IR 05000321/1992029
| ML20125E469 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/01/1992 |
| From: | Christnot E, Skinner P, Wert L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20125E449 | List: |
| References | |
| 50-321-92-29, 50-366-92-29, NUDOCS 9212170067 | |
| Download: ML20125E469 (20) | |
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W % UtvliED 37 At ES j
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kn NUCLEAR nEGULATORY COMMI6SION REGION 18
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- $ 101 MARIE TT A S T HE E'. , N t ATLANTA, CLORGI A 3032
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Report Nos.: 50-321/92-29 and 50-366/92-29
- Licensee
- Georgia Power Company
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P.O. Box 1295 Birmingham, AL 35201 l
Docket Nos.: 50-321 and 50-366 License Nos.: OPR-57 and NPF-5 Facility Name: - Hatch Nuclear Plant
- Inspection Conducted
- October 11 - November 7, 1992-
! -Inspectors: ,ml a M n///&
1 . . Wert, Jr.f/ Sr. Resident Inspector Date~
[ M n / W ,--( M al.lw Date
E'.F.fhistpot,Residft' Inspector i
Approved by: &d / _ /2M92 Pierce H. Skinner, Chief Date
! Project Section 38 )
- Division of Reactor Projects L
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- SUMMARY
Scope: This routine, announced inspection involved inspection on-site in j the areas of operations, surveillance testing, maintenance activities including IB emergency diesel generator work, refueling
! activities, review of non-conforming Unit 2 drywell penetrations,
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and review of open items.
5 Results: One noncited violation was identified involving numerous Unit 2 spare drywell penetrations which were not in conformance with
- - American Society of Mechanical Engineers code requirement This
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, issue was identified by the 1icensee. Noncode caps had been installed on the spare penetrations since the construction phase
- containment integrity-test. (NCV 50-366/92-29-01
- Non-conforming j . Spare Primary Containment. Penetrations, paragraph 6)
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l The inspectors noted that-several problems occurred during-maintenance activities on the:IB diesel generator. Maintenance-3 personnel were not fully aware of some_ aspects of the speed sensor t and the associated microswitch tripping device.- Additionally, it
- . was identified-that some_ personnel were not knowledgeable
regarding details of the_ start logic circuitry. It was not t understood which portions of the circuitry were. actuated during different testing procedures. The speed sensor problems were .
-9212170067 921202 PDR ADOCK 05000321
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2 initially identified as a result of diesel generator testin The appropriate Technical Specification Limiting Conditions for Operation were entered and complied with during the activitie (Paragraph 4b)
A review of the licensee's actions in regards to Violation i 321,366/91-06-01: Failure to Perform Physical Inventories of Special Nuclear Material, was conducte The inspectors concluded ;
that the corrective actions, while in accordance with the documented response to the violation, were not as thorough as expected. (Paragraph 7)
The inspectors identified a problem involving the screenwash systems for the service water intake screens which had not been noted by the plant equipment operators. The condition permitted small debris to enter the service water pump suction area of the intake structure. While no systems were rendered inoperable, a potential for degradation of the service water systems existe (Paragraph 2b)
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REPORT DETAILS Persons Contacted Licensee Employees J. Betsill, Unit 2 Operations Superintendent C. Coggin, Training and Emergency Preparedness Manager D. Davis, Plant Administration Manager
- P. Fornel, Maintenance Manager
- 0. Fraser, Safety Audit and Engineering Review Supervisor
- G. Goode, Engineering Support Manager
- J. Hammonds, Regulatory Compliance Supervisor W. Kirkley, Health Physics and Chemistry Manager
- J. Lewis, Operations Manager
- C, Moore, Assistant General Manager - Plant Support
- D. Read, Assistant General Manager - Plant Operations
- P. Roberts, Acting Outages and Planning Manager
- K. Robuck, Manager, Modifications and Maintenance Support
- H. Sumner, General Manager - Nuclear Plant
- J. Thompson, Nuclear Security Manager
- S. Tipps, Nuclear Safety and Cnmpliance Manager
- P. Wells, Unit 1 Operations Superintendent Other licensee employees contacted included technicians, operators, mechanics, security force members and staff personne NRC Resident inspectors
- L. Wert
- E. Christnot NRC inspectors who provided onsite inspection assistance during this period:
R. Musser, Project Engineer, Region 11 B. Holbrook, Operator Licensing Examiner, Region 11 D. Seymour, Acting Prcject Engineer, Section 3B, Region 11
Attended exit interview Acronyms and abbreviations used throughout this report are listed in the last paragrap . Plant Operations (71707) Operational Status Unit 1 operated at power for the entire reporting period. Unit 2
' continued in its tenth refueling outage with significant modifications, maintenance inspections and fuel movement
> activities in progress. Among the inodifications were the installation of a torus hardened vent, upgraded battery chargers,
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replacement of the HPCI test valve, installation of digital feed water and recirculation pump control systems, and preliminary upgrade work on the IB EDG. The maintenance activities included the main turbine work, condensate pump re) airs, valve testing, and preparations for the ILRT. The licensee lad commenced the IL.lT at the end of the reporting perio The inspectors reviewed plant operations throughout the reporting period to verify conformance with regulatory requirements, TSs, and administrative controls. Control room logs, shift turnover records, temporary modification logs, LCO logs and equipment clearance records were reviewed routinely. Olscussions were conducted with plant operations, maintenance, chemistry, health physics, I&C, and NSAC personne Activities within the control rooms.were monitored on an almost daily basis. Inspections were conducted on day and on night shifts, during weekdays and on weekends.= Observations included control room manning, access control, operator professionalism and attentiveness, and adherence to procedures. In general, the inspectors observed that CR personnel placed an increased emphasis on procedural adherence. During several of the outage testing activities, prc.sdural changes were processed to correct problems with the procedures. Instrument readings, recorder-traces, annunciator alarms, operability nf nuclear instrumentation and reactor protection system channels, availability of power sources, and operability of the Safety Parameter Display System were monitore Control Room observations also included CCCS. system lineups, containment integrity, reactor. mode switch position, scram discharge volume valve positions, and rod movement control Numerous informal discussions were conducted with the operators and their supervisors. Some inspections were made during shift change in order to evaluate shift turnover performance. Actions observed were conducted as required by the licensee's administrative procedures. The complement of licensed ' personnel on ecch shift met or exceeded the requirements of T Several active safety-related equipment clearances were reviewed c
to confirm that they were properly prepared and executed.-
Applicable circuit breakers, switches, and valves.were walked down to verify that clearance tags were in place and legible and that equipment was properly positioned. Equipment clearance program requirements are specified in licensee procedure.30AC-0PS-001-OS, p Coctrol of Equipment Clearances and Tags. No major discrepancies
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were identified. During a routine tour of.the Unit-2_ torus area, 4 --
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the inspectors identified that valve 2P52-F329 was in the open position and had a clearance tag requiring it-to be shut. 2P52-F329 is a 1/2 inch instrument air-isolation valve to 2G11-F00 It has a knife switch-type handle which apparently was inadvertently bumped during maintenance activities. The valve is located inside the-inner catwalk area in a cramped area. The Unit 2 shift supervisor was' informed and the valve was restored to
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proper position. The inspectors concluded that the safety significance of this valve being out of position was minima Selected portions of the containment isolation lineup were reviewed to 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 of the valves for leakage or leakage path Selected portions of the plant service water system lineup were revievM to confirm that the-lineup was correct to support ongoing EDG tw+ . This included examinations of the standoy diesel service watecr pump which is a dedicated cooling water pump for the IB (swing) EDG. The review included verification of proper
< valve positioning, motor cooling water, and pump seal water
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availability. A small (dripping) leak was .ated on a bellows in i the PSW discharge piping from the IB diesel generator.- This item
! had been previously identified by the licensee and was corrected i prior to the end of the report period.
l Thc inspectors completed a survey. addressing the licensee's
, quality assurance (SAER) and quality control activities. The i survey was directed by regional management and included information involving both the corporate and onsite organizations.
' Review of Issues identified During Inspection Tours
! Plant tours wre taken throughout the reporting-period on a j routine basis. The areas. toured included the following:
Reactor Buildings
! Station Yard Zone within the Protected Area
! Turbine Building i-
-Intake Building
- Diesel Generator Building l Fire Pump Building
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Recombiner Building
, Central and Secondary Alarm Stations
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Waste Gas Treatment Building-
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Main Stack-(Lower elevations)
l Switchyard Relay House Unit 2 Torus (proper)
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During the drywell tours and a visit insidelthe torus proper, the
, inspectors specifically searched for extraneous material in the-
- . torus and in the downcomer. rin Examination behind several of the downcomer deflection plates identified a few items including hardhats and several tools. The amount of material was not nearly as significant as noted by the inspectors during previous outages.
L (Inspection Report 50-321,366/91-12 contains oetails.) The items-
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appeared to be of the type likely to be inadvertently dropped by -
workers during DW maintenance activities. Only one small piece of
foam material was noted floating in the torus. Underwater work
and other activities were in progress in the torus during the 1 tour. The torus water quality was noted to be better than previously observe Discussions with the divers support crews and the RB coordinator-indicated that the divers had not identified or recovered any significant amounts of material out of-d the torus during their work. -The inspectors confirmed that the objects in the downcomer ring will be removed prior to drywell-3~
closeout and a thorough inspection of the torus including the 4 downcomer ring will~be conducted.
5 During a routine tour of the intake structure on November 3, one i of the inspectors noted that the trough used to carry.away the; i material washed off of the traveling water screens was totally
blocked with a large quantity of leaves. . It appeared that the
, interiors of both screen housings were filled with leaves. The
- condition was reported to the Unit I shift supervisor who directed
, a PE0 to address the problem. The inspector's concern was that i the screens may not have been effectively preventing leaves from entering the intake area. During a backshift tour early on-November 4, the inspector noted that the Unit 2 operators were monitoring a RHRSW strainer which had a large .d/p (16.5 psig)
across it. The alarm response procedure states that a d/p of 20
- psig may damage the strainer. Although other RHRSW strainers were l available for use, the operators were attempting to complete a
- test which required the existing RHRSW alignment. Later that morning, the strainer was. removed from service and cleaned.- The
- inspector observed that the strainer basket had several inches of i leaves in it. The inspector noted that while some work had been i
initiated on the " downstream" traveling water screen, the_ trough and the " upstream" screen housing were still full of leaves. The
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Unit I shift supervisor was informed of the observations. At the l
close of the inspection period,_ the licensee war conducting .an additional review of the issue.- Several corrective actions were t immediately initiated, including directions to the operating I shifts regarding operation of the screenwash systems and rotation l of the PSW strainers. The sfe.ndby service water strainers were-examined and found to contain only a small quantity-of leaves.
l The inspectors concluded that, while no inoperability of the:
l service water systems occurred, a potential existed for degradation of those' systems. The inspectors _noted that, although-i during this time of year the Altamaha river contains many leaves
! and the system could become clogged _ rapidly, the conditions should have been identified by the watchstanders. The inspectors will followup on the licensee's additional actions on this -issue.
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During a tour of the DW the inspectors noted that electrical penetration X106A appeared to be significantly overloaded with cabling and connections. The cover inside the DW had been removed from the penetration for maintenance activities. The inspectors
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noted some apparent or slight damage on a few small cables and l concluded the large quantity of " extra" cabling would make it very difficult to reinstall the cover plate without damaging some of
, the cable Discussions were held with onsite engineering management and the appropriate system enginee The problem of overloaded electrical penetrations (too much wire) and potential cabling problems had been recognized by the licensee previousl A corrective action program has been in place since 1988 to address several penetrations during each refueling outag Specific special purpose procedures have been developed for the inspection and resolution of each penetration. The inspectors reviewed the procedure for penetration X104F and concluded it was thorough and addressed potential problems adequatel To date, 16 of the total 23 electric 41 penetrations on Unit 2 have been examined under this program. Over half of the 22 Unit 1 penetrations have been completed. The engineer verified that the cabling in X106A is nonestential. Most of the cabling was connected to DW thermocouple The damaged cables were repaired and actions were completed to decrease the large quantity of wiring which would be required to be " loaded" back into the box.
. The inspectors reviewed a number of photographs depicting before
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and after conditions of numerous penetrations and terminal boxes which have been addressed in the overall upgrade program. The amount and arrangement of wiring was improved and identified degraded conditions (for example, corrosion) were corrected. The inspectors concluded that the overall conditions of the X106A penetration were not a safety concern and that the licensee's ongoing program for inspection and upgrading electrical
, penetrations is appropriate to address potential concern No violations or deviations were identifie . Surveillance Testing (61726, 61701)
Surveillance tests were reviewed by the inspectors to verify procedural and performance adequacy. The completed tests reviewed were examined for necessary test prerequisites, instructions, acceptance criteria, technical content, authorization to begin work, data collection, independent verification where required, handling of deficiencies noted, and review of completed work. The tests witnessed, in whole or in part, were inspected to determi w that approved procedures were available, test equipment was cal' e.ed, prerequisites were met, tests were
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conducted according to ,. edure, test results were acceptable and systems restoration was complete The following surveillances were reviewed and witnessed in whole or in part: SV-R43-001-05: Diesel, Alternator and Accessories
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Inspection (IB EDG) SV-C51-001-2S: SRM Function Test
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i 6 SV-R43-019-2S: IB EDG Logic Functional Test SV-C41-001-2S: Standby Liquid Control Recirculation Test SV-R43-019-2S: EDG 18 24-Hour Run/LOSP Functional Test
' SV-R42-008-0S: Battery Capacity Test (Performance Test) SV-R43-017-2S: EDG 2C 24-Hour Run/LOSP Functional- Test SV-R42-008-2S: IB EDG Battery Capacity Test i
j SV-E41-002-1S: HPCI Pump Operability i'
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During observation of the HPCI testing, the inspector noted that a -
communications problem resulted in the CR operators shutting down HPC A long standing problem, discussed below, frequently resulted in the
. "HPCI steam exhaust line.drai t pot high level" annunciator actuating during HPCI-testing. The alarm occurred _during this test and the operator initiated action-in accordance with the alarm response procedure. - Apparently, thes'e actions-were-not fully successful and a
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barometric condenser high level alarm occurred. While the operability l of HPCI is not adversely affected, the concern is that the condenser
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Efforts to contact the PE0 assigned to the HPCI room to assist-in the j testing were unsuccessful. After a short time,-the barometric condenser high pressure alarm initiated. After further efforts to contact the PE0 i were unsuccessful, HPCI was secured. --The HPCI room is a fairly high
- noise area during HPCI runs and apparently the PE0 did not hear the -
- plant page system. The inspector discussed his concerns about the CR
, operator's inability to contact the PE0 with_. operations management. Due to other problems with communications, operations management has L obtained several sets of cordless telephone communications' sets which
- appear to. work very well in such_ circumstances.: It is expected that the I use of these headsets will increase and similar incidents will be prevented. Additionally . shift management emphasized _to-the- PE0 his
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r responsibilities during assigned tasks.- The problem with the exhaust
- drain pot alarm has resulted in implementation of a DCR on Unit 2-during
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the current outage. If. that modification corrects the' problem, it will l be. implemented on Unit 1 as-well. .While thel exhaust drain: pot and
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communications problems do'not directly' affect HPCI operability, they-are unnecetsary distractions to the operators during control of-the HPCI
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l No violations or deviations were identified.
I Maintenance Activities (62703)
L Maintenance activities were observed and/or reviewed during the 1 reporting period to verify that work was performed by-qualified personnel and that approved procedures in use adequately described
- - work that was not within the skill of the trade. Activities, L l
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procedures, and work requests were examined to verify; proper authorization to begin work, provisions for fire, cleanliness, and exposure control, proper return of equipment to service, and that limiting conditions for operation were me In addition to the activities discussed in paragraph 5, the following maintenance activities were reviewed and witnessed in whole or in part: MWO 2-92-3375 - Install Cybrerex Chargers per DCR G7-115 MWO 2-92-2907 - Install Sensor and Perform V0TES Testing of Valve 2B21-F016 MWO 1-92-4221 - 1B EDG Replacement of Cylinder Sleeves, 0-Rings and Piston . MWO l-92-5720 - Troubling Shooting and Adjustment of IB Diesel Gent-ator Speed Sensor MWO 2-92-5505 - Machine RHRSW Strainer Cover and Body EDG Maintenance Activities On October 11, the IB EDG was removed from service to perform procedure 52SV-R43-001-05: Diesel Alternator and Accessories Inspection. This involved the changeout of the cylinder liners, pistons, and connecting rods, and was part of an EDG upgrade program. The inspectors observed and reviewed these activities at frequent intervals. During the inspection, the EDG was started twice and a high load run was performed. The inspection was completed on October 21, at which time procedure 34SV-R43-002-1S:
EDG Monthly Test was performed. The IB EDG was then declared operabl On October 22, procedure 42SV-R43-013-2S: 24 Hour Run/ Loss of Offsite Power Logic Function Test was starte Shortly after the start of the test, the stator high temperature alarms actuated and the operators terminated the test. Followup reviews indicated that, due to the high level of output placed on the EDG for the test, these alarms would be expected. A temporary change was made to the procedure to address the high temperature, the monthly test was re-performed and the 24 Hour test was resumed on October 2 On October 24, at the completion of the 24 Hour load test, the control switch war placed in the STOP position. This action stopped the EDG, but the start signal failed to clear. Although the machine had stopped, the logic network indicated that machine was still running. This resulted in the licensee declaring the EDG inoperable. The problem was traced to a malfunctioning speed sensor. The speed sensor was replaced on October 26. The licensee re-performed the monthly test but the diesel start light
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remained lit, the standby PSW pump remained running and a hard ground was discovered on the negative side of_the EDG batter This problem was traced to a ground in the newly installed speed sensor. The speed sensor was disassembled and the ground was-cleared. The inspectors observed portions of these troubleshooting processe On October 27, at 7:30 a.m. the monthly test was performed and the ;
EDG was declared oper ?le. At 10:07 a.m. on the same date i procedure 34SV-R43-005-IS: Semi-annual Test, was started and the-control switch in the control room was placed in the START position. Approximately five seconds later the EDG tripped, and a start failure alarm was received. _This problem was caused by the trouble shooting performed on the speed sensor to clear the electrical ground. During the disassembly of the speed sensor two plungers that actuate micro switches in the sensor at specific speeds fell out, They were later recovered- from beneath the ED The licensee declared the EDG inoperable and recorded the inoperability as effective back to October 24. The speed sensor was reassembled and reinstalled on the IB ED On October 28 at 1:08 a.m., the m a thly test was performed satisfactoril At 3:05 a.m. on tae same date, the semi-annual test was re-started and seven secr;nds after placing the control room switch in the-START position, with the EDG at approximately 900 RPM, another start failure was received. This time the problem was traced to the fact that two speed sensor wires had been incorrectly connected during the reassembly after the plungers were reinstalle The inspectors reviewed the EDG start logic system which consists of three networks. These are: the EDG start logic,-the stop logic, and the shutdown logic networks. The inspectors noted that the speed sensor was within the EDG stop logic network and the two micro switches activated at 250 rpm and 810 rpm respectivel These switches indicated to the overall logic- system that the EDG has started (250 rpm), and that it is up to speed (810-rpm). The inspector also noted that when a slow start 'was initiated, (starting the EDG from the local- panel), these micro switches were not in the logic system. The inspector further noted-that when the EDG is started from the centrol room, (the fast start), the switches were in the system. This.explaineo the reason why the EDG would operate' locally for the monthly test, but would not operate for the semi-annual test (with the two plungers missing).
The inspectors discussed these observations with licensee personnel who were reviewing the issu On October 29, procedure 52SP-10892-JF-1-1S, was written to adjust the speed sensor. This process consisted of removing the speed sensor from the front end of the engine, utilizing an electric-drill hooked up to a variac to drive the speed sensor, and using a strobatac to verify the 250 and 810 rpm set points. The ._ _ _ _ - _ _ _ _
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inspectors observed this process. -The speed sensor was adjusted, re-installed on the engine and the semi-annual test was performe The engine started successfully from the control room and the inspectors observed the correct relays _ actuating as necessary to satisfy the start, stop and shutdown logic networks. The EDG was declared operable. The inspectors noted that subsequently a directive was issued which indicated that after any maintenance on the EDG logic system the semi-annual test would be performed for operability. This will ensure the full circuitry is tested. A brief review of work history did not indicate that any recent work had been' performed for which inadequate testing was performed, The inspectors concluded that weaknesses had occurred in that some-
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of the maintenance activities and details of the start logic were not fully understood by personnel. The safety significance of the specific problems was not large. The licensee had established requirements for removal of the IB EDG from service which were more conservative than the minimum TS requirements. The initial problem had surfaced during testing and the _TS LC0 actions were complied with until the IB EDG was restored to full operabilit No violations or deviations were identifie . Refueling Activities (60710) (Unit 2)
Activities relating to fuel movement (return of fuel to reactor vessel)
were monitored by the inspector Procedures 34FH-0PS-001-0S:: Fuel-Movement Operation, and 42FH-ERP-014-0S: Fuel Movement, were' reviewe Completion of attachment 2 (Unit Two Fuel Movement Prerequisites) of 34FH-0PS-001-0S was verified. The inspectors noted that operations personnel closely reviewed the LC0 and clearance logs to ensure required systems were operable prior to fuel' movement. -TS requirements-and management directed additional prerequisites were met. Several of the completed surveillance tests were reviewed to ensure TS requirements were included and met. Portions of several different shifts of-refueling bridge operations were observed. _0bservations-were conducted-
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from the refueling floor and the CR. TS and procedural requirements concerning platform manning were met. The inspectors observed consistent-compliance with bundle and-orientation signature requirements in accordance with the approved Fuel Movement sheets. The Fuel Tag Board on the refueling floor and duplicate Movement Sheets in the-CR were kept up to date. CR personnel maintained communications'with the platform during . fuel movement as. required. Attachment 2-(Fuel Movement-Prerequisites) to 34FH-0PS-001-0S was completed at the required intervals. Required periodic surveillance were closely tracked. SRM functional testing was completed as- require The inspector noted that prior to and during fuel movement several problems with the fuel handling mast and_ bridge were encountered. The majority of the problem involved limit switch settings for the mas Several MW0s:were generated to address this problem. The malfunction was finally determined to be a sheared pin'on-a drive shaft that_ caused
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the limit switch to appear to be out of adjustment. During the review of these activities the inspector became aware that the documentation of specific activities was not beirl performed in a timely manner and that some of the actual work descriphons were insufficiently detailed. This concern was discussed with licensee personnel and managemen During this report period the licensee performed the GE recommended examinations of the reactor vessel shroud access hole cover plates on Unit 2. SIL 462, Supplement 3, discussed an instance of radial cracking of these welds at another BWR which had apparently extended into the shroud ledge material. NRC ins 88-03 and 92-57 also addressed the issue. As a result of the examinations at Hatch, a circumferential indication was identified on one of the plates. A Region II materials inspector that was onsite followed the licensee's activities. The-issue was discussed with regional and NRR managemen Inspection Report 321, 366/92-25 contains an additional discussion of this issue. The
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inspectors will verify during the next inspection period that the licensee has implemented the SIL 462 reactor operating guidelines recommended by GE prior to Unit 2 startu The issue was the subject of a subsequent meeting involving NRC management, GE and the licensee on October 27, 1992. The licensee
. provided information indicating that the circumferential hole cracking
is not a safety concern, and operation of Hatch Unit 2 for cycle 11 was acceptable until the Spring 1994 refueling outage. At this meeting, the licensee committed to inspect Unit 1 in the forthcoming Spring 1993 outage and will have a temporary repair available for implementation at that-time. They also committed to inspecting and repairing the Unit 2 access hole covers during the Spring 1994 outage. The long term corrective actions commitment by the licensee is identified as IFI 50-321,366/92-29-02: Inspection of Shroud Access Hole Covers During Spring of 1993 for Unit 1 and Spring 1994 for Unit 2.
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No violations or deviations were identifie . Unit 2 Spare Drywell Penetration Caps Not in Accordance with ASME Code Requirements (71707) (40500) (92700)
- During the current Unit 2 refueling outage, walkdowns of the primary containment penetrations were conducted. These walkdowns were discussed
- in LER 366/92-01
- Errors in Plant Documents Result in Missed TS Surveillance, and LER 366/91-18: - Error in FSAR Results in Missed TS
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Surveillance. These LERs addressed failures to perform proper LLRTs of some torus penetrations and included commitments to perform complete
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containment walkdowns. NCV 366/91-34-01: Failure to Perform LLRT and Visual Verification of a Containment Penetration, addressed the issue As a result of the walkdowns, a Hatch engineer identified that 22 of the 71 total spare penetration caps did not meet the applicable ASME code Section III requirements. On penetrations greater than 8 inches in diameter some of the caps had been installed with a fillet weld which was not in accordance with the code. On some penetrations less that 8 inches, a code cap and fillet weld were not installed. Temporary caps
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(installed for the original containment- structural integrity test) were-found in place of the proper caps. These temporary. caps consisted of rectangular sections of steel plates welded on the end of the pipin The qualifications to code requirements by both the material utilized and the attachment welding was not documente Upon being informed of the situation, the inspectors asked if an operability determination had been performed. Although Unit 2 was shutdown at the time, it was suspected that a similar condition may-exist for Unit I which was at full rated powe On October 16, 1992,.
the inspectors.were provided a copy of an engineering assessment of the
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non-code containment penetration caps found on Unit 2. It also addressed Unit- 1 penetrations should a walkdown identify similar deficiencies. The inspectors reviewed the assessment using the guidance provided in GL 91-18 and NRC Inspection Manual Chapter 9900. The assessment concluded that the penetrations were operable and that no safety concern existed. It concluded that the caps were a non-conforming condition and must be brought into' compliance with the code requirements prior to startu The primary justification utilized in the assessment was the successful completion of numerous ILRTs in accordance with Appendix J to 10 CFR 50. ILRTs have been successfully-completed on each unit approximately every 3-years. Visual inspections have been conducted on the penetration and no degradation was note LLRTs are not: required for these penetrations because they are welde The inspectors did not identify any. inadequacies in the assessmen Additionally, two regional materials inspectors were onsite and briefly reviewed the assessment. The resident inspectors observed removal and replacement of several of the small diameter caps in the torus are The attachment welds on several of the " removed" temporary caps appeared to be structurally soun Over the next several days, walkdowns were conducted of the accessible Unit I containment penetrations. No non-conforming penetrations were identified. About 25 of the spare penetrations are not accessible and will be examined next outage (scheduled to start on March 10,1993).
Criterion V of Appendix B of 10 CFR 50 requires that the' containment and penetrations be in accordance with the applicable code. . Section 3.8 of:
the Unit 2 FSAR states that-the Unit 2 containment and penetrations are in accordance with ASME Code Section III, Subsection NE. 'The-licensee-identified that the code requirements'were not met. This issue will not-be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criterie of Section VII.B of the Enforcement Policy. The deficiencies were identified as a result of questioning of the caps by a Hatch engineer and were promptly discussed with the resident-inspectors. A prompt operability assessment was performed. The licensee will submit a voluntary LER addressing the issue. All Unit 2 spare penetrations will'be restored to a condition in
- compliance with code requirements prior to reactor startup. The status of Unit 1 penetrations were also addressed. This issue is identified.as NCV 366/92-29-01: Non-Conforming Spare Primary Containment Penetration .
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One NCV was identifie . Inspection of Open items (92700) (90712) (92701) (92702)
The following items were reviewed using licensee reports, inspection,
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record review, and discussions with licensee personnel, as appropriate: (Closed) VIO 366/91-15-01: Incorrect Procedure Resulting in ESF Actuation and LER 366/91-012: Less Than Adequate Procedure Results in ESF Actuations. These item addressed an inadequate modification procedure for ATTS Rosemount trip cards. The Rosemount cards were being installed to replace GE trip cards in ATTS for increased manufacturer diversification in the ARI syste The event was regarded as serious by the inspectors due to the inadvertent actuation of several ESF systems. The inspectors reviewed and verified the licensee's corrective actions as stated in the LER and in the response to the violation. Among the most significant corrective action was a change to 42EN-ENG-001-0S:
DCR Processing, which requires that trip system be returned to service one at a time after modification work. Additionally, changes were made to the procedures which guide how work process sheets are written. Procedure 50AC-MNT-001-0S: Maintenance Programs, requires that the sheets only specify the sequence of steps and reference the appropriate plant procedure or drawing for
, the actual work. The inspectors have observed that work process sheets in the field are usually written in this manner. While sometimes the steps of the work process sheets are not signed off at completion, workers were aware of their responsibilities
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involving use of approved procedures to accomplish'the modification work.
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Based on the review discussed in Inspection Report 321,366/91-15
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and this review of the licensee's actions, the LER and the j violation are closed.
, (Closed) VIO 366/91-12-02: Spent Fuel Pool Not Maintained Within
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TS Limits and LER 366/91-14: Less Than Adequate Storage Rack Design Evaluation Results in TS Non-compliance. These items addressed the fact that the water level in the SFP was not being
- maintained as required by Unit 2 TS 3.9.10. The cause of the TS violation was an inadequate safety evaluation which had been performed for the installation of high density fuel storage racks in 1980. The modification increased the height of the racks by about 15 inches above the SFP floor. Additionally, the level requirement was incorrectly interpreted to require 23 feet of water above the top of " active fuel" instead of above the top of the fuel assemblies. On August 28, 1991, amendments were issued for the Unit I and Unit 2 TS which revised the requirements to require at least 21 feet of water above the top of the upper tie plates of the irradiated assemblies seated in the rack Detailed calculations were performed to ensure that 10 CFR 100 and the
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Standard Review Plan requirements would be met. The licensee has also issued guidance to the operators which explains concisely the required SFP level. The root cause of the problem, an inadequate safety evaluation, has been addressed through the licensees significant enhancement of evaluation controls and training since the time this error occurre The inspectors have noted that SFP level has been maintained well above the revised level requirement. Vio 321/92-18-02:
Inadequate Corrective Actlons Resulting in SFP Overflow, remains open and involves some concerns on the SFP level alarm system No other TS violations have occurred recently involving inadequate safety evaluations of design changes, inspection Report 321, 366/92-?2 contains a discussion of a recent review of a DCR safety evaluation by the inspectors. Based en this review of the licensee's actions, the violation and LER are closed c. (0 pen) VIO 321/92-18-02: Inadequate Corrective Actions Resulting in Spent Fuel Pool Overflow. During review of the licensee's response to this item, the inspectors noted that the corrective
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actions listed did not spacifically address the cause of the
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violation. The corrective actions listed addressed the specific equipment problems which were noted in the violation. The response listed the cause of the -violation as "as lack of proper management attention to resolution of the subject problem." The inspectors concur with this as a primary factor.in this issu While none of the corrective actions listed in the violation addressed this aspect, the inspector's discussions with NSAC personnel indicated that the involved management personnel are aware of their role in this violation. The inspectors have noted an increased attention level and more thorough followup of issues 4 on the part of several managers in recent weeks. The inspectors concluded that although the corrective actions listed in the r response do not fully address the cause of the violation, other actions have been initiated which address the inspector's concerns. This violation will remain open pending additional review by the inspectors of the effectiveness of the specific action listed in the response, d. (Geen) VIO 321, 3G6/91-06-01 Licensee Failed to Conduct Quality Physical Inventories of SNM. This violation addressed the fact that PIs were not being conducted in a manner that was sufficient to account for all SNM in the licensee's possession, and that
, partial physical inventories reflecting lthe results of transfers and movements of SNM were not being conducted as require The inspector reviewed the licensee's corrective actions for this violation, reviewed selected portions of the licensee's procedures
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and records, and conducted interviews of cognizant licensee personnel with regard to thi-s issue. The inspector determined that the PIs currently being performed were primarily " piece" counts; as opposed to a PI performed by physically ascertaining
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the presence of the individual.SNM items by serial number, identification tag, or other unique identifie For items which are physically inaccessible (items in the core, etc.), a records comparison should be used to perform the P The inspector concluded, based on this review, that the PIs at Hatch, at the time of this inspection, were not being performed to the level of detail necessary to ensure adequate tracking of SN The inspector discussed this conclusion with reactor engineering management. -The licensee stated that the procedures for performing the PI, including Procedure 42FH-ENG-030-0S, Special-Nuclear Material Inventory and Transfer Control, would be reviewed and revised where necessary, to ensure that a detailed and thorough PI would be performed. The implementation of these further corrective actions will be reviewed during subsequent inspections. Based on this review, this violation remains open.
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e. (Closed) VIO 321,366/91-06-02, Inadequate Material Control and j Accounting Procedures; and VIO 321,366/91-06-03, Unauthorized Transfer of SNM. These two violations addressed the fact that the licensee's material control and accounting procedures were
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i deficient in that they did not adequately control the receipt,
- transfer, and disposal of SNM.
l The inspector reviewed the licensee's corrective actions for this
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violation, reviewed selected portions of the-licensee's procedures
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and records, and conducted interviews- of _ cognizant-licensee
personnel with regard to this issue. The corrective actions for the two violations were identical. Procedure 42FH-ENG-030-0S,
- Special Nuclear Material Inventory and Transfer-Control, and
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Procedure 40AC-ENG-007-0S, Control of Special Nuclear Material,
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were revised to explicitly delegate the responsibility'for
! controlling and accounting of SNM to Reactor Engineering. In i- addition, other procedures which dealt with SNM were reviewed by l the licensee, and revised where necessary, to clarify and strengthen the controls on SNM;- including the receipt and transfer
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of SNM.
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!: During this inspection, the inspector reviewed pertinent portions l of selected procedures to determine if appropriate controls had l been implemented. .The inspector also reviewed selected records
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! for the receipt and transfer of SNM. In addition, the inspector i- compared the SNM items on a "real time" inventory listing to the
- SNM located in a licensee warehous No discrepancies were identified. Based on this review of the licensee's corrective i actions, this item is close f. (C1osed) VIO 321,.366/91-06-04 Licensee Failed to Report the Loss of SNM From Inventory._ This violation addressed the failure of
, the licensee to report the loss of SNM to-the NRC,-via the ENS, i
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This violation was caused by the licensee's misinterpretation of 10 CFR 70.52 reporting requirements. Plant personnel did not believe that this event met the criteria requiring reporting to the NRC within one hour. In addition, the licensee believed that the SNM in question had not really been lost, because apparently these items had been inadvertently buried as radioactive waste in a licensed radioactive waste disposal site. Discussions with some NRC personnel at the time of the event were interpreted by the licensee to support the issue as not_being reportable. .The
. resident inspectors were also informed of the event. The j licensee's corrective action for this event was to make
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appropriate plant and corporate personnel aware of the correct interpretation of the reporting requirements of 10 CFR 70.5 Based on,the review of the licensee's corrective actions, this
- item is close !
! (Closed) LER 321/91-32, Personnel Error Results in Missed TS-i Surveillance. On December 28, 1991, at 10:30 pm (CST), during a i' routine review of completed surveillance procedure data packages, the license determined-that a daily check of the Unit 1 Torus oxygen concentration had not been performed the previous day as
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required by TS section 4.7. A.5. - Licensed Operations personnel performing procedure 34SV-SUV-019-IS, Surveillance Checks, had i
incorrectly marked the torus oxygen concentration as "not
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required," on December 27, 199 ,
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-involved personnel and Beginning of Shift (B0S) training for-Operations shifts regarding this event. The inspector reviewed the surveillance records for pertinent dates, and reviewed-the i material covered during the BOS training. Based on the
- inspector's review of the licensee's corrective actions, this -LER is close '
I (Closed) LER 321/91-30: Instrument Drift Causes Area Radiation-
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Monitor Trips Resulting in ESF Actuation. On December 2, 1991, at 1 10:55 am and-11:33 am (CST), and on December 7, 1991, at 5:45 am
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(CST), the MCREC system automatically transferred. from the normal-L -mode to the pressurization mode. These events occurred when the
. refueling floor ARMS tripped on false. high radiation signals.
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The licensee's investigation determined that the high radiation
- - trip setpoints'of two ARMS (ID21-K601D and 2021-K601A) drifted, i causing the ARMS to trip on a false high radiation signal. The
licensee's corrective-actions for these events included; returning
- the MCREC system to normal, resetting the ARM high radiation trip.
i setpoints to their proper values, functional testing _-of- four of the refueling floor ARM units, and the replacement of.one-trip p unit-(1D21-K6010). The trip unit was replaced because of repeated i '
instances of setpoint drift. The other three trip units were satisfactorily functionally tested.
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i The inspector reviewed selected portions of the licensed records, l including records for the functional tests that were performed,
- and based on this review, this LER is closed.
' (Closed) LER 366/91-21: Personnel Error Results in TS Noncomplianc On November 5, 1991, the licensee determined that Post Accident Monitoring System recorder 2T58-R608 had been inoperable due to personnel error for' greater than 30 days. Since this condition was not identified untti November 5, the required TS actions were not complete The licensee's corrective actions included issuance of a directive by the Manager of Operations to licensed operators to remind them that the purpose of the once per shift instrument recorder checks is to identify unusual parameter indications and problems with the recorder and to promptly initiate investigations as required. The t directive also stated that "for any recorder required by Tech Spec l to be considered as operable; the chart paper must be advancing,-
! the pen must be inking, and the pen must be indicating the parameter value as indicated by a channel check." This event had been previously reviewed by the resident inspectors. Details of
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l their review were discussed in Inspection Report 321, 366/91-3 Based on the resident inspectors review, and on the review of the licensee's corrective actions performed during this inspection, this item is close . Exit Interview l The inspection scope and findings were summarized on November 13, 1992, l with those persons indicated in paragraph 1 above. The inspectors
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described the areas inspected and discussed in detail the inspection findings. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspectio Item Number Status Descriotion and Reference 50-366/92-29-01 Opened and NCV-Non-conforming Spare Primary Closed Containment Penetrations (paragraph 6).
50-321,366/92-29-02 Open Inspection of Shroud Access Hole Covers During Spring 1993 for Unit I and Spring 1994 for Unit . Acronyms and Abbreviations AC - Alternating Current APRM - Average Power Range Monitor ARI - Alternate Rod Insertion ARM - Area Radiation Monitor l
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ASME - American Society of Mechanical Engineers ATTS - Analog Transmitter Trip System ATWS - Anticipated Transient Without Scram BOST - Beginning of Shift Training BWROG- Boiling Water Reactors Owners Group CFR -
Code of Federal Regulations CR - Control Room CRD - Control Rod Drive CST - Condensate Storage Tank DC -
Deficiency Card DCR - Design Change Request d/p - pressure differential DW - Drywell ECCS - Emergency Core Cooling System EDG - Emergency Diesel Generator EHC - Electro Hydraulic Control System ESF -
Engineered Safety Feature EST - Eastern Standard Time FSAR - Final Safety Analysis Report FT&C - Functional Test and Calibration GE - General Electric Company GL - Generic Letter GPM - Gallons per Minute HP -
Health Physics HPCI - High Pressure Coolant Injection System HVAC - Heating, Ventilation and Air Conditioning I&C - Instrumentation and Controls IFI -
Inspector Followup Item ILRT - Integrated Leak Rate Test IN -
Information Notice IRM - Intermediate Range Monitor LCO - Limiting Condition for Operation
. LER -
Licensee Event Report
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LLRT - Local Leak Rate Test l LOCA - Loss of Coolant Accident LOSP - Loss of Offsite Power LPRM - Local Power Range Monitor MCREC- Main Control Room Environmental Control System MFP - Main Feed Pump MWE -
Megawatts Electric MWO - Maintenance Work Order NCV - Non-cited Violation NRC - Nuclear Regulatory Commission NRR - Office of Nuclear Reactor Regulation NSAC - Nuclear Safety and Compliance PE0 - Plant Equipment Operator PI - Physical Inventory l PSIG - Pounds Per Square Inch Gauge PSW - Plant Service Water System RB - Reactor Building RCIC - Reactor Core Isolation Cooling System RFP - Reactor Feed Pump i
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RHRSW- Residual Heat Removal Service Water System RPS - Reactor Protection System RPT - Recirculation Pump Trip RTO - Resistance Temperature Detector RTP - Rated Thermal Power RWCU - Reactor Water Cleanup System Rx - Reactor SAtR - Safety Audit and Engineering Review SCS - Southern Company Services SER - Safety Evaluation Report SFP - Spent Fuel Pool Sll - Service Information Letter SNC -
Southern Nuclear Company SNM -
Special Nuclear Material 50R - Significant Occurrence Report
- SOS - Superintendent of Shift (Operations)
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S0V - Solenoid Operated Valve-SRM - Source Range Monitor SRV - Safety Relief Valve STA - Shift Technical Advisor i
TS - Technical Specifications
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