IR 05000321/1989027
| ML19332E145 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 11/16/1989 |
| From: | Brockman K, Menning J, Randy Musser NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19332E144 | List: |
| References | |
| 50-321-89-27, 50-366-89-27, NUDOCS 8912060281 | |
| Download: ML19332E145 (20) | |
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p , ' NUCLEAR REGULATORY COMMISSION - If[ o -: REGION 11 , , t g -[- 101 MARIETTA STREET.N.W.
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' ATLANTA, GEORGIA 30323 m J.... ~f: m . .. . , , Report Numbers: 50-321/89-27 and 50-366/89-27 i Licensee: Georgia Power Company.
s 'P.O. Box 1295 s Birmingham, AL 35201 Douket Numbers: 50-321 and 50-366 > License' Numbers: DPR-57 and NPF-5 Facility Name: Hatch Units 1 and 2 . .t Inspection Dates: Sep'. ember 23 - October 27, 1989-Inspection at Hatch site near Baxley, Georgia I // -/M/ ' Inspectors: m s Jo . Menning, Senio A esident Inspector Date signed , h //-/(-Pf
'_ _, m Ra all A. Musser, Resi46nt Inspector Date Signed' L Approved by: _2M erdu/ N- / A - 8 9 , K/nneth Brp6kman, Chief, Proiect Section 3B Date Signed ! , Mivision',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, Reactor Operator License Verification, Refueling Activities, and Action on-Previous Inspection Findings.
Results: One non-cited violation and three Inspector Followup Items (IFI) were identified during this reporting period. The NCV (paragraph 5) was for inadequate functional testing following the installation of - , post-LOCA radiation monitors. The first IFI (paragraph 6) related to administrative controls regarding the ability of the Operations Supervisor to determine the license status of the individuals on his shift.
The second IFI (paragraph 7) related to administrative , controls with regards to ensuring that only current procedure revisions are utilized.
The third IFI (paragraph 8.b) related to incorrect louver set points delineated in calibration procedure 57CP-CAL-180-2.
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< h ? i . ~ PersonsLContacted:. N $[ ' i J ' ' j {S i-1 Licensee; Employeesi-Q - - I*ChCoggin',-'TrainingLand=EmergencyPreparednessManager- ' "
- D.1 Davis,1 Manager General Support
"
- J. Fitzsimmons, Nuclear Security. Manager
m r " ,, ,.. '*P,pFornel, Maintenance Manager p" > . : 0A Fraser, Site Quality Assurance Manager - U n
- G. Goode,iEngineering; Support Manager 4 -
- M;.Googe, Outages and: Planning Manager .; -. J. f i: Lewis, Acting.0perations Manager-ig ,
- C. Moore, Assistant General Manager -fPlant Support
! %> y H.: Nix,lGeneralqManagerf-Nuclear Plant
~ I
- H. Sumner,1 Assist. ant General. Manager
. Plant-Operationsi - $, 4*S.1Tipps,; Nuclear.' Safety and; Compliance Manager ? b R. ' Zavadoski, Health Physics and-Chemistry Manager ' g s e . !0ther licens'ee ' employees contacted-included L technicians,-- operators, ' ' ' ~ mechanics,- security. force members:and-office personnel..
s , . n " " ' #" 'NRC= Resident Inspectors p ' ., ..J.
Menning_- ! , , , J '*R. Musser '
K , J t _ NRC: Management on site during inspection period: '
, "K.;Brockman,; Chief,7 Projectisection 3B, Division of Reactor Projects, RII-
B ' , a
- Atte'nded-exit interview i
f4 - . .
.~ Acronyms ?and initialisms-used throughout this report are listed in the-last. paragraph.
i ,~ n . 2.
- 0perational; Safety Verification (71707) Units 1 ~and 2
/Onit I continued to operate at power during this reporting period. Unit 2=
l remained in.the condenser retubing/ refueling: outage that commenced on ' e " , September 4, 1989.
The - reloading of the Unit 2 core commenced on-p- October:22,'1989.
. -.. . .-The-inspectors kept themselves informed on.a daily basis of the overall > ' plant status and any significant safety matters related to plant . operations. Daily discussions were held with plant management and various members of:the plant operating staff. The inspectors made frequent visits to the control room. Observations included control room manning, access ' . ? h
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, , . ' M . i . C .,. ' -control,. operator professionalism and attentiveness, adherence -to.
,,. procedures,Jadherence "too limiting conditions for operation, instrument- ' . ! readings, recorder J traces, Lannunciator alarms, -operability of E nuclear
. instrumentationiand - reactor protection. system channels,. availabilityiof' ! power _ sources, and operabili_ty.of the Safety. Parameter Display' system.
.
&, - These observationsalso, included log book' entries, tags' and-clearances on, i eq ui pment,'. temporary 3 alterations in-_effect, _ECCS _ system lineups,. 'n containment c integrity,s reactor mode switch position,- conformance with ' technicalf= specification:Esafety _ limits,;_ daily surveillances, iplant ' chemistry,- scram discharge Evolume valve positions, and l rod movement ' l a , controls. This inspection activity involved numerous informal discussions y with' operators.and their supervisors.
t The i operability? of - selected safety-related systems l was confirmed on, j ." essentially, 'a wee kly - basis. __ These' confirmations; involved the~ ~! v_erification-of. proper valve and-control switch-positioning, proper.
~ - circuit breaker and : fuse: olignment,- and,the operability of related ' instrumentation and1 support systems. Major components were also inspected - , - for_' Ll_eakage, proper. lubrication, cool ing._ water supply, and general . . condition. :0n October 2, 1989, the inspector confirmed the~ operability _of- . . the Unit 1 Core Spray system "A" loop.
Proper electrical, valve, and 4' switch alignments-were confirmed 'using Attachments 2 and 3 to procedure "34S0-E21-001-1S.
On October 13, 1989, the inspector confirmed the' . .. operability of the Unit 1 Jockey Pump system. Proper switch, breaker, and' , (valve 111neups; were confirmed using Attachments 5 and 6: to procedure.
" ' 34S0-E21-001-1S. - On 0ctober 16, 1989, the operability of the Unit 2 standby 11.iquidi control -(SLC) system was l confirmed.
Proper breaker, switch, Land valve lineups were verified using Attachments 2 and 3' to procedure 3450-C41-003-25. On October 18, 1989 thc operability of the J Unit 1 Reactor Core Isolation Cooling-(RCIC)-system was confirmed. -Proper switch, breaker, 'and valve lineups were verified. using ' Attachments 1, - 2,
- and-3, respectively, to' procedure 34S0-E51-001-IS.
. General. plant-tours were-conducted on, at least, a weekly basis. Portions , i of the control building, diesel. generator building, intake structure, , ~ ' R turbine building, reactor building, and outside areas were-toured.
.' Observations. included general plant / equipment conditions, fire - hazards, -fire alarms, fire extinguishing equipment, emergency lighting, fire - barri_ers, emergency equipment, control of ignition sources and flammable materials, and control of maintenance / surveillance activities in progress.
Radiation protection controls, the implementation of the-physical security , program, housekeeping conditions / cleanliness, the control of missile hazards, and instrumentation and alarms in the main control room were also
observed.
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r - f3 i 4t I-In;thefarea of! housekeeping, the following: discrepancies were ob' served by i %' ' the~. inspector: '
! J ' _' ~ On20ctober 2,1989, a significant amount; of debris was observed on
<-~ ~
- the floor-at elevation 8)' -in the Unit.1-reactor building's.-southeast-
'
lcorneriroom.- lThis condition was brought ~ to the attention of the- ' Y - Shift Supervisor.
' t On October ' 2, 1989, it was observed that an area posted as a l &v - contaminated area had not ~ been provided with a step of f pad or " receptacles for used items of protective-clothing. The contaminated
h_ carea was located in,the Unit I reactor-building. at location--158RFR10.
L* 1This ' condition was brought to the attention of _ a - health physi.cs i foreman.
I,' ' . The inspectors observed selected operations shif t turnover briefings to ,, ' " -confirm that al1< necessary information concerning the ' status of-plant --systems was being addressed. Each briefing was conducted by the oncoming - -050S.
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 safety were' generally stressed. The STAS discussed any recent procedure ' ' revisions ' that could have an impact on the attendees, The-inspectors ' attended? shif t turnover briefings on the following dates' and shifts: . September 27,.1989'- Day. October 16,1989 Day, October 22 - Day, and' , _0ctober 24, 1989 - Day.
, 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 down to verify that. clearance - b . tags-were in _. place and legible, and - that equipment was properly
positioned.
Equipment clearance program requirements are specified in - licensee procedure 30AC-OPS-001-05, " Control of Equipment Clearances and
- Tags." On September 29, 1989, Unit'1 equipmentTclearanceEl-89-1072 was walked down. This clearance was placed to isolate the standby service
' - water pump and to support maintenance on. the Unit 2 PSW system.
On October. 2,1989. Unit 2 equipment clearance 2-89-911 was walked down. This clearance was placed to support maintenance on the Unit 2 SLC system.
q ". .. Implementation of the licensee's sampling program - was reviewed by the - 'l ' inspector.
-This review involved observation of sampling activities l-(reactor coolant and tank sampling) and chemistry surveillance.
Related > records were also reviewed. During this inspection period, the inspector monitored the following activities. On September 29, 1989, the inspector ' observed the performance of the daily checks and observations of the .j instrumentation at'the meteorological towers, in accordance with procedure ' 62CI-0PS-010-0.
On October 4, 1989, the inspector observed the i . performance of a check of the Unit 1 reactor coolant conductivity, in accordance with procedures 62CH-SAM-030-OS and 60AC-HPX-010-0S and as specified by Technical Specification 4.6.F.2.a.1.a.
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,' u,:, - , g%,4:x,Q, y y 7 3 + ' ' . { g, , -4-r , ~ , y ~ . LThe licensee'.s' deficiency control system was reviewed to verify that the > system was functioning as intended.
Licensee procedure ~10AC-MGR-004-05, ' ." Deficiency Control-System," establishes requirements and responsibilities , for the preparation, processing, review,= and disposition of deficiency ' , > > - reporting documents. -This procedure applies to_'all-deficiencies affecting1 ' equipment,. procedures, or. personnel.
Deficiencies are reportedL on , Deficiency Cards.
OnL0ctober 17,-1989-, the inspector reviewed DCs that.
'had been generated the previous day. The inspector verified that DCs had been: prepared-as'_ required by the; control-ling procedure and that -several
deficiencies. that' were~ noted in the Shif t Supervisors' logs had been ! documented on DCs. More spe'cifically, it was varified that DC 1-89-4271 had been prepared _ to document a high-EHC filter differential pressure , condition--in Unit 1.. It.was also verified that DC 1-89-4287 had been - ' generated to document the -wetting down. of the "1B" emergency diesel generator following' failure of PSW valve-1P41-F403B, -On:0ctober 19, 1989, ' _ the. inspector also. reviewed recently prepared DCs and verified that P problems observed in the plant -had been properly documented.
The . , -inspector noted that DC 1-89-4308 had been prepared to document an invalid ' - "CRD Diagonal Oxygen Level Low" alarm.
It was also observed that DC 2-89-3326 _ had ;been generated to document that temperature recorder - 2T47-P627 was printing all points upscale.
' ' Selected __ portions of ;the containment isolation lineup were reviewed :to i 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 1 or power removal..was required), and inspection of piping upstream of the valves:for leakage-or leakage' paths. On September 26,.1989,-the-inspector reviewed-the following~ Unit' I containment isolation
valves: 1E21-F044A,- 1G11-F019, IG11-F020, IP33-F004, 1P33-F006, 11P33-F012,.1P33-F014,.1P41-F050, 1P42-F051, 1P42-F052, 1P70-F066, l1P70-F067,. - 1T48-F103, IT48-F104, IT48-F115, IT48-F116, IT.48-F118A,. 1T48-F1188,-and:1T48-F307. On September 29, 1989, the inspector reviewed the following Unit 1 containment isolation valves: =1G11-F003, IG11-F004, IP33-F002, 1P33-F010, IT48-F308, 1T48-F309, IT48-F310, IT48-F318, IT48-F319, 1T48-F320, IT48-F321, IT48-F322, 1T48-F324, IT48-F325, IT48-F326, IT48-F327, 1T48-F332A, IT48-F332B, 1T48-F333A, IT48-F333B, , -1T48-F334A, IT48-F334B, 1T48-F335A, 1T48-F335B, IT48-F338, and 1T48-F339.
' , . F No violations or deviations were identified.
,
3.
. Maintenance Obserntion (62703) Unit 1 ,. During the report period, the inspectors observed selected maintenance activities.
The observations included a review of 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, and adherence to the appropriate quality controls.
The primary
maintenance activities observed during this month are summarized below: ,
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, . Q: ; m, ,m , ' ^ Maintenance'Act'6ity ' ~ Date-7- N~ - ak Repaircof.ltheRodPosition'. 09/27/89: > , Indication Display,,in accordance c , , '" M withiMWO:1-89-4285' fqs , , . , %s lbt ; Replacement of an Exhaust Extension : 10/11/89' i%
- Gasket'on'the 10 Diesel Generator Exhaust Manifold, tin accordwce
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- with MWO.~1-89-4681
' c.e iDryingloffthe.1B-Diesel Generator,. 10/19/89 ' , in<accordance with: procedure % -525P-101789-R21-IS- - '
-- ' ' . No violationsor deviations were -identified, w 'W 4 ^. d T 1Surveill ncei esting Observations (61726) Unit 1 < .. >. h ' 'TheLinspectors observed-the performance of.' selected.surveillances. The ' ' observations. included a review of the proceduresEfor technical adequacy, > .conformancer to technical specifications, verification; of test instrument: , ' Ecalibration,i observation Lof 'all, or part,.of'.the actual surveillances,:
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- removal 1. from service: andL return to service of the. system or componentsL
' - af fected, Ea'nd J review :. of - the data - for acceptability based upon Uthe , ' L acceptance ' criteria. The primary: surveillance tests ^ observed during'this month are summarized below: . . , 1 Surveillance" Testing Activity Date
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(Reactor 18uilding Instrument Sumps-09/27/89' ' , y ' Isolation. Valves Exercise,-in > B accordance with; procedure' ~ L341T-T45-001-1S w , M ' ., . . 10/04/89
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.RCIC. Monthly Pump Operability, . + 'in:accordance with. procedure iv '34SV-E51-002-1S > w A ,.HPCI Monthly Pump Operability, 10/05/89 - P
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g-in accordance with procedure f- , 34SV-E41-002-1S: <
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Post Maintenance Testing and 10/20/89; <" Monthly Operability-Run of the , 181 Diesel Generator, in accordance '.< with procedu-as 575V-R43-001-0S fi 'and 34SV-R43-002-15 E ! yk, j . < j, e . ( f J b;2 '[
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- ' , - , !. !-Rg~ . Oii Oct6ber.4..1989, ~ during the ' performance of the RCIC Monthly. Pump ' c operabil_ ity Test,; conducted :in accordance with 34SV-E41-002-IS, (the.
' rW ' inspector _noted:a steam;1eak on valve IE51-F039. This_was brought to-the _ [p" - attention. of Lthe Unit 1 Shift Supervisor,lwho; subsequently informed ^the sinspectorithat1:the r condition; had.been previously-noted? and would -be .. repaired during1the_next system outage.
. I 10nl 0ctober 5, _1989,' _duri_ng. the performance ' of. the: HPCI Monthlyi Pump. _ F Operability Test, in accordance with 345V-E41-002-IS,.the inspectors'~notedi b a--steam leak'on valve IE41-F3055 and a leak coming from the top of check ~ - E ' valve IE41-F009. These. items were brought to the attention of the Unit'1' F Shif t-Supervisor-Subsequent to this notification,- the Shift Supervisor;= , . oinformed the inspectors that the _' leak on ~ valve IE41-F3055 had been- - = previously documented and that a deficiency card would be initiated to-effect.the repair of valve 1E41-F009, 'No.. violations or deviations were-identified.
. 5 '. . Reportable Occurrences-(90712 & 92700) Units 1 and'2 t . A1 number of ; LERs - were: reviewed for potential. generic impact, to_ detect
- trends, and to-determine whether corrective actions appeared appropriate.
- Events which were reported immediately were also reviewed as they occurred;
- to: determine that'. technical specifications were being met and that the public health and safety-were of utmost consideration.
I L nit:1:- 89-07.
Manufacturer's Error Renders Technical Specification V p Required Equipment-Inoperable This LER concerns inoperability of the post-LOCA-radiation-monitor recorders in Unit-1. The recorders were found to be incapable of recording the full-range a' of zero to-1E06 R/hr as required by-Section 3.2, Table-3.2-11, Item 12 of the. Unit 1 Technical Specifica-tions.
The. deficiency was discovered:by the licensee during the' performance of a six-month calibration- ' survei-11 ance. The root causes of the deficiency were determined to be a wiring error by the' vendor of. the ' . ' associated. radiation monitors and personnel error on y the part of the implementing engineer.
, - The monitors which drive the post-LOCA radiation )
recorders can be internally wired for any of several , , output voltages.
The monitors supplied to the licensee were wired incorrectly, in that the monitor output voltage range was incompatible with the l recorder input voltage range. The recorders had been j inoperable since their installation (on November 20, 1988).
However, the digital indication on the { t ! y .
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__ [? Jc: monitors; and' lthe as'sociated: annunciation..were! N . avai'lable forL control _ room-?personneliduring the time ! " that u the recorders 4 were inoperable. _ i The. post-LOCA-i " . radiation. monitors were o physical.ly '- inspected after.
% delivery at: the plant site.-_. However, 1such receipt-- a
c= p inspections 1 are ;not' intended? to.- detect functional . - deficiencies; such as 'the-internal swiring: error...T he -' ' , ~ post-installation ifunctional. test., developed L byi the.
- "a 3' . implementation engineer? was --inadequate.-in thatfit , failed to check the compatibility;of the input and: J-output : voltages of_ the: recorders a'nd -monitors,- d ' l-l' , -respectively.
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, ' -~Correcti~ve actions ~ i_nvolved notifying the vendor of.
the error, re-wiring the monitors in accordance with> ' - 4 vendor instructions, and incorporating-detai.ls of the
< event into the plant's. Engineering ~ Continuing Training >- program; The inspector reviewed related-'correspon-- ' ~
- dence -between the licensee and' vendor and the completed MW0s for. re-wiring ~ of.the monitors. Lescon:
si plan EC-IH-00762-10 that was taught in the Engineering:
_ e" Continuing Training. program during-the third q'uarter
of:1989 was.also reviewed.
The inspector concluded- . that corrective actions had been~ completed:'as intended.
l ' q " Criterion XI " Test Control," in Appendix B of.10'CFR ~ _ Part 50 requires <that testing required to-demonstrate y+ that structures, systems,. and components lwill perform satisfactorily in service be identified and performed.
This instance of inadequate ' post-installation testing ! + .i s a violation of Criterion. XI.
However, this.
violation meets the criteria in Section. V of the NRC - s Enforcement Policy. for not. issuing 1 a. N_otice of
- '_ Violation and, therefore, is not being cited.
This ' ' ' matter, identified' as NCV-50-321/89-27-01, is , ~ considered closed.. Review'of the LER.is also closed.
- f1' .t-Unit 2: 89-05 ~Feedwater Controller Failure Causes Reactor Scram on y Low Water Level , This LER concerns the Unit 2 automatic scram on l . September 3, 1989.
The events of this scram were
previously discussed in NRC Inspection Report Nos.
- 50-321/89-20 and 50-366/89-20.
Review of this LER is
closed.
One non-cited violation was identified.
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.: - , y . '[ , %g 6h Reactor Operator. O cense Verification'(41701,.'42400B, 42700, and_71707); Uni ts 01 Land '2-- .; p' Thi_sfinspection^ ef fort was 1 performed ^ to : verify ~ licensee ; methods.. for' - s
control of L the111 cense status. of reactorL operators - on fwatch.
The " - . , ' Lverification' involved : reviews of related administrative-controls. and - r , Jcontrol room records.
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- Review:of: current administrative controls revealed thatlindividu~ ls are a
assigned 'to - control: room - shif t _ duties by the Operations-Department's' . Master Scheduler, based upon.this person's knowledge of the license status' l offpersonnel. The ' Master Scheduler and Operations Department 1 management:
are.. promptly : notified by the Training Department of license status ' > -changes,;.as, required by:13ection 7.3,4.2 of ; licensee procedure
_.
- ^ -72TR-TRN-002-OS,.. " License Requalification - Training Program."
~ Additionally,. the Training. Department provides the Operations Department with a current ; status of licensed personnel on a quarterly basis.
' .However,~ this quarterly status report isl neither updated continuously nor.
. , _provided to Jon-duty ; operations shift supervision..Since the Master- . , Scheduler is relied upon.to only assign qualified individuals, on-duty; ' operations shif t supervision: is not provided with the current license status of potential watch standers.
~ ' Control " room operator L logs _were _ reviewed to - determine ifc temporarily? di squali fied 1 individual s 1have aindeed been -restricted from performing licensed duties. during _ their periods of; disqualification.
More > , ' - specifically,:the inspector selected several licensed individuals who were recently designated as inactive by virtue of? their performance in the' , requalificat' ion program, and confirmed that these individuals did. not . perform' licensed duties during the' time periods that they-were considered - inactive.
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The - inspectorL concluded that the-licensee's existing administrative controls wo_ul d, generally, ' provide for prompt adjustment of' shif t ' schedules. following a disqualifying event.
However, the controls appear - to be; weak in several areas. For instance, delays in schedule adjustment could occur.if key management people were unavailable.
Additionally, the controls do not clearly provide.for defense in depth against unintentional or willful assumption' of licensed duties by an unqualifled individual.
More specifically, the controls do not extend to licensed individuals or to, on-duty operations shift supervision.
The inspector observed ' that ' operations shift personnel do currently sign in on a roster sheet prior to assuming duties. However, this sheet is not part of any plant procedure,
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and is not used. to provide certification, on an individual basis, of L qualification to perform licensed duties.
The inspector reviewed his assessments of existing administrative control
weaknesses with representatives of the Operations and Training
Departments.
The licensee subsequently informed the inspector that ~ provisions.would be made to allow on-duty operations shif t supervision to _ _.
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accessicomputer-baseditraining filesj and thereby Lverify currentilicense - stat'us; _ (As =part 1of this fef fort, ' procedural _ requirements wouldi be, w developed to cover areas such as control-ofJaccess to.the files,'frequencyE cAll of: andE responsibilitiesEfor status l verifications, and the updatingLof: i files.='The 111censee alsoL indicated 'that x the feasibility _ of, having s
-individuals..~ certify llqua'lification L to perform zlicensed duties would be - .
- l evaluated. PendingLeompletion-of the. licensee's actions _and review by the inspector,J this ; matter will be tracked _ as IFI 50-321,366/89-27-02 - Reactor < + - Operator Lice ^nse Verification.
'One:IFI-was-identified.
7.
Refueling Activities (60710) Unit 2 y --This! inspection ~ effort was performed to determine if refueling-activities , were1being controlled and conducted as required by TS and tapproved '
'm - procedures t ~ The ' ef fort was ' focussed on activities which occurred during " the core reload for the ongoing Unit 2 outage, ~The inspecto reviewed the licensees' fuel handling procedure-and the, requirements specified in--the ., UnitT2sTS. Additionally,.the inspector observed fuel handling during two--
different shifts.
Oq Prior L to' Jcore J -loading,- the-inspector reviewed the fuel. movement' i . , ' prerequisites. delineated ini Attachment 2 - of procedure-42FH-ERP-014-0S,- '! Fuel Movement Operation." - The inspector verified-several of the-items ' -following-the licensees' performance of the attachment.
The verification-
- included the;following items:
(1) The reactor mode switch was verified;to l be locked Lin the REFUEL position with the key removed, (2) The HP.
~ ' Department-was notified that access to the' drywell must be restricted to ' < s the 156-foot elevation and below, (3) The removal of the SRM shorting links,EandL(4) The-reactor water level and the fuel pool level is at least 123 feet:over the top of the irradiated fuel. =It was not evident to the
w % inspector how it_could be determined that~23 feet of water was present in ~ ~ - the spent fuel pool as ' required by TS _ 3/4.9.10.
When the. inspector expressed -this concern to-the Shif t Supervisor, the response was thattas
- 4 long as water was over-flowing into the skimmer surge tank, 23-feet of water (over the irradiated fuel) was present in the spent fuel pool. This matter was further pursued with plant engineering personnel who were able
- - to. demonstrate, :with plant drawings, that, -indeed, if water were over-flowing into the skimmer surge tank, z23. feet of -water (over the l
irradiated fuel) was present in the spent fuel pool.
During these.
- ' discussions, the Assistant General Manager-Plant Operations informed the-inspectbr that ~ a DCR was in progress to provide a means of level
indication in the spent fuel pool. The level indicator was installed that l ' , same day.
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The inspector ,7G immedi'a'tely-informed the Shift-Supervisor, who in turn suspended all? fuel.
. [p ~ earlier.
movemento operations..Af review of _the _ procedureL (latest revision)-
indicated that the change had been approved.and' made ef fective two days - - .The licensee performed a "line for.'line"' comparison of the two E
. procedures and determined that the procedures were essentially the same, , lwith the only -dif ferences being editorial; in nature. : Following.this F review and the'reperformance of the prerequisite sheet, fuel movement'was _ . resumed. - The: inspector -expressed a concern to licensee management in the ! < areal-of procedure control.
The' licensee performed a pre _liminary - , investigationfinto the problem and is in 'the process of determining a ' ';p method' of precluding the recurrence of thi's situation. Pending completion h . of the" licensee's actions and review by the inspector, this matter will be tracked as IFI 50-321,366/89-27-03 - Methodology - for ensuring : that.the proper procedure revision is-utilized.
During the inspection, the inspector observed portions of two-shif ts of fuel handling operations. The refueling / fuel movement crew consistsLof an SRO, R0 (hoist; operator),. and, a reactor engineer.
These persons were - constantly:on o the refueling. bridge during any fuel. movement _(the reactor- > -
s engineer leaves the bridge momentarily to update the core and fuel pool status boards and fuel movement sheets). Fuel movements were performed as specified on the fuel movement sheets. ' The fuel _ movement 1 sheets specify ' the' order in which the core-is to be loaded, the location of the fuel assemblies.in the' fuel pool, the serial number of each assembly, the core . location /in which the assembly is to be inserted, and the orientation at which the bundle'is to-be:placed into the core. Proper bundle orientation is achieved by installing the bundle with its channel fastener pointed - toward the compass direction (NE, SE, SW, and NW). specified in the , . - procedure.
- , o Ouring'. the performance of fuel movement, the SRO on the refueling. bridge is in constant communication with the control room. The SR0 apprises.the-control room of all initiations and completions of. lifts over the core and fuel. pool. Additionally, as a backup to the reactor engineer, the SR0 a maintains an unofficial copy of the core map and colors in each core j position upon the seating of each fuel bundle in the core.
The operator in--the control room monitors fuel loading with an additional core map so _ - that shif t personnel are continuously aware of the core status. During j the' periods. of fuel movement observed by the inspector, it was observed
- 4 that the fuel movement / core loading process was conducted in a very
".. ~n " professional manner.
All personnel were noted to be quite knowledgeable of the processes involved with fuel handling which contributed to the smooth conduct of the operation.
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' .- , , While performing fuel-movement observations, the inspector observed the manner in which the licensee controls foreign objects from entering the- ., open reactor ' vessel.
All potentially loose objects on the refueling , ' bridge are fastened either. to personnel or to the bridge.. Items such as binoculars are tied off to the' bridge to allow for use, and at the same _ time _ provide protection against -the possibility of dropping the item.
. Additionally, items of - protective clothing (such as rubber shoes and . gloves) are taped to the individual to preclude their inadvertent removal.
'The inspector believes, however, that the program could be further enhanced with additional controls.
The removal of all items of jewelry and the emptying - of pockets would further reduce-the possibility of foreign objects being introduced into the open vessel. In discussion with plant QA personnel.the inspector was informed of a weakness identified by
' the licensee. A QA Audit Item has been issued stating that tool control
' procedures were not being followed when work was being performed on the refueling bridge. The inspector will monitor the licensees' progress in , correcting this discrepancy.
One IFI was identified.
8.
Action on Previous Inspection Findings (92702) Units 1 and 2 a.
(Closed) Violations: (51-321/86-35-02 and 50-366/86-35-03) EQ Documentation for States Company Terminal Block Inadequate and Okonite Cables and 'plices and (50-321/86-35-03 and 50-366/86-35-04) EQ Docuentation for Rosemount Transmitter's Accuracy During Accident Condition Not Complete.
(Closed) Unresolved Item 50-321,366/88-20-01, Use of Taped Splices in Instrument Circuits.
. The NRC inspector reviewed the information included in a memorandum from G. Lainas, NRR, to A. Gibson, Region II, dated September 20, 1989, which transmitted NRR's safety evaluation of taped cable splices at plant E. I. Hatch Units 1 and 2.
The NRR staff concluded in this memorandum that the licensee had adequately demonstrated qualification for the Okonite tape splices used in certain EQ circuits outside primary containment. The staff also concluded that moisture intrusion would not occur in the cable splices as used in .the plant Hatch applications and that the potential leakage currents from the taped cable splice configurations used for 'the selected transmitter circuits specified are negligible.
This completes the resolution of concerns on States Company terminal blocks and Rosemont transmitters which were left open in Inspection Report 88-20.
All conclusions are based on review of the information provided by the licensee during NRC Inspection 88-20. These items are now considered to be closed, and no further action by the licensee is required.
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- . , > , . y-A_ 'bu (Closed) Violation :50-321,366/88-17-01,. Failure to:: Adequately-. gv e'
- Establishiand cImplement Diese_1l Generator Building Ventilation System; Procedures'
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- This violation concerned three examp~lesHof failure. to adequately establish and' implement' diesel-generator building Lventilation system w
. Ch procedures 34S0-X41-001-IN and J 3450-X41-001-2S.. 'In the first HT _ 'examplepthe system _ operating procedure. for. UnitL1 was' not designated ' s> as' safety-related while; the Unitc2 procedure :was.
In - the ' second- , ""
- example, the Unit 1 Land Unit 2: procedures ( required verification: of
- differentitemperature: settings for the IB (swing)' diesel exhaustifan y-thermostats. Additionally, < the thermostat : settings for all' of the: J
- Unit cl. diesel, generatorfroom'.s - axhaust f ans and two
- of( the heaters y
'were1not in agreement: with-- the plant-design _ data - referenced on? " Y - P&ID H-12619, : Revision' 5.
The third example _ of_.this? violation ' involved ' the failureD to align the 1B and 2C' diesel generator. oil' .storagezroom exhaust fans a~nd the 2C: battery exhaust fans _'per the ',, applicable] procedures.--- ' "
- The_ inspector reviewed the licensee's letter of response datedi
.AugustL22, 1988. In its' response, the' licensee determined that' the ' y - rootTcausesrof 1the. violation were inadequate procedureireview and : , f personne1 error,c and: that -a contributing factor Lmay have been-- an
- incorrect > plant drawing.- As a result'of the violation, root causes, and contributing factor, the;following short-term corrective / actions; were taken by;the) licensee and verified by the inspectori g
$:A ~- Four1ABNs (88_-372, 88-571, 88-701, and 88-914) were issued-to - s correct: the thermostat settings-on P&ID'12619. ABNs88-877 and: ' ~- .~88-1045 were also issued against P&ID.12619 to show flow switch ~~g.
. MPL. numbers on the diesel layout and elementary drawings.
, - Via SRO:changeL(temporary change) 88-772, the licensee initially '~ - _ revised procedures: -34SO-X41-001-1N and -34S0-X41-001-2S to temporarily. reflect _ the corrected thermostat settings, per ABN-372.
The thermostats were also reset, as required. by the : revised procedures and the plant. drawing..~ This was subsequently.
changed as a result of additional corrective actions.
IE On June 10, 1988, the fan switches were realigned, as required - -- by'the system operating procedures.
- Procedure -10AC-MGR-003-05, " Preparation and Contro'l - of P rocedu re s,'.' was' revised to require Nuclear Safety ~ and , Compliance to provide a' written justification for each revised l ' (except' cancellations) and new procedure classified as ! non-safety-related. This written justification becomes part of .l' the permanent history of the procedure maintained by document , control.
If justification for non-safety-related can not be i provided, Nuclear Safety and Compliance ensures the classification is changed to safety-related prior to issuance of , the-revised /new procedure.
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W;J. JP ' cW p:%i" 131 , < F . y,.. L ('F Th'e classification of' procedure i34S0-X41-001-IN= was - changed to ~-> . safety-related (34S0-X41-001-1S) <This.' revision was ; ef fectivet on October 211 1988.
o . 2 fprogram-to monitor. thermostat ' settings? and -'controlE switch: , positions 1 atT least ~ weekly for f approximately two imonths to
' - ' . identify recurring problems: and their causes was established by.
(the. issuance of L Standing. Order 10-0PS-01-08883 on _ August.18,:
.g " 1988.n This program began on August'23,/1988,Jand was;termilnated Eon OctoberJ12,~1988. ~ ' ' Af ter zissuance cof-the licensee response, _ dated _ August 22,-1988, the- . following supplemental; corrective actions 'were deemed necessary by , thell_ _icen see; ~ [ - -' Form ; ' 0PS-0378, " Diesel Building Log," in ' procedure ~
34GO-0PS-031-15, " Daily Outside: Rounds," was-revised to ' require , ? - daily. verification of f HVAC control' switch positions.
This, revision,- which was effecti.ve' on November 19,-1988,- references 'f a . procedures 34S0-X41-001-15 and' 34S0-X41-001-2S' for - appropriate ' , , , y control switch positions, ' '- A Maintenance. Training Bulletin on diesel 1 generator building: -: 'HVAC:. control switch.' operation. was: sent :to - the. field' on - > o . December! 12, 1988, -As a result of x recurring _ problems. identified by the.two -month i - - monitoring-program locking. plastic boxe's = weret placed over the - thermostats and' switches,:per MW0:1-88-5584, which was completed
- on January 8; 1989.
M ' ' " Also asca result; of _ recurring problems identified by. the' two -- ' -month. monitoring program -- - procedures l 34SO-X41-001-15 'and 3450-X41-001-25 were revised _to remove;the requirement to-check - r 1r, thermostat settings.
Apparently, the. settings were changed during thermostat -calibration.
The calibration procedures, ' -57CP-CAL-060-IS and 57CP-CAL-180-2, are now the only: procedures - used to verify?the thermostat settings.
g , a <. Temporary changes 89-216 and 89-215, respectively, were issued ' - W against calibration procedures 57CP-CAL-060-1S, revision 2, dated February 10,1989, and 57CP-CAL-180-2, revision 0, dated July 22,_1985 in order to ensure that the thermostat set points j in these procedures matched the thermostat operating ranges in I w, the corrected P&IO, i ? { .;
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ga*i.*' 14= " y ' ' . The-inspectos verified that i.he~ revision to form.0PS-0378, '" Diesel Building Log;" in procedure 34GO-0PS-031-IS, " Daily Outside Rounds," included al.1. of L the ; appropriate panels for. each diesel ' generator.
'
- The-inspector'also verified that a Maintenance Training Bulletin: on=
~ " diesel; generator bui_iding HVAC control switch operation was sent to Lthe: field) and ' that-locking - plastic -boxes u were placed; over the:
- thermostats and, switches.
- As a result of the licensee's decision to remove the verification ofL thermostatL.settingsn from the system operating procedures,- the
- inspector; reviewed - the calibration procedures and compared the
'. thermostat set-_ points used in these-procedures = with the-design data
- referenced.in'the corrected P&ID. 'In two cases, the inspectorEnoted that set points-. referenced in procedure 57CP-CAL-180-2 did not match-thee operating ' ranges specified-in 'P&ID 12619f.
This procedure; ' . incorrectly specified' that generato'r room 2A louver 2A (2X41-N012A) g' and. generator room 2C louver 2A (2X41-N0128) were to close; at -84 F { .and.open at 80 F in lieu of closing at 80rF and opening at 76'F, as spec _if.ied in the corrected P&ID.
'At the higher - temperatures specified in the procedure, these small. louvers would have opened at-the same: time as the large louvers instead of before, as specified in
- the FSAR. This wa's brought to the attention of the I&C foreman and Lthe. cognizant : system engineer.
The system engineer informed 1the-
- inspectorc that the recently revised procedure was in the validation process 'and ;that~ the set points would be corrected before the-new revisio'n
- became effective. Pending completion -' of - the 111censee's
'
actionsland review by the inspector,.this matter will be tracked as _ IFI :50-366/89-27-04 - - Incorrect Louver Set Points in Calibration Procedure-57CP-CAL-180-2.
JAdditionally, the inspector compared the current Unit 1 and 2 diesel
- generator-building ventilation system operating procedures
< '(34S0-X41-001-IS, revision 2, editorial change 1, effective May 27, 1989, and 3450-X41-001-2S,. revision 1, editorial change 1, January 27,_ 1989)' to ensure that the ~ procedures were-uniform with respect _to each diesel generator and -to ensure that there were no
- discrepancies-with regard to the IB (swing) diesel, which ' was addressed in both procedures.
The inspector noted that the system line-up portior, of the Unit 1 procedure called for the diesel generator louver, diesel generator battery room louver, and switchgear. room louver switches to be in the automatic position, and the system line-up portion of the Unit 2 procedure called for these switches -to be in the closed position.
Additionally, the system m line-up portion of these procedures called for the Unit 1 generator oil room louver switches to be in the open position and the Unit 2 switches, including the 18 diesel generator, to be in - the closed position.
These discrepancies were corrected in the startup portion ,
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- switches 1were 'positioped as. required?in_. the1startup portion ~ of.the-g;f
- procedures. Numerous labelling' discrepancies infthe Uni _t 2 procedure f
(ie, diesel generator-2A room-fans'2Al,:2A2,-.and-2A3'versus 2A,L2B, R and._2C).andia - few 'labellingidiscrepancies in _ theLVnit 1 procedure
' W (ie, switchgear.1E room _ louver.1Al versus 'IX41-C007A)- were noted.
_ , l3 ~ The: Unit 2 procedure also referenced a generator. room IB. CO-2 - purge.
' . switch which did not exist'on panel' 2H21-P261Lin'switchgear room: 2F.
. L .This switch is located on panel H21-P261 in switchgear. room IF_ and isL p' addressed in the - Unit 1 procedures - The -inspector broughtithese - -
- discrepancies to the' attention _ of the shif t supervisor who; informed the1 inspector;t. hat the startup portion of the procedures <is used for--
i verification.during;the performance of the daily rounds-procedure.
- _The shif t1 supervisor also informed thelinspector that revisions 3 and p 2-of the Unit 1 and 2 procedures, respectively, would' correct these u - discrepancies-and that these-- revisions Twere in the validation '_ process. Theiinspector verified. that-the. revised procedures <had been: l ' - approved; for ' validation on August 21, 1989, but. were _ not 'yet , x -- e f f ecti.ve'.__ The inspector also reviewed the Lnon-validated procedure - y . e.
revisions and. verified that-they were uniform with' respect' to each '
E die. sell generator, that there were no discrepancies withlrespect. to - theJ18 (swing)' diesel generator due to the fact that it:was now only, a _ h~~'~ addressed in1the Unit 1 procedure, and that the'~ l'abelling di scre- .- p* pancies were corrected.
Review of this vio1"*fon is-closed, j
This violation was also referenced in, para ' d(2)(a) of othe ) z . safety. system functional inspection report ( 166/89-08) dated.
,= ,,~ . August 19, 1989.
a
b c.
'(Closed) Deviation 50-321,366/88-17-02, Failure to Periodically Test - L _ Diesel Generator Building Ventilation System Thermostats and Dampers ", The inspector revieweo the licensee's letter.of response dated' August
22, 1969. Corrective action involved.the assignment of a calibration' l , Y frequency for the thermostat controls on the I&C program and: the n . development and issuance of a procedure to test thermostat and damper
l operation on.- a periodic basis.
In its response,.the licensee j ' committed' to issue' this procedure on December 15, ~1988.
The-j O inspector _ verified that a 36-month calibration frequency ~ had been j assigned on the<I&C calibration program in procedures 57CP-CAL-060-IS.
- j and-57CP-CAL-180-2 and that procedures 57IT-X41,001-1S and
"
, 571T-X41-001-2S had been developed for the performance of functional ! L-testing of the thermostats and timers controlling the diesel ! I generator building heating and ventilation.' Procedures 57IT-X41-001-1S and 2S were approved and issued for validation on December 15, 1988.
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p I ;-- ,v; - , . ( . J.=',
, This deviation was referenced as a continued ares of weakness in the- . licensee's emergency diesel generator HVAC surveillance program in paragraph 4.d(2)(a) of -the safety system functional inspection report (50-321,366/89-08 dated August 19, 1989), in that procedures 57IT-X41-001-IS and 57IT-X41-001-2S had not yet been validated and . testing - had not yet been performed.
After this inspection, the licensee issued a letter- (HL-267, 02052) dated July 7, 1989, documenting safety system function-inspection response commitments.
Commitment 7, issues N-1038 and N-1079, of this response stated that the procedure -upgrade program versions of procedures 571T-X41-001-IS and 571T-X41-001-2S were in the validation process and would be made effective by September 30, 1989. The inspector verified' that these procedures had been validated and had become effective on ' September 15, 1989.
Review of this deviation is c1csed.
One IFI was identified.
'9.
Exit Interview (30703) The inspection scope and findings were summarized on October 27,^1989, .: with those persons-indicated in paragraph I above.
The licensee did not
- !
-. identify as proprietary any of the material provided to or reviewed by the i inspector (s) during this inspection.
Dissenting comments were not received from the licensee.
u-Item Number Status Description / Reference Paragraph 321/86-35-02 Closed VIOLATION - EQ Documentation for 366/86-35-03 States Company Terminal Block Inadequate and Okonite Cables and Splices (paragraph 8.a) 321/86-35-03 Closed VIOLATION - EQ Documentation for 366/86-35-04 Rosemount Transmitter's Accuracy During Accident Condition Not Complete (paragraph 8.a) 321,366/88-17-01 Closed VIOLATION - Failure to Adequately Establish and Implement Diesel Generator Building Ventilation System Procedures (paragraph 8.b) 321/89-27-01 Opened and NCV - Inadequate Testing of Post-Closed LOCA Radiation Monitors (paragraph 5) - e- .-,,,_ y y .- _ - -
, - _ _ _ _ . > - a,. f **
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-* * if L 321,366/88-17-02 Closed DEVIATION - Failure to Periodi- . cally Test Diesel Generator > [ Building Ventilation System , Thermostats and Jampers (para- ' , graph 8.c) 321,366/f,8-20-01 Closed URI - Use of Taped Splices in Instrument Circuits (para- { graph S.8) i 321,366/89-27-02 Opened IFI - Reactor Operator License Verification (paragraph 6) l 321,366/89-27-03 Opened IFI - Methodology for Ensuring that the Proper Procedure Revision is Utilized (paragraph 7) 366/89-27-04 Opened IFI - Incorrect Louver Set Points in Calibration Procedure 57CP-CAL-180-2 (paragraph 8.b) 10. Acronyms and Abbreviations , ABN As-Built Notice - CFR Code of Federal Regulations i CRD Control Rod Drive . - ' DC Deficiency Card - Design Change Request DCR - ECCS'- Emergency Core Cooling System EHC Electro-Hydraulic Contr.1 - Environmental Osalifications EQ - ! ESF Engineered Safe.ty Feature - i FSAR - Final Safety Analysis Report l HP Health Physics - HPCI - High Pressure Coolant Injection System HVAC - Heating, Vent 11rtion and Air Conditioning , Instrumentation and Control I&C - Inspector Followup Item IFI - Licensee Event Report I LER - LOCA - Loss of Coolant Accident Maintenance Work Order MWO - MPL Master Parts List - Non-Cited Violation NCV - L NE Northeast - NW Northwest - 050S - On-Shift Operations Supervisor P&ID - Piping and Instrumentation Diagram l L i I i
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