IR 05000321/1989012

Insp Repts 50-321/89-12 & 50-366/89-12 on 890624-0721. Licensee-identified Violations Noted.Major Areas Inspected: Operational Safety Verification,Maint Observation,Ros & Surveillance Procedures & Records

ML20248C910
Person / Time
Site:	Hatch
Issue date:	08/02/1989
From:	Herdt A, Menning J, Randy Musser NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20248C908	List: IR 05000321/1989012 ML20248C904
References
50-321-89-12, 50-366-89-12, IEB-88-010, IEB-88-10, NUDOCS 8908100184
Download: ML20248C910 (14)

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'e NUCLEAR REGULATORY COMMISSION REGION 11 o

101 MARIETTA ST., .,,p ATLANTA. GEORGIA 30323

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Report Numbers: 50-321/89-12 and 50-366/89-12 Licensee: Georgia Power Company l- P.O. Box 1295

! Birmingham, AL 35201 Docket Numbers: 50-321 and 50-366 License Numbers: DPR-57 and NPF-5 Facility Name: Hatch 1 and 2 Inspection Dates: June 24 - July 21, 1989 Inspectors: / [.

John 4 . Menning, ienior Besident Inspector

$ I P-/ - M Date Signed i RandaT A. Musser, Resident Inspector l, / f-E-Of Date Signed Approved by: AM) @! b '8f Alan R. Herdt, Chief, Projects BranO. 3 Date Signed Division of Reactor Projects SUMMARY Scope:

This routine inspection was conducted at the site in the areas of Operational Safety Verification, Maintenance Observation, Surveillance Testing Observation, Reportable Occurrences, Surveillance Procedures and Records, and Action on Previous Inspection Finding Results:

Three strengths were identified during this reporting period. Implementation of the licensee's DC program and the professionalism and attentiveness of operations personnel were observed to be strengths (para and maintenance was also observed to be a strength (paragraph in that 3) graph 2),

preventive activities were effectively executed and corrective maintenance was both timely and effective. Two licensee-identified violations, which are not being cited, were also identified (paragraphs 5 and 7.b). The first non-cited violation was for improper calibration of the HPCI Woodward controller, and the second related to the inadvertent loss of logic power for drywell floor and equipment drain sump pump sz001g4 890802 "

gDR ADOCK 05000321 PDC .

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l REPORT' DETAILS Persons Contacted Licensee Employees

• C. Coggin, Training and Emergency Preparedness Manager

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

• P. Fornel, Maintenance Manager

• 0. Fraser, Site Quality Assurance Manager

• G. Goode, Acting Engineering Manager

• M. Googe, Outages and Planning Manager W. Kirkley, Acting Health Physics and Chemistry Manager J. Lewis, Acting Operations Manager

• C. Moore, Assistant General Manager - Plant Support H. Nix, General Manager - Nuclear Plant

• lf. Sumner, Assistant General Manager - Plant Operations

• S. Tipps, Nuclear Safety and Compliance Manager Other licensee employees contacted included technicians, operators, mcchanics, security force members and office personne NRC Resident Inspectors J. Menning

• R. 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 Both Hatch units continued operating at power during this reporting period with Unit 2 continuing its end-of-cycle power coastdow Unit 2 was operating at approximately 36 percent of rated power at the start of the reporting period, and operated et approximately 80 percent of rated power at the end of the period. On the morning of June 25, 1969, Elant Hatch surpassed the existing GE, BWR, worldwide record for dual unit operation (180 days). At that time, Units I and 2 had remained synchronized with the grid for 186 and 180 days, respectively. On the afternoore of July 14, 1989. Unit 3 exceeded the existing Hatch Site record for having a unit ;

tied to the grid (205.5 days). This record was also previously held by {

Hatch Unit 1. The inspectors kept themselves informed on a daily basis of the overall l plant status and any significant safety matters related to plant operations. Daly discussions were held with plant management and various I members of the plent optrating staff. The inspectors made frequent visits

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L, to the control room. Observations included control room manning, access control,- operator professionalism and attentiveness.. adherence to procedures, adherence to limiting conditions for operation, instrument readings, recorder. traces, annunciator alarms, operability of nuclear instrumentation and reactor protection system channels, availability of power sources, and operability of the Safety Parameter Display syste These' observations also included 109 book entries,-tags cnd clearances on.

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equipment, . temporary alterations in effect. ECCS ~ system lineups,

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containment integrity, reactor ' mode switch position, conformance with

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technical specification safety limits, daily surveillance, plant

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chemistry, scram discharge ' volume. valve positions, and rod movement l: controls. . This inspection activity involved numerous informal discussions with operators and their supervisor The operability of ' selected safety-related systems was l confirmed on essentially a weekly basis. These confirmations involved verification of proper valve and control switch positioning, proper circuit breaker and fuse alignment, and operability of related instrumentation' and support system Major components were also inspected for leakage, prope lubrication, cooling water supply, and general condition. On June 25, 1989, the inspector confirmed the operability of the Unit 2 Standby Gas Treatment system. Proper switch, electrical, and valve alignments were

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confirmed using Attachments 1, 2 - and 3, respectively. +o procedure 34S0-T46-001-25. On July 5, 1989, the inspector confirmed the operability of the Unit 1 RHRSW system. Proper switch, breaker, and valve lineups were confirmed using Attachments 1, 2, and 3, respectively, to procedure 3450-E11-010-I On July 10, 1989, the operability of the Unit 2 emergency diesel generators was confirme Proper switch, breaker, and

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valve positions were verified using Attachment 2 and 3 to. procedure L 34S0-R43-001-2S. On July 17, 1989, the' operability of the Unit 2 HPCI system was confirmed. Proper switch, breaker, and valve positions were verified using Attachment I and 2 to procedure 3450-E41-001-2 General plant tours were conducted on at least a weekly basis. Portions of the control building, diesel generator building, intake structure, turbine bJilding, reactor building, and outside areas were toure Observations included general plant / equipment conditions, fire hazards, fire alarms, fire extinguishing equipment, emergency lighting, fire barriers, emergency equipment, control of ignition sources and flammable materials, and control af maintenance / surveillance activities in progres Radiation protection controls, implementation of the physical security program, housekeeping conditions / cleanliness, control of missile hazards, and instrumentation and alarms in the main control room were also observe The inspectors observed selected operations shift turnover briefings to confirm that all necessary information concerning the status of plant systems was being addresse Each briefing was conducted by the oncoming 050 The inspectors noted that each OSOS discussed existing plant problems, activities that were anticipated for the shift, and any new standing orders or management directives. Radiological and industrial

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safety were generally stressed. The STAS discussed any recent procedure i revisions that impacted on the attendees. The inspectors attended shift I turnover briefings on the following dates and shifts; June 25, 1989 -

Day; June 25, 1989 - Evening; July 3, 1989 - Day; and July 20, 1989 - Da Several safety-related equipment clearances that were active were reviewed to confirm that they were properly prepared and placed. Involved circuit breakers, switches, and valves were walked dcwn to verify that clearance tags were in place and legible and that equipment was properly positione Equipment clearance program requirements are specified in licensee procedure 30AC-0PS-001-05, " Control of Equipment Clearances and Tags." On June 26, 1989, Unit 2 equipment clearance 2-89-597 was walked down. This clearance was placed to allow electrical backseating of valve 2B21-F016 ,

and the closing (in the de-energized position) of valve 2B21-F01 On i July 6, 1989, Unit 1 equipment clearance 1-88-0555 was walked down. This clearance was placed to provide for administrative control of torus purification system isolation valves 1G51-F011 and 1G51-F01 i Implementation of the licensee's sampling program was reviewed by the inspector. This review inv11ved observation of sampling activities (rearior cMar.c and tank sampling) and chemistry surveillance. Related records were osso reviewe During this inspection period, the inspector monitored the following activitie On June 29, 1989, the inspector observed the sampling of the Unit 2 Pre-treat Off-Gas for hydrogen in accordance with procedures 64CH-SAM-001-0S and 64CH-GCL-010-0 On l July 13,1989, the inspector observed the performance of the set point ;

checks, hi/ low flow test, and the source check of the Unit 2 Reactor 3 Building Vent Radiation Monitor in accordance with procedure 62CI-CAL-011-0 The licensee's deficiency control system was reviewed to verify that the system is functioning as intended. Licensee procedure 10AC-MGR-004-05,

" Deficiency Control System," es tablishes requirements and responsibilities for the preparation, processirg, review, and disposition of deficiency reporting documents. This procedure applies to all deficiencies affecting equipment, procedures, or personne Deficiencies are reported on Deficiency Cards. On June 28,, 1989, the inspector reviewed DCs that had been generated the previous day. The inspector verified that DCs had been prepared as required by the controlling procedure and that several deficiencies that were noted in the Shift Supervisors' and Operation Supervisors' logs had been documented on DCs. More specifically, the inspector verified that DC 1-89-2826 hr.d been prepared to document the

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failure of the HPCI exhaust line diaphragm master trip uni It was also l noted that DC 2-89-1835 had been generated to document the failure of the l "HPCI Turbine Inlet Drain Pot Level High" annunciator to clear upon completion of the m:r thly pump operability run. On July 5,1989, the inspector also revir ed recently prepared DCs and verified that problems

! observed in the plaM had been properly documented. The inspector noted l that DC 1-89 ^888 h6d been prepared to document the unanticipated I

autostarting o ' EHC pump IN32-C001A. It was also noted that DC 2-89-1863 had been prepcred to document a leak in the RWCU regenerative heat exchanger.

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Selected' portions of the containment isolation lineup were reviewed to L ' confirm that the lineup was correct.- The review involved verification.of proper valve positioning, verification that motor and air-operated valves were not: mechanically blocked and that power was available (unless blocking or power removal was required), and inspection of piping upstream q of the valves for leakage or leakage path On June 25, 1989 .the j

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inspector reviewed the _following Unit 1 containment isolation valves:

1E11-F024A. and B, IE11-F027A' and B, IE11-F028B,1E41-F111,1E51-F019, IP33-F004, IP33-F012, 1P41-F050, IP42-F051,- IP42-F052, 1T48-F103, IT48-F307, IT48-F324, and 1T48-F238. On July 5,1989, .the inspector reviewed the following Unit ? containment isolation valves: 2E11-F02dB, 2E51-F001, 2E51-F105, 2P33-F015, 2P33-F007, 2T48-F115, 2T48-F116, 2T48-F211, 2T48-F212, 2T48-F309, 2T48-F310, 2T48-F325, 2T48-F327, 2T48-F332A, 2T48-F333A, and 2T49-F004A and During this reporting period, the inspector reviewed the licensee's controls on overtime of personnel who ' perform safety-related function Section 6.2.2 9 of the technical specifications establishes requirements

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l L for the control of such overtime, and Section 8.4 of licensee procedure L

30AC-0PS-003-05, " Plant Operations," provides implementing instructions to support the technical specification requirements. On July 6, 1989, the inspector reviewed the Operations Department Overtime Report.for the month of May and determined that technical specification and procedural requirements had been me On June 26 and 27, 1989, the inspector verified that all required notices to workers were appropriately and conspicuous'ly posted pursuant to 10 CFR.19.11.- Related posting requirements are delineated in Section of licensee procedure 40AC-REG-002-05, " Federal and State Reporting Requirements." This procedure establishes posting locations at the Waste Separation and Temporary Storage Facility, Simulator Building near the breakroom, and Unit 1 Switchyard near Gate 16. Although not referenced in procedure 40AC-REG-002-0S, the licensee has also established a posting location north of the new Security Building. The inspector reviewed the postings at these locations and observed no discrepancie During this reporting period, the inspector reviewed the mechanisms which provide for the notification of the Operations Department by the plant training organization that licensed individuals have been placed on inactive license status. Such individuals are not allowed to perform duties whi:h require a NRC Reactor Operator license or Senior Operator license. Requirements for maintaining active license status, conditions requiring placement on inactive status, and requirements for reinstatement to active license status are delineated in procedure 72TR-TRN-002-0S,

" License Requalification Training Program." Step 7.3.4.2 of procedure 72TR-TRN-002-0S states that individuals will be designated as inactive by written notice to the individual and the appropriate Department Manage However, in discussing this matter with the Operations Training Superintendent and the Operations Superintendent, the inspector learned that it has been common practice to provide prompt telephone notification to Operations Department management of license status changes. The

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l' inspector concluded that these telephone notifications are important in ensuring that individuals in inactive license Ltats are not performing licensed duties. Da July 11, 1989, the inspector encouraged the Operations Training Superintendent to continee this practic On July 10-11, 1989, the inspector attended a portion of GPC's license requalifi-cation training for SR0s/R0s concerning the Plant Specific Technical Guidelines. The course was presented in two major divisions; Top Level Guidelines and Contingency Guidelines. The Top Level Guidelines consist of four topic areas as follows: (1) Reactor Pressure Vessel Control Guideline, (2) Primary Containment Control Guideline, ,

(3) Secondary Containment Control Guideline, and (4) Radioactivity Release '

Control Guideline. The Contingency Guidelines consist of seven topic areas as follows: (1) RPV Level Restoration, (2) Emergency RPV Depress-urization, (3) Steam Cooling, (4) Core Cooling Without Level Restoration, (5) Alternate Shutdown Cooling, (6) RPV Flooding, and (7) RPV Level Power Control. The purpose and various entry conditions for each guideline were emphasized to the class. Additionally, the instructor made references to the differences between the current revision of the EPGs in effect at Hatch to that of Revision 4 of the EPGs (to be implemented at Hatch in March 1990). The inspector found the course to be very informative and that the learning objectives set forth in the text were me Finally, it-should be noted that the instructor was very well prepared and appeared to be very knowledgeable of the subject materia Two strengths were identified the licensee's implementation of the DC program was observed to be a strength during this reporting period. The inspectors observed that plant personnel at all organizational levels were critical and thorough in documenting deficiencies on DC This conscientious support of the program ensured that management had the information necessary to accurately track and trend deficiencies within the plant. The professionalism and attentiveness of operations personnel were also observed to be strengths during this reporting period. The inspectors observed that operators and their supervisors were alert to changes in equipment performance and responded promptly and effectively to equipment problems that were experience No violations or deviations were identifie . Maintenance Observation (62703) Unit 2 During the report period, the inspectors observed selected maintenance activitie The observations included a review of the work documents for adequacy, adherence to procedure, proper tagouts, adherence to technical specifications, radiological controls, observation of all or part of the actual work and/or retesting in progress, specified retest requirements, i

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and ' adherence .to the appropriate quality controls. .The primary maintenance coservations during this month are summarized below:

Maintenance Activity Date Repair. of the Mid-Range Drywell 06/26/89 Pressure Recorder in accordance with MWO 2-89-3661 and procedure 57CP-CAL-156-2S Repair of the 2R42-S029 (2D) 125 07/05/89-volt Battery Charger in'accordance with MWO 2-89-3829 Adjustment of the' Cam Micro-Switches 07/17/89 on the "2C" Emergency Disel Generator Governor in accordance with MWO 2-89-4036

. Replacement of the LOSP' Timer 07/18/89

.(2R43-N782A) fo'r the'"2A" Emergency Diesel Generator in accordance with  !

MWO 2-89-4039

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Maintenance was observed to be a strength during this reporting period in 1 l- . that preventive activities were~ effectively executed and corrective'  !

maintenance was -both timely and effective. The inspectors noted that" '

L system outages were consistently executed as planned. Examples include preventive maintenance.that was performed on the "A" and "B" trains of the

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Unit 2 Hydrogen Recombiner system and on the "B" train of the Unit 1 SGTS.

l The ' inspectors also noted numerous instances in which corrective i

maintenance was both timely and effective. Examples include repair of the  !

l "2F" 325/250 volt battery charger and trouble shooting and repair of the Unit 2 master feedwater controlle !

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No violations or deviations were identifie ! Surveillance Testing Observation (61726) Unit 2 The inspectors observed the performance of selected surveillance. The-observation included a review of the procedure for technical adequacy, '

conformance to technical specifications, verification of test instrument l calibration, observation of all or part of the actual surveillance,  !

removal from service and return to service of the system or components 1 affected, and review of the data for acceptability based upon the i

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l acceptance criteria. ' The primary surveillance testing observations during this month are summarized below:

Surveillance Testing Activity Date MSIV Leakage Control System 06/28/89 Valve Operability in accordance with procedure 345V-E32-001-25 Diesel Generator 2A Monthly 06/30/89 Operability Test in accordance with procedure 345V-R43-001-25 RCIC Pump Operability Test in 07/11/89 accordance with procedure 345V-E51-002-2S Functional Test and Calibration 07/13/89 ;

of the "B" Unit 2 H907Analyzer (2P33-P601A) in accbruance with procedure 57SV-P33-001-2S On June 28, 1989, while observing the MSIV Leakage Control System Valve Operability in accordance with procedure 345V-E32-001-2S, the inspector noted a minor procedural discrepancy. Each valve tested by the procedure is opened / closed with the operation of its companion keylock test switc The procedure identifies each keylock test switch with it; assigned MPL number. However, each keylock test switch is labeled (on panel 2H11-P664)

with its' associated valve MPL number in lieu of the switch MPL numoer listed in the procedure. This situation could possibly be confusing to the operator performing the surveillance and could lead to operation of a wrong switch. This discrepancy was brought to the attention of the Operations Superintenden No violations or deviations were identifie . Reportable Occurrences (92700) Unit 1 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 and the public health and safety were of utmost consideratio Unit 1: 88-17 Procedure Error Causes High Pressure Coolant Injection Inoperability This LER concerns an instance in which the HPCI system was found to be inoperable during the performance of surveillance procedure 34SV-E41-002-1S, "HPCI Pump Operability." Specifically, the pump could not reach rated flow at rated reactor pressure. This situation

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was ' attributed to personnel error in that the HPCI

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setting Corrective action . involved properly calibrating the Woodward controller and successful completion of

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procedure 345V-E41-002-1S. The inspector reviewed the-l Woodward controller calibration data and the results of 34SV-E41-002-1S and verified that -this corrective -

action had been complete However, the LER

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incorrectly reported that HPCI was declared to be -

operable on December 9, 1988, at 1715 CST. Review of the. pump operability procedure and the shift supervisor's 109. indicated that the system was not tested and declared operable until December 10, 1988, at 0200 CST. Additional corrective . action involved r

counselling all I&C personnel and including this event

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'in I&C continuing training. 1The. inspector verified'

L the additional corrective action through review of I letter LR-MIC-002-0289 (dated February 13,1989)'and review of I&C Trainin Program Student Text media number IC-ST-89100-00 dated March 22,1989).

L Technical Specification 6.8.1.c requires that written l procedures be established, implemented, and maintained for the surveillance and test activitier of safety-related equipmen This matter is cons >6ered to be a violation of Technical Specification 6.8. However, this violation meets the' criteria in section V of the NRC Enforcement Policy for not issuing a Notice of Violation and, therefore. is not being cited. This matter, identified as NCY 321/89-12-01,

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l L is considered to be closed. Review of the LER is-also closed.

l Surveillance Procedures and Records (61700) Units 1 and 2 1. ^ i l " Surveillance records were reviewed to determine whether the surveillance *

of safety-related systems and components is being conducted in accordance with approved procedures as required by the technical specifications, the

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licensee's IST program, and the approved fire protection / prevention

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program. This inspection effort did not include the review of calibratio activitie The calibration of_ safety-related components was previously E addressed -in NRC Inspection Report Nos. 50-321/89-10 and 50-366/89-10 under NRC Inspection Procedure 56700.

l The inspector initially reviewed the licensee's surveillance data base to verify that surveillance have been performed at the required frequencies.

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In the cases of surveillance required on a "once per operating cycle,"

"once per 18 months," or "during cold shutdown" basis; the inspector

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confirmed that the last two surveillance had been performed at the I

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required frequenc In the cases of surveillance required on an "every three months," "once per 92 days," or " monthly" basis; the inspector

. confirmed that the last four surveillance had been performed at the required frequency. The surveillance requirements selected for review and the associated surveillance procedures are listed belo Surveillance Requirement Associated Procedure Unit 1 TS 4.3.C. SV-C11-001-15, Rev. O, " Control Rod Scram Testing" Unit 2 TS 4.1.6. V-C11-001-25, Rev. 1. " Scram Discharge Volume Isolation Valve Functional Test" Unit 1 TS Table 4.1-1, 345V-B21-001-15, Rev. 1, "MSIV Closure Item 10 Instrument Functional Test" Unit 2 TS Table 4.3.1-1, 34SV-C71-001-25, Rev. 3, " Turbine Stop Item 9 Valve Instrument Functional Test" Unit 1 TS 4.6.H. SV-B21-004-IS, Rev. 3 " Relief Valve i

Operability" Unit 2 TS 4.4.1. SV-B31-001-25, Rev. 2, " Recirculation Pump Discharge Valve Operability" Unit 1 TS 4.5.A. V-E21-002-15, Rev. 5, " Core Spray Valve Operability" Unit 2 TS 4.5. SV-E41-002-2S, llev. 6. "HPCI Pump Operability" Unit 1 TS 4.7.A. V-T48-003-IS, Rev. 2, " Post-LOCA e

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Functional Test" l Unit 2 TS 4.6.1. SV-E32-001-25, Rev. O, "MSIV Leakage

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Control System Valve Operability" Unit 1 TS 4.9.D.1(a) 57SV-C71-005-IS, Rev. 2, "RPS Power Monitor Functional Test and Calibration" Unit 2 TS 4.7.1. V-ECV-001-25, Rev. 0, " Monitoring River Bottom Conditions at the Intake Structure and River Stage Relationship" Appendix B. Section 2. SV-FPX-032-05, Rev. 0, " Automatic Sliding of FHA Fire Door Surveillance" Appendix B Section 2.1. SV-FPX-019-15, Rev. 1, " Penetration Seal of FHA Surveillance" ASME Section XI, Part IWV 345V-E11-002-15, Rev. 5, "RHR Valve Operability" ASME Section XI, Part IWV 345V-E21-002-25, Rev. 3, " Core Spray Valve Operability" ASME Section XI, Part IWV 34SV-E41-001-1S, Rev. 4, "HPCI Valve Operability" ass 1E Section XI, Part IWP 34SV-C41-002-25, Rev. 3, " Standby Liquid Control Pump Operability Test" ASME Section XI, Part IWP 34SV-P41-001-15, Rev. 1, " Plant Service Water Pump Operability" ASME Section XI, Part IWP 34SV-E11-004-25, Rev. 4, "RHR Service Water Pump Operability"

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The inspector also reviewed' selected -completed surveillance documentation for the previously . listed surveillance requirements. The inspector confirmed that in each case testing was in'conformance with the associated requirements, test results were properly reviewed, and acceptance criteria l- were met (or appropriate action was taken for items failing to meet the

! acceptance criteria). The specific surveillance records that were reviewed by the inspector are listed belo Procedure Date of Surveillance 345V-E32-001-25, "MSIV Leakage Control System 05/12/88 L

Valve Operability" 345V-C11-001-25, " Scram Discharge Volume 10/05/88 Isolation Valve Functional Test" 34SV-B21-004-15, " Relief Valve Operability" 12/11/88

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42SV-C11-001-IS, " Control Rod Scram Testing" 12/12/88 34SV-E11-002-15 "RHR Valve Operability" 12/21/88 34SV-E41-002-?.S, "HPCI Pump Operability" 12/23/88 34SV-C41-002-2S, " Standby Liquid Control 12/27/88 Pump Operability Test" 34SV-B31-001-25, " Recirculation Pump 12/29/88 Discharge Valve Operability" 34SV-E41-001-IS, "HPCI Valve Operability" 12/30/88 34SV-C71-001-25, " Turbine Stop Valve 03/05/89 Instrument Functional Test" 57SV-C71-005-1S, "RPS Power Monitor 03/12/89 Functional Test and Calibration 34SV-E21-002-1S, " Core Spray Valve Operability" 03/13/89 34SV-B21-001-15, "MSIV Closure Instrument 03/31/89 Functional Test" No violations or deviations were identified. Based on the review of the licensee's surveillance data base and of completed test documentation, the inspector concluded that the surveillance of safety-related systems and components is being conducted in accordance with the technical specifica-tions, the licensee's IST program, and the approved fire protection /

prevention program.

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l 1 Action on Previous Inspection Findings (92701) Unit 2 1 (Closed) URI 366/89-10-02, Installation of Non-Q Circuit Breakers in Safety-Related Applications (

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1989, that two apparently non-Q molded case circuit breakers had been installed in safety-related application The licensee had been conducting plant walkdowns in response to NRC Bulletin 88-10 at the time of this discovery. The subject circuit breakers were identified as Westinghouse Model HFB3110ML. Additional investigation has shown that the circuit breakers were procured as commercial grade items and were properly dedicated prior to in;tallatio The items were dedicated by inspection on March 29, 1985, with Material Inspection Request No.85-927. Additionally, the licensee determined that the EQ qualification of the involved MCC was maintained since the breakers were installed as like-for-like replacements, and the entire MCC was environmentally qualified as a unit. This determination was based on the provisions of Section C.6 in Regulatory Guide 1.89 Revision 1, June 1984. In summary, it was concluded that installa-tion of the subject circuit breakers did not in any way affect the operability of the MCC or any of its component Review of the URI is close (Closed) URI 366/89-10-04, Inadvertent Loss of Logic Power for Drywell Floor Drain and Equipment Drain Pumps This URI was opened subsequent to the inadvertent loss of logic power for the Unit 2 drywell floor and equipment drain sump pumps on June 14, 1989. The loss of logic power occurred when MCC 2R24-S017.was de-energized for PM. Investigation has shown that this event was caused by inadequate review of the MWO (2-89-01895) for the PM. The need for an LC0 was not identified during either the initiation or shift supervisor review Sections 4.3.6 and 8.5.5 of procedure 50AC-MNT-001-05, " Maintenance Program," require that MW0s be reviewed for LCO conditions. Investigation has also shown that the same individual conducted the initiation reviews. Although not prohibited by existing plant procedures, this practice precludes independent review during the initiation stages of MWO processing. Corrective action involved establishing the practice of having different individuals perform inif iation reviews and re-emphasizing to shif t supervisors the need tc closely examine MW0s that remove distribution panels and control panels from service. The inspector discussed these c9rrective actions with an Outages and Planning Department Superintendent on July 12, 1989.

l Technical Specification 6.8.1.a requires that written procedures be j established, implemented, and maintained covering the activities '

referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 9 in Appendix A of Regulatory Guide 1.33 .

recommends that maintenance that can affect the performance of j

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' safety-related equipment be properly preplanned and performed in accordance with written procedures or instructions. The failure to adequately review MWO 2-89-01895 as required by procedure 50AC-MNT-001-0S is a violation of Technical Specification 6.8. However, this violation meets the criteria specified in Section V of ,

the NRC Enforcement Policy for not issuing a Notice of Violation and, j

therefore, is not being cite The violation, identified as NCV i 366/89-12-02, is considered to be closed. Review of the URI is also close i

- ExitInterview(30703)

The inspection scope and findings were summarized on July 21, 1989, with those persons indicated in paragraph I above. Particular emphasis was placed on the two licensee-identified violations discussed in paragraphs 5 and 7.b. The strengths in licensee performance discussed in paragraphs 2 and 3 were also highlighted'. The licensee did not identify as proprietary-any of the material provided to or reviewed by the inspectors during this inspection. Dissenting connents were not received from the license <

Item Number Status Description / Reference Paragraph 321/89-12-01 Opened and NCV - Improper Calibration of 1 Closed HPCI Woodward Controller  :

(paragraph 5)

366/89-12-02 Opened and NCV - Inadvertent loss of Logic Closed Power for Drywell Floor Drain '

and Equipment Drain Pumps (paragraph 7.b)

366/89-10-02 Closed URI - Installation of Non-Q Circuit Breakers in Safety- i Related Applications (paragraph {

7.a) l i

366/89-10-04 Closed URI - Inadvertent loss of Logic l Power for Drywell Floor Drain j and Equipment Drain Pumps J>

(paragraph 7.b)

9. Acronyms and Abbreviations  !

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ASME - American Society of Mechanical Engineers Boiler and Pressure Vessel Code BWR - Boiling Water Reactor l CST -

Central Standard Time { l DC - Deficiency Card y DCR - Design Change Request (i ECCS - Emergency Core Cooling System i EHC - Electrohydraulic Control {

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f FPG - Emergency Procedure Guidelines EQ -

Environmental Qualification ESF -

Engineered Safety Feature FHA - Fire Hazards Analysis GE -

General Electric GPC - Georgia Power Company HPCI - High Pressure Coolant Injection I&C - Instrumentation and Control IST - Inservice Testin LC0 . Limiting Condition for Operation LER - Licensee Event Report LOCA - Loss of Coolant Accident LOSP - Loss of Off-Site Power MCC -

Motor Control Center MPL - Master Parts List MSIV - Main Steam Isolation Valve MWO - Maintenance Work Order NCV -

Non-Cited Violation NRC - Nuclear Regulatory Connission OSOS - On-Shift Operations Supervisor PM -

Preventive Maintenance PSTG - Plant Specific Technical Guidelines RCIC - Reactor Core Isolation Cooling RHR -

Residual Heat Removal RHRSW - Residual Heat Removal Service Water RO - Reactor Operator RPS - Reactor Protection System RPV -

Reactor Pressure Vessel RWCU - Reactor Water Cleanup SGTS - Standby Gas Treatment System SRO - Senior Reactor Operator STA -

Shift. Technical Advisor TS - Technical Specifications URI -

Unresolved Item

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