiring Manual Scram This LER concerns the manual' scram of Unit' 2, on December 25, 1988, following the trips of. both

, recirculation, pumps during turbine stop'.. valve'

surveillance testing.. The events of this LER and.the licensee's corrective actions were previously reviewed

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in NRC Inspection Report Nos. 50-321/88 42 and 50-366/88-42. Review of this LER is close Three licer.see-identified violations were identifie ~. Drawing System Verification (71707 and 71710) Units 1 and 2 During'the inspection period, the inspector. performed an assessment of the Hatch drawing system. This . assessment involved a review of critical .

drawings, a review of the drawing change process, and an as-built verification of a safety-related syste The results of the assessment are summarized below: Review of Critical Drawings The licensee has determined that approximately 912 of the plant' drawings are to be considered critical for use by operations (control room) personnel or personnel manning the TSC. A list of these drawings is maintained by Document Control and the Engineering and Operations Departments. The incpector reviewed 30 critical drawings in the main control room and TSC. Each drawing was checked for legibility and confirmed to be the most current, approved revisio An operations shift supervisor was asked to demonstrate the process of determining whether a drawing represents the most current plant configuration. Two critical drawings with outstanding ABNs were selected for this revie The first drawing was identified as D-11001, "P&ID for Service Water Piping at Intake Structure." The second drawing was identified as H-11036, "P&ID for Circulating Water System". Since these drawings are considered critical by the licensee, the drawings were expected to be marked up to reflect the ABNs and changes in the plant. (In the cases of critical drawings, any outstanding ABNs are included on the actual microfilm drawing card filed in the control room or TSC.) The ABNs which were outstanding to the two selected drawings were physically walked down by the shift supervisor and inspector. The walkdowns confirmed that the drawings represented the current plant configuratio _ _ _ _ - - _ _ - _ _ _ _ _

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In the cases of non-critical drawings, ABNs are not included on the microfilm cards filed in the control room or TSC. The ABN number is written on the front of the microfilm card, informing the user that a copy of the ABN must be obtained to determine the current plant configuration. A file of all outstanding ABNs against non-critical drawings filed in the control room is kept in the operations supervisor's office (physically a part of the control room). For all non-critical drawings filed in the TSC, cne associated ABNs must be obtained from Document Control. In either case, the ABNs are in a form that is compatible with the main documen In the cases of both critical and non-critical drawings, the scope of the drawing change is easily' identifiable. The portion of the drawing to be deleted (if applicable) will be " clouded" and

"h atch-ne rked. " The portion of the drawing to be added (if applicable) will only be " clouded." Additionally, each individual portion of the change will be identified with the ABN number. The maximum number of outstanding ABNs allowed prior to a drawing being revised depends upon the particular category of drawing in questio Plant Hatch has five different categories of drawings. The critical drawings are comprised of category 1 and 2A drawings. When a change is made to one of these drawings, a revision must be made to the drawing within 30 days. Categories 2, 3, and 4 are considered non-critical drawings. When a change is issued against a category 2 drawing, a revision to that drawing must'be made within 90 days. The maximum number of outstanding changes prior to a category 3 drawing being revised is Once a category 3 drawing accumulates 3 outstanding changes, the drawing must be revised within 90 day Category 4 drawings are for reference only, and no changes are made to these drawing b. Review of the Drawing Change Process There are different procedures for updating the drawings in the control room and TSC. Specifically, critical drawings in the control room receive special priority over the drawings in the TSC and other satellite station When a change (ABN or WCN) is issued against a critical drawing, Document Control has 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to get tue updated microfilm card to the control room. For the TSC and other satellite drawing stations, Document Control must provide updated microfilm cards within 10 day This 10-day period applies to critical and non-critical drawings in all satellite drawing stations with the exception of the control room. However, the 10-day time frame does apply to non-critical control room drawings. Periodic audits of the drawings in both the control room and the TSC are performed. The Operations Department performs a semi-annual audit of the control i

room drawings and likewise, the document control staff performs a i semi-annual audit of the drawings in the TS When a drawing discrepancy is identified, the ABN process is used for updating the affected drawings. This process is implemented by engineering procedure 42EN-ENG-002-05, " Work Completion and As-Built

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Notices." This procedure does not include the' requirement 'for a:

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safety review. The need for a safety review is determined either by

.the implementing engineer, Nuclear Safety and, Compliance '(NS&C is -

involved with all deficiencies ncted ~ in the plant through -the licensee's deficiency card system)..or the A/E. Additionally, there-is no.. set time;for control' room prints to be updated or flagged as a result of a discrepanc However, if a system and its. discrepancy were safety-related/important to safety, an ABN could = be issued to the control room within one da Design changes ~and ' modifications are controlled by engineering m

procedure 42EN-ENG-001-OS,."DCR Processing." Upon completion of a design change or . modification' and' prior to having the affected :

.i system / equipment ' declared . operable, the responsible engineer- must

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confirm that the WCNs implementing the changes are issued to Document Control. Therefore, for systems / equipment. represented on ~ critical drawings, the control room staff would have the updated: microfilm

~ cards within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of engineering: submittal to Document Contro .If. work on a system / equipment is nartially complete or delayed. for

long periods of time, operations.is made aware of these changes via the- temporary modification system. . Temporary modification requirements are delineated in procedure 30AC-0PS-005-05, " Temporary Bypass, Jumper, . and . Lifted Leads Control ." Temporary changes to equipment can also be shown on drawings via a temporary ABN or WC The number assigned to the ABN/WCN has~a "T" designator' indicating a

temporary change to the drawing.

, As-Built Verification On ' February 1, 1989, the inspector performed 'a hand-over-hand walkdown of the accessible portions of the Unit 1 HPCI syste . Drawings : H-16332 and' H-16333, "HPCI System P&ID," were used in accomplishing the system walkdown. Equipment in the plant was -

compared with the representation of-that equipment on the P& ids. The following discrepancies were noted:

(1). The following valve outlets were not capped as shown on the P& ids:

- 1E41-F100 l

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- 1E41-F3007

- 1E41-F3005

- 1E41-F3003

- 1E41-F3014

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- IE41-F3026

- 1E41-F062 (2). The following pressure indicator was not present as shown on the P&ID:

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1 These i_tems were considered to be.of minimal safety significance and hads no impact on the operability of' the system. They were-also brought to. the attention of the Unit 1 Shift Supervisor and the system engineer.

, .Past History Due to concerns brought to light 'in early 1988, the licensee -

voluntarily initiated- an Operational Upgrade Effort. . As a part of the .0perational' Upgrade Effort, control room drawings were-improved so that the operators could more readily determine the

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current plant configuratio Upgrade efforts in the drawing control . area have; been discussed in OPA team Inspection Report Nos. 50-321/88-15, 50-366/88-15, 50-321/88-36, and 50-366/88-36 and .in resident inspector Report Nos. 50-321/88-29, 50-366/88-29,.50-321/88-34 and 50-366/88-3 No violations or deviations were identi.fie . . Review of Licensee's. Receipt, Storage, and Handling of Emergency Diesel Generator Fuel Oil'(TI 2515/100) Unitc 1 and 2 During this inspection period, the inspector reviewed the licensee's program for. receiving, storing, and handling EDG fuel oil, focusing on the program elements that prevent and detect fouling. As part of this effort, the inspector also reviewed the licensee's. consideration of and responses to NRC Information Notice 87-04. This Information Notice was issued as a result of the Arkansas Unit 2 EDG fuel oil starvation event which occurred on June 27, 198 The inspector' initially reviewed the regulatory requirements related to EDG fuel oil quality. The technical specifications require a sample of fuel oil to be obtained from each fuel storage tank in accordance with ASTM-D270-65 at least once every 92 days and verified to be within the acceptable limits specified in Table 1 of ASTM-D975-74 when checked for viscosity, water, and sediment. These requirements are specified in Sections 4.9. A.2.d and 4.8.1.1.2.c of the Unit 1 and 2 Technical Specifications, respectively The plant EDG Fuel Oii system P& ids (H-11037 and H-21074) were reviewed to assess the capabilities of installed equipment. The inspecter noted that there is no permanent fuel oil storage tank recirculation capability which would allow for periodic, complete fuel oil inventory cleaning to remove accumulated particles. It was also noted that two independent flow paths q exist between each storage tank and its associated day tank. Fouling of ,

one component in either flow path would not preclude operation of the l associated EDG. However, only single flow paths exist between each day J tank and the associated EDG. Operation of the EDGs is vulnerable to the fouling of individual filters and strainers in these line (The licensee's program for the inspection and cleaning of filters and '

strainers in the EDG Fuel Oil system is discussed below.) Review of the

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P& ids and a walkdown of equipment also showed that duplex filters are provided with differential pressure indicator Several fuel oil-related alarms annunciate in the main control room on the 1(2)H11-P652 panels. The " Fuel Oil Level High-Low or Tank Water Detector" annunciator for each day tank alarms when fuel oil level is above 3 inches or below 12 inches below the tank top or when the tank moisture detector is activated. The " Fuel Oil Press Low" annunciator for each EDG alarms at 10 psig indicating low fuel oil pressure to the diesel. A review of the Unit 2 ELI dated October 1988 showed the day and storage tank level transmitters providing level indication in the main control room, day tank level switches activating control room annunciators,-and day tank level switches controlling the fuel transfer pumps to be Seismic Category The day tank moisture detectors are not Seismic Category I. A review of the Unit 1 ELI dated October 1988 showed that similar switches and transmitters are not Seismic Category The inspector also reviewed the licensee's EDG fuel oil sampling progra Prior to off loading fuel to the EDG storage tanks, fuel oil truck contents are sampled for API Gravity and water and sedimen This sampling is performed per procedure 62CH-SAM-029-0, " Diesel Fuel Oil Truck Content Analysis Program." Periodic sampling of the storage tanks to support the previously cited technical specification requirements is performed per procedure 62CH-SAM-003-05, " Oil Sampling." This procedure is specifically intended to provide representative samples and states that tanks should be recfeculated at leact 30 minutes before taking sample The inspector questioned a cognizant chemistry supervisor abcut whether periodic bottom sampling was being performed in the day and storage tanks for accumulated water and/or high particulate concentrations which could develop due to oxidation or biological contamination. The inspector learned that the sampling of tank bottoms is currently limited to the semi-annual sampling of the storage tanks for microbiological materia This work is performed by the licensee's Fuel Services group. However, the supervisor indicated that requirements are now being developed for the sampling of day tank bottoms. The licensee is also considering the inclusion of water and sediment in the sampling of storage tank bottom Pending completion of the licensee's efforts in this area and review by the inspector of requirements that are developed, this matter will be tracked as IFI 321,366/89-01-04, Bottom Sampling of EDG Fuel Oil Day and Storage Tank During the review of fuel oil sampling, the inspector learned that the licensee uses a fuel additive (NALC0 8256) to prevent oxidation and bacterial growt The use of NALC0 8256 is currently controlled by standing order 50-CHM-05-1288. The licensee intends to eventually include these instructions in procedure 64CH-SAM-002-0 Review of the licensee's preventive maintenance program showed that a new procedure providing instructions for cleaning and inspecting fuel oil system components was recently approved for validatio More l specifically, procedure 52PM-R43-002-05, " Diesel Generator Day Tank Cleaning and Inspection," provides for the flushing of strainers and draining of day tank bottoms at least once every 3 months, the inspection

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and cleaning of strainers at least once every 18 months, and the cleaning of day tanks at least every 60 month The inspector learned that procedure 52PM-R43-002-0S will most likely be validated by the end of the next Unit 2 refueling / maintenance outage. Filter elements are currently inspected and replaced every 18 months in accordance with Section 7.2.1'of procedure 52SV-R43-001-05, " Diesel, Alternator, and Accessories Inspection." The inspector observed that no program requirement appeared to exist for the cleaning and inspection of the fuel oil storage tanks, and this matter was discussed with a cognizant maintenance engineer. This individual confirmed that the requirement does not presently exist but indicated that all storage tanks were cleaned in November 1986. The maintenance engineer also stated that the licensee has generated an action item to develop a procedure within the next two years for cleaning and inspecting the fuel oil storage tank Pending development of this procedure and subsequent review by the inspector, this matter will be tracked as IFI 321,366/89-01-05, " Procedure for Cleaning Fuel Oil Storage Tanks."

The inspector reviewed the licensee's requirements for monitoring and removing accumulated water from the day tanks. The licensee does not currently check for water in the day tanks periodically or after some specified period of diesel operation. Rather, reliance is placed upon the day tank moisture detectors which operate continuously and alarm in the main control room. If a day tank moisture alarm is received, ARPs 34AR-652-001-1 and 2 require that the tank be drained until the alarm clears. As previously mentioned, procedure 52PM-R43-002-0S will provide for the draining of day tank bottoms at least once every three months as a preventive measur Requirements for the monitoring and removal of water from storage tanks were also reviewed. As discussed previously, the licensee is now considering the inclusion of water analysis in the sampling of storage tank bottoms. The inspector learned that the licensee is also currently evaluating st ategies for removing accumulated water from the storage tanks and has opened an action item for tracking purpose Pending completion of the licensee's evaluation and subsequent NRC review, this matter will be tracked as IFl 321,366/89-01-06, Removal of Water from Fuel Oil Storage Tank The inspector concluded that the licensee has taken action in response to Information Not ce 87-04 (and information from other industry sources) to i

enhance the plant's ability to prevent and detect fouling within the EDG fuel oil syste The elements of the licensee's program that are under evaluation and/or still being developed will be tracked by the three identified IFI No violations or deviations were identifie . 10 CFR Part 21 Report Followup (92701) Units 1 and 2 By letter dated April 30, 1987, the Fairbanks Morse Engine Division of Colt Industries advised the NRC of an Indicator Valve Plug failure. The vendor recommended at that time that such plugs be removed and inspected

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for thread deterioration if installed in Fairbanks Morse Model 38TD8-1/8 emergency diesel generator adapter relief and indicator valves. It was also recommended that such inspections be conducted at five year intervals and integrated into plant preventive maintenance procedures. The inspector reviewed the licensee's response to this vendor notification and its recommendations. The inspector determined that these brass indicator plugs had been replaced in the IR43-S001A, -50018, and -5001C diesel generators in April 1987 under MW0s 1-87-3120, 1-87-3082, and 1-87-3119, ,

respectively. Plugs in the 2R43-5001A and -5001C diesel generators were I replaced in April 1987 under MWO 2-87-1704 and in April 1988 under MWO i 2-87-1682, respectively. The inspector also determined that the licensee has not yet incorporated five year inspection requirements into preventive maintenance procedure The licensee currently plans to include such inspection requirements in a new procedure (52PM-R43-001-05). This i matter, tracked by Region II as item 321,366/P2187-01, will remain open I pending review by the inspector of this new preventive maintenance f procedur By letter da'.ed January 13, 1989, Asea Brown Broveri made a report to the NRC pursuant to 10 CFR Part 21 concerning K-Line K-225 through K-2000 circuit breakers that were delivered prior to July 197 Users of these K-line circuit breakers were advised to add rebound springs on the slow close levers in accordance with provided instructions. On February 6, 1989, the licensee made the determination that such circuit breakers were not employed in safety-related applications at Plant Hatch. Review of this matter, tracked by Region II as item 321/P2189-01, is close . Action on Previous Enforcement Matters (92702) Units 1 and 2 (Closed) Violation 321/87-12-01, Inadequate Operations and Surveillance Procedures The licensee's letter of response dated August 13, 1987, was reviewed by the inspector. Corrective actions involved performing a full PUP review on excess flow check valve operability test procedures, revising RHR system procedures to provide a positive method of verifying that systern piping is filled prior to placing the system in the SDC mode, and counselling operations personnel relative to the reduction in reactor vessel inventory event on June 15, 1987. The i inspector reviewed procedures 57SV-SUV-004-1S and 2S, " Reactor 1 1 Coolant Instrumentation Lines Excess Flow Check Valve Operability,"

I and verified that these procedures had undergone PUP review. The inspector also reviewed procedures 3450-E11-010-1S and 25, " Residual Heat Removal System," and determined that intended changes had been incorporated into Section 7.2.3 of each procedure. Since corrective actions have been completed, this matter is close !

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' (Closed) Violation 366/88-14-02, Violation of Primary Containment Integrity During Hydrogen Recombiner System Testing The inspector reviewed the licensee's letter of response dated July 5, 1988. Corrective action beyond restoring the system to service involved counselling a manager relative to the event. The inspector determined via discussions with this individual that the counselling had taken place. Review of this matter is close (Closed) 'liolation 321,366/88-17-03, Deficient Operating Procedureo The licensee's letter of response dated August 22, 1988, was reviewed by the inspecto Corrective action involved the modification of several procedure Procedures 3450-N21-007-IS and 25, " Condensate and Feedwater System," were to be revised to provide specific instructions on filling and venting condensate pumps during power operations. Unit 1 startup procedures were also to be revised to add the requirement to restore the Drywell Pneumatic system to its normal nitrogen supply using system operating procedure 3450-P70-001-1 Finally, procedure 3450-P70-001-1S, "Drywell Pneumatic System," was to be changed to delete the requirement to close the outboard nitrogen supply isolation valves IP70-F025A and IP70-F025B when swapping from nitrogen supply to instrument air suppl The inspector reviewed Rev. 5 of procedure 3450-N21-007-15 and determined that the intended changes had been incorporated as Section 7.3.15 of-that procedur Review of Rev. 6 of procedure 34S0-N21-007-25 revealed that the intended changes had been incorporated as Section 7.3.15 of that procedur The committed changes to the Unit I startup procedures were incorporated in Rev. 3 of procedure 34G0-0PS-003-IS, " Normal Startup System Status Checklist." The inspector also reviewed Rev. 3 of procedure 3450-P70-001-13 and determined that the intended changes had been incorporated into Data Package 4 of that procedure. Review of this matter is close . Exit Interview (30703)

The inspection scope and findings were summarized on February 24, 1989, with those persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findings. Particular emphasis was placed on the three licensee-identified violations indicated in paragraph 5, the three inspector followup items indicated in paragraph 7, and the three violations closed in paragraph The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection. Dissenting comments were not received from the license Item Number Status Description / Reference Paragraph 321/87-12-01 Closed VIOLATION - Inadequate Operations and Surveillance Procedures (paragraph 9)

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1 366/88-14-02 Closed VIOLATION - Violation of Primary Containment Integrity During Hydrogen Recombiner System Testing (paragraph 9)

321,366/88-17-03 Closed VIOLATION - Deficient Operating Procedures (paragraph 9)'

321/89-01-01 Opened and LIV - Deficient RHR Valve Closed Operability Procedure (paragraph 5)

366/89-01-02 Opened and LIV - Deficient LSFT and Time Closed Response Testing Surveillance Procedures (paragraph 5)

366/89-01-03 Opened and LIV - Inadequate Procedure for Closed SRM Channel Checks (paragraph 5)

321,366/89-01-04 Opened IFI - Bottom Sampling of EDG Fuel Oil Day and Storage Tanks (paragraph 7)

321,366/89-01-05 Opened IFI - Procedure for Cleaning Fuel Oil Storage Tanks (paragraph 7)

321,366/89-01-06 Opened IFI - Removal of Water from Fuel Oil Storage Tanks (paragraph 7)

Licensee management was also informed that the four LERs discussed in paragraph 5, and the second 10 CFR Part 21 item (321/P2189-01) discussed in paragraph 8 were considered to be closed. Other subjects discussed at the exit interview included the Unit 2 annunciator audit (paragraph 2);

the equipment clearance walk downs (paragraph 2); the drawing system verification (paragraph 6); the review of the licensee's receipt, storage, and handling of emergency diesel generator fuel oil (paragraph 7); and the open status of 10 CFR Part 21 item 321/366/P2187-01 (paragraph 8).

11. Acronyms and Abbreviations ABN - As-Built Notice A/E - Architect-Engineer API -

American Petroleum Institute ARP - Annunciator Response Procedure ASTM - American Society for Testing and Materials CRD - Control Rod Drive DCR - Design Change Request {

EDG - Emergency Diesel Generator >

ELI - Equipment Location Index i

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LESF - EngineerediSafety Featu '

HPCI . High Pressure Coolant Injection IFI. -c Inspector-Followup Item

~LER - Licensee Event. Report LIVT - Licensee-Identified Violation i LSFT - Logic System Functional; Test'

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MSIV - . Main Steam Isolation Valve:

MWO -

Maintenance Work Ordert-NRC - Nuclear Regulatory Commission:

NS&C - Nuclear Safety and Compliance- _

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OPA - c Operational Performance Assessment. Team Inspection OSOSL-. On Shift Operations Supervisor P&ID'-: Piping and. Instrument Drawing PUP' - Procedures Upgrade Program RCIC ' Reactor. Core Isolation 4 Cooling RHR -

Residual Heat Removal RPS < ~ Reactor Protection System SDC Shutdown Cooling Mode :

SLC - Standby' Liquid Control System SRM '- Source Range Monito "TI - Temporary Instruction 4 TMM - Temporary Mechanical Modification TSC - Technical-Support Center .;

WCN . Work Completion. Notice

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