IR 05000321/1993021

Insp Repts 50-321/93-21 & 50-366/93-21 on 930913-17.No Violations Noted.Major Areas Inspected:Engineering & Technical Support of Plant Mod,Design Changes & Plant Operations

ML20059A300
Person / Time
Site:	Hatch
Issue date:	10/08/1993
From:	Casto C, Hunt M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059A296	List: IR 05000321/1993021 ML20059A293
References
50-321-93-21, 50-366-93-21, NUDOCS 9310260292
Download: ML20059A300 (3)

Text

UNITED STATES ffp pro % NUCLEAR REGULATORY COMMISSION

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,g * S 101 MARIETTA STREET, N.W., SulTE 2900 i ;y ATLANTA, GEORGIA 303234199

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Report Nos.: 50-321/93-21 and 50-366/93-21 Licensee: Georgia Power Company P. O. Box 1295 Birmingham, AL 35201 Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5 Facility Name: Hatch I and 2 Inspection Conducted: September 13-17, 1993 Inspector:

M. D. Hunt

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l D !6 J3 Date Signed Accompanying Personnel: M. N. Miller H. L. Whitener Approved by: . cd C 4. Cast 5, Chief '

/[ bcaK /a/ &O Date S1gned Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Scope:

This routine, announced inspection was conducted in the areas of engineering and technical support of plant modifications, design changes, and plant operation Results:

This inspection revealed no weaknesses in the development of modification packages after the design packa'ges were received on site. The engineering groups are actively involved in the identification and resolution of problems in support of reliable plant operations as indicated by equipment performance trending data for both safety and non-safety equipment. The technical-staff appeared knowledgeable and exhibited a pride of workmanship for those items examined during this inspectio In the areas inspected, violations or deviations were not identifie DR ADOCK 0500

REPORT DETAILS

. Persons Contacted Licensee Employees

• Breitenbach, Supervisor, Engineering Support

• Burkett, Supervisor, Engineering Support

• Curtis, Superintendent, Operations Support

• Fornel, Manager, Mainterance

• 0. Fraser, Site Supervisor, Safety Audit & Engineering Review R. Glisson, Supervisor, Maintenance Engineering

• G. Goode, Manager, Engineering Support

• M. Googe, Manager Outages & Planning T. Huckaby, Engineering Supervisor

• R. King, Engineering Supervisor

• C. McDaniel, Acting Manager, Plant Administration

• T. Metzler, Supervisor, Nuclear Safety & Compliance

• C. Moore, Assistant General Manager, Plant Operations

• D. Read, Assistant General Manager, Plant Support

• J. Robertson, Plant Engineering Supervisor

• K. Robuck, Manager, Plant Modifications & Maintenance Support

• E, Shaw, Engineering Supervisor

• L. Sumner, General Manager

• S. Tipps, Manager, Nuclear Safety and Compliance ,

• A. Wheeler, Plant Engineering Supervisor Other licensee employees contacted during this inspection included .

engineers, operators, technicians, and administrative personne Other Organizations

• G. McGaha, Hatch Design Project Manager, Southern Company Services NRC Resident Inspector (s)

• L. Wert, Senior Resident Inspector E. Christnot, Resident Inspector B. Holbrook, Resident Inspector

• Attended exit interview Design Changes and Modifications (37700)

Plant Hatch has three departments that perform engineering functions in '

support of plant operations. These are identified.as Engineering Support Department, Plant Modifications and Maintenance Department, and Maintenance Departmen In some instances there is an overlap of responsibilities between the departments. Personnel are shared between departments if an individual has a certain expertise that is needed by another department. Each department and its function was examined by the inspectors and the results are discussed below, f

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a. Engineering Support The inspectors reviewed several activities performed by the -

Engineering Support Department to determine its effectiveness in identifying and resolving technical issues affecting plant safet The System Engineering (SE) Section and the Components Engineering (CE) Group in the Engineering Support Section were the two groups selected for examination and review. The selected groups interface with plant operations, design engineering, and the maintenance department in resolving equipment problems associated with overall plant operations. The areas reviewed included tempo-rary modifications, minor modifications, significant operating reports (SOR), request for engineering reviews (RER), equivalency modifications, support programs, work backlog, and the organiza-tion of the SE and CE group The System Engineering Section was staffed with 17 engineers, two '

plant engineering supervisors, one section supervisor, and separated into two groups. One SE group was primarily assigned reactor systems and the 120 VAC and 125 VDC electrical systems and components. The other SE group was assigned balance of plant 1 (BOP) systems and the 600 V and 4160 V switchgear and motor control centers. The system engineers assigned systems and responsibilities are listed and defined in documents identified as System Engineers Practices (SEP) and Departmental Instructions (DI). The inspectors considered the use of the SEPs as a convenient method for providing necessary documentation outside the area of formal procedures. The following SEP and DI documents were reviewed:

Departmental Instruction DI-ENG-41-1089N, "Use of System .

Engineers". (list responsibilities of SEs) 4 System Engineers Practice SEP 92-001, " Definitions And Use Of Systems And System Engineers". (defines systems, organization, and assignments)

System Engineers Practice SEP 92-015, " System Engineer System Walkdown". (guidance for walkdowns)

SEP 92-015 provides instructions for the " system walkdown" that includes: 1) material condition, 2) observation of operating parameters and surveillance testing, and 3) observation of ,

maintenance activities. Each SE must complete a detailed walkdown >

log for the assigned system that lists deficiencies and corrective actions for these three categories. In addition, the SE is required to write and submit to management a detailed Quarterly System Report for each system that includes the results of the '

walkdowns. The inspectors reviewed several Quarterly System Reports and determined that the system walkdowns and the reports are an excellent method and tool for identifying, tracking,' and reporting problem It provides management with detailed up to

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date documentation. In another area, the SE provides assistance to the maintenance department by reviewing " maintenance work orders" (MWO). During the last year SE closed out 272 MW0s with a backlog of 29 MW0s that remain open. Most of the open 29 MW0s were submitted over the last few months. The SE group had the lead in developing the " Minor Modification" Work Procedure, 42 EN-ENG-029-03, Minor Design Change, dated April 19, 1993. Since this procedure was developed, 34 minor modifications were initiate *

The inspectors reviewed the minor modification packages listed below to verify that the criteria in 42 EN-ENG-029-03 was met:

Minor Modifications

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MDC 93-5001, Add new isolation valve downstream of existing drain valve 2P51-05 MDC 93-5004, Remove cathodic protection system from condense MDC 93-5009, Add a simple 02 injection system as requested by RER-88-741 to feedwater pipin MDC 93-5020, Replace recorder 2S32-R016 and 2S32-R018 with single two pen recorde The inspectors concluded that the SEs adequately fulfill their function to manage activities related to maximize the performance, availability, and reliability of the system In addition to the SE, the Engineering Support Department has a specialized CE group that provides additional technical support expertise for components and programs. The CE group was staffed with eight engineers and a plant engineering supervisor. The-group's main function was providing plant technical support in the mechanical areas for generic components and programs. .The CE duties and responsibilities are listed in Departmental Instruction DI-ENG-46-0693N, "Use of Component Engineers." Some of the components and programs assigned to the CEs are air operated valves (A0V), check valves, solenoid valves, motor operated valves i (M0V), relief valves, pumps, piping, snubbers, supports, tanks, and vessels. In addition, the inspectors verified the CE special- "

ized generic programs listed as follows:

ASCO Solenoid Valve Program Environmental Qualification (EQ) Program Check Valve Program Erosion / Corrosion Program Inservice Inspection (ISI) and Testing Program Leak Rate Testing Program '

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Lead Shield / Evaluation Program Snubber Testing Program

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For snubbers, the inspectors examined several equivalency modifications to verify the requirements in Procedure No. 42EN-ENG-009-05, Evaluation For Equivalent Replacement Parts And Material were satisfied. The two equivalency modifications reviewed were:

NPRG LOG NO. INNF-001, MPL NO. L35 NPRG LOG NO. 1235-001, MPL N0. L35 and 2L35 ,

The inspectors reviewed the following " requests for engineering review" (RER) to verify that CE supported plant activities by calculating lead shielding to support the ALARA program:

RER 93-0003, Unit 1 Recirculation Piping Lead Shieldin RER 93-0016, Unit 1 Drywell Recirculation Piping And Drain Line HER 93-0026, Unit 1 Control Rod Drive Scram Discharge .

Heade RER 93-0031, Unit 1 RHR - Containment Spray Piping Ell-GBB-16'.

The CE group supports maintenance by reviewing and assisting with MW0 CEs conduct plant walkdowns, observe testing, perform inspections, and conduct specialized tests. CEs also write minor modifications, temporary modifications, equivalency modifications, design change requests (DCR), and test procedures. The inspectors reviewed the following activities performed by the CE:

1993 Quarterly IST Reports of Valves And Pump ASME NIS-1 ISI Owner's Data Report - Spring 1993 for Unit Service Water Testing Report - 2nd Report Unit 1.

The inspectors examined each item previously listed to determine j its requirements were met and verified that CE was performing their assigned dutie ,

The inspectors concluded that CE was an effective group in supporting plant activities for generic components and program r The inspectors reviewed all 58 open temporary modifications. The following safety related temporary modifications and their associated work order developed by the Engineering Support Department were examined to determine if the governing administrative procedures were followed and a 50.59 safety evaluation was performe In addition, the inspectors verified that each control room had a log identifying these open temporary modifications (TMM) identified as follows: >

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Temocrary Modifications 1-93-36, Unit 1, MWO l-93-1160 Add Clamp As Seal For SBGT Lin , Unit 1, MWO 1-93-3580 Lift Leads To Disconnect Humidity Sensors In SBG , Unit 2, MWO l-93-850 Lift Wire To By-pass Temperature Recorder 2B31-R601 point 2 , Unit 2, MWO 2-93-1852 Interlock Heater And Fan In SBG , Unit 2, MWO 2-93-1955 Replace 20A Circuit Breaker 1R24-S004 With 25 The inspectors reviewed additional documentation such as special reports and significant operating reports (S0R) to verify that the Engineering Support Department is involved in resolving problems associated with other departments. The inspectors reviewed both the "open" and " closed" SORS to determine Engineering Support Department involvement. As an example, one of the closed SORS followed-up by CE was SOR 2-92-006, " Level Switch 2G41-N356 Has Wires Shorted To Ground." The follow-up by CE led the licensee to identify that additional wires in the drywell were damaged and further inspections in both units were needed. The inspectors concluded that CE involvement with this SOR demonstrated that Engineering Support Department activities were effective in identifying and resolving this plant proble The inspectors reviewed the HPCI Task Force special report dated July 1, 1992. This report detailed the activities for improving the HPCI and RCIC reliability and' performance. The Task Force identified and corrected these problems as a complete progra The inspectors concluded that the HPCI Task Force demonstrated that the licensee's Engineering Support was effective in support-ing the plan The inspectors concluded that both System Engineering and Component Engineering are effectively supporting plant activities and function b. Plant Modifications and Maintenance The plant modification program at Plant Hatch is controlled by procedures at the various levels of the organizatio Administrative Control Procedure No. 40AC-ENG-003-05, Design Control, establishes the requirements and assigns the re-sponsibilities for plant design control of systems, structures, and components. Plant design control is intended to ensure that

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basic design criterion is maintained and revised in a planned, controlled, and documented manner. This procedure establishes the '

responsibilities and requirements for the conduct of tests and -

initiating requests for engineering assistanc .

Engineering Services Procedure No. 42EN-ENG-001-05, DCR Processing, provides instructions to engineering support personnel'

for initiating, controlling, documenting, implementing, and closing out design change requests (DCRs) for both~ temporary and permanent plant changes. This procedure defines the minimum qualifications and establishes training requirements for those personnel who process and review design documentation.

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The design activities are performed.by the Southern Company Services. The controlling procedures are contained in The Plant Hatch Operational Support Policy and Procedures Manual. This manual defines the engineering organization requirements for the.' s engineering design and support functions for Plant Hatch and also includes procurement and quality assurance procedure ,

This site has chartered a Configuration Control Board.(CCB) which screens and prioritizes recommended changes to the plant's configurations through design requests or other suggestions from various departments and personnel. All departments of the plant and the Architect / Engineer (A/E) at the management level are represented on this boar ,

The inspectors reviewed the design change prioritization process '

to. verify that appropriate screening criteria are developed and implemented. Prioritization of proposed design changes or suggested design changes (Idea Forms) is performed at two level .

Approximately 16 months before a work window develops,.a pre-CCB

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meeting, consisting of supervisory level personnel from all plant departments and the A/E, is held to review all submitted Idea- ,

Forms and proposed DCRs (including the backlog of DCRs)~ to establish a prioritized (approved) work list based on a Benefit Index (BI). The BI is a numerical value assigned to various +

suggestions and DCRs. This value is determined by the importance of the modification Emergency modifications are given the highest rating (50), NRC Commitments (IEN/IEB) are given a 30, INP0 recommendations are given a 20 and a category called "Other"

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is rated 10. The approved work-list is presented for CCB review -i approximately 15 months before the work window develop Consequently, plant safety and reliability are emphasized by the licensee's use of the B The inspectors concluded that the licensee has developed a- :

methodology and criteria for selection of needed design changes which considers' plant safety, reliability and cost benefit <

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After the screening process is completed those items accepted are scheduled for development. When a modification involving a design -

change is accepted, a DCR is developed and the A/E is directed to take the appropriate action. Since the design work is performed by the A/E located off site, the inspectors could only review the finished design and implementation packages. Certain parts of selected design packages were requested by the inspectors and made available for their review.

Eight design packages which had been completed during the last refueling outage for each unit were selected for review. The inspectors verified that the proper design and site approvals were performed. These included approvals included: verification that 10 CFR 50.59 evaluations were performed; drawing lists were updated; fire protection and Appendix R reviews were performed; the need for operator training was reviewed; operating procedure changes were made if required; and that post modification testing '

was accomplished. Certain design aspects of these modifications were examined in part to verify that proper reviews were performed and that assumptions were well founded when used in the various calculations and other activities. Listed below are the design packages reviewed by the inspector DCR# IJJ11 87-150 Interposing Relays for Local Starters88-065 Control Room Panel DCRDR Modification 90-163 Recirc/Feedwater Controllers91-002 Replace TCV/TSV Scram Bypass Annunciator Pressure Switches91-052 Replace Cables to HPCI Valves91-173 RHR/RHRSW Xtie Vent 92-068 Relocate Steam Trap Drain Valves92-146 Reroute IRM Cable The inspectors examined various parts of the modifications listed above and reviewed the records for the post modification testing performed to determine operability where special testing was required. The various engineering personnel in the Plant Modi-fication and Maintenance Department were assigned to oversee the installation of modifications. In several instances the responsible engineer was present and discussed the various details of the modification and provided various welding and hydrostatic test document It was noted that a pride of ownership for their work was exhibited by the personnel involve ,

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The inspectors discussed the DCR backlog with licensee engineers and reviewed a trend plot and a status report indicating the control of the DCR backlog. This objective evidence indicates that management is controlling design process. The plot showed a decreasing DCR backlog from 791 in 1990 to 337 as of Se7tember 1993. The status of these 337 DCRs was reported as foilows:

71 are scheduled for implementation / closeout in 1993 74 are scheduled for implementation /closecut in 1994 37 are under review for voiding 20 are under review for closure 106 are to be reviewed for future lists for 1995 29 are to be reviewed for future lists for 1996 The above data indicates a controlled work off of the backlog and advanced planning for design changes by the licensee's management is occurrin The inspectors selected a series of control room drawings, some containing temporary minor modifications (TMM), to review plant configuration control by verifying that the control room drawings were marked to indicate that a modification had been made to a system. The Category 1 drawings are maintained on aperture cards which are filed in each control room area along with a viewer for ready access by the operators. The cards for drawings for which a modification exists are colre coded for easy identificatio The licensee has a requirement that all Category I drawings must be updated in 30 days when a permanent modification is completed and the as-built drawing placed in the control room file Drawings that are marked to indicate the existence of a TMM must be evaluated in 90 days to determine if further action is required to make the TMM permanent or provide justification for the continuation of the TMM. Listed below are the drawings that were '

verified to be at the proper revision level as verified by document control records. Those with temporary modifications are identifie ,

Drawing N H-23635, Re TMM 2-92-123 H-21023, Re TMM 2-92-139 H-27497, Re TMM 2-93-29 i H-24436, Re H-26028, Re H-16199, Re H-17815, Re H-11025, Re r r

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H-16238, Rev. 17 H-43898, Rev. 1 TMM l-92-53 H-17818, Rev. 21 D-11026, Rev. 9 The review of the licensee's method for plant configuration

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control did not identify any weaknesses and was adequate for the control of documents necessary to support safe operation of the plan c. Maintenance The Maintenance Engineering Department is part of the site '

engineering that supports safe reliable plant operation and timnly resolution of technical problems. Activities of this group include: coordination and oversight of the Preventive Maintenance (PM) program, management and implementation of the Predictive Maintenance program, maintenance of test data base, review and analysis of test data, MOV testing, and the trending of equipment performance to aid management in better allocation of resource Important aids in equipment problem identification are the Vibration Analysis and Lube Oil Analysis programs performed by Maintenance Engineering. These programs are applied to safety related equipment and non-safety equipment important to reliable plant operation. The inspectors reviewed objective evidence in the form of status reports, equipment case histories, and trending data to verify that these programs have been effective in identifying equipment problem In a status report to management dated July 14, 1993, a summary of the vibration program included recent case histories, Unit 1 outage-related work, current equipment problems and vibration levels of critical machines. Of 94 critical machines reported, 84 -

showed normal vibration levels,10 showed above normal vibration levels. Of the 10 machines with above normal levels of vibration, four had corrective actions pending and six were still under investigation. This report showed a nominal 90 percent of the critical machines have a normal range of vibrations. This represents an upward trend from about 64 percent in 198 Additionally, case histories showed that vibration analysis had been effective in identifying motor, pump, turbine, and blower (i.e., rotating machinery) problem The inspectors reviewed an equipment status report to management dated January 15, 1993, summarizing results of the oil analysis '

program for the third and fourth quarters of 1992. The report contained a brief summary of identified problems where early action prevented further component degradation and potential plant -

operability problems. The report also contained 38 case histories of problems identified by the oil analysis or a combination of the oil / vibration analysis programs. Some examples of early detection

of problems through the oil and vibration monitoring which lead to corrective actions and avoided potential operational problems are as follows:

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Significant problems with RCIC pump (2E51-C001)

involving loose bearings, a loose locknut and a cracked shaft sleeve were identified and repaired during a refueling outage thus avoiding a plant operational proble High bearing wear increase lead to repair of a condensate booster pump motor thus avoiding a potential feedwater transien Early repair of an offgas condensate return pump circumvented degraded system performanc Removal of excess water, cleaning of sediment in new oil and used oil storage tanks and addition of new oil ensured quality lubricant available for reliable operation of main and reactor feedwater turbines, j The case histories demonstrated identification of wear and high-rates of wear and in some cases the degraded parts could be identified. Also, in a number of cases, an oil change or change in the type of oil was indicated in order to reduce the wear rate.

The licensee identified 13 examples of problems identified as a result of the collection and trending of predictive maintenance

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data. These problems were identified mainly through the oil and vibration analysis and maintenance history reviews. The inspectors reviewed four case histories of the 13 examples and concluded that the root cause was identified and in some cases DCRs or MDCs were written to correct or improve the conditions.

One indicator trended by the licensee was rotating machinery failures. A downward trend in rotating machinery failure rate from 59 in 1985, to nine in 1992, indicates that the Preventive / Predictive Maintenance programs have been effective in improving plant operability. In the area of trending activity, the licensee has performed 805 reviews of plant equipment for the purpose of identifying repetitive failure modes and recommending corrective actions in the period August 1992 through July 1993.

Included in these reviews were 207 equipment items which were identified as requiring excessive corrective maintenance. Based on the equipment reviews, actions were taken to reduce adverse trends related to plant equipment. The types of action included:

initiate or. modify repetitive tasks; initiate MW0s; revise procedures; perform engineering reviews; request plant modifications; modify training; and etc. The equipment review T

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also included some equipment groups. MOV performance was one equipment group reviewed and trended. The results show a decrease in MOV failures from 63 in 1985 to 16 in 1991. These numbers included failures resulting from seat leaks, packing leaks, motor operators and miscellaneous problems. A significant contributor to the decreasing failure trend is due to an improved leak rate program. However, motor operator failures also showed a decreasing trend. Maintenance Engineering has also trended CFAR l data from the NPRDS data base from 1987 through 1993. The data show a gradual improving trend concerning the significance criterion (Z). The averaged Z for a nominal 20-equipment groups has decreased from a high of four to a nominal 2.3 in recent year Hatch Unit 1 equipment has been recently rated by safety significance based on PRA. Maintenance Engineering is tracking equipment with high safety significance for failures. The program intent is to provide increased sensitivity to the failure of safety significant equipmen During this inspection the inspectors tracked a real time event, failure of the Torus to Reactor Building Vacuum Breaker (IT48-328A) to open during the quarterly surveillance test. The inspectors reviewed this event to verify communication and interfaces between engineering groups, root cause determination, corrective actions and post maintenance testing. No problems were identified relative to the licensee's action in this even The activities of the Maintenance Engineering Department was making a satisfactory contribution to safety and non-safety equipment reliabilit . Exit Interview The inspection scope and results were summarized on September 17, 1993, with those persons indicated in paragraph 1. The inspectors described the areas inspected and discussed in detail the inspection result Although reviewed during this inspection, proprietary information is not contained in this report. Dissenting comments were not received from the license . Acronyms and Initialisms A/E Architect Engineer A0V Air Operated Valve BI Benefit Index B0P Balance of Plant CCB Configuration Control Board CE Component Engineers CFAR Component failure Analysis Report DCR Design Change Request DCRDR Detail Control Room Design Review

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DI Department Instruction ENG Engineering HPCI High Pressure Coolant Injection System IEB Inspection and Enforcement Bulletin IEN Inspection and Enforcement Notice IRM Intermediate Range Monitor ISI Inservice Inspection MDC Minor Design Change MOV Motor Operated Valve MWO Maintenance Work Order NPRDS Nuclear Power Reliability Data System PM Preventive / Predictive Maintenance PRA Probabilistic Risk Assessment RCIC Reactor Core Isolation Cooling System RER Request for Engineering Review RHR Residual Heat Removal System RHRSW RHR Service Water SBGT Standby Gas Treatment System SE System Engineer SEP System Engineering Practice SOR Significant Operating Report TMM Temporary Minor Modification Xtie Cross Tie

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