IR 05000335/1989009
| ML17222A759 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/05/1989 |
| From: | Jape F, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17222A758 | List: |
| References | |
| 50-335-89-09, 50-335-89-9, 50-389-89-09, 50-389-89-9, IEB-85-003, IEB-85-3, IEIN-84-13, NUDOCS 8904200187 | |
| Download: ML17222A759 (14) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-335/89-09 and 50-389/89-09 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.:
50-335 and 50-389 License Nos.:
DPR-67 and NPF-16 Facility Name:
St. Lucie 1 and
Inspection Conducted:
March 6-10, 1989 Inspector:
.
earn Lea er Team Members:
E.
Lea R. Wright Approved by:
F. Jape, C ief guality Performance Section Operations Branch Division of Reactor Safety Date Sign Date Signed SUMMARY Scope:
This routine, unannounced inspection was in the areas of design, design changes; plant modifications and corrective actions requiring engineering input.
Results:
PC/Ms were prepared and installed in accordance with the licensee's program requirements and applicable industry codes and standards.
Safety evaluations performed in accordance with the requirements of
CFR 50.59,
CFR 50.49, and Appendix R were thorough and techni-cally adequate.
Management is actively involved in assuring quality design output, and the engineering staff appears to produce modification packages that are both programatically and technically adequate.
Both the sfte technical staff and respective JPN engineering personnel contacted appeared knowledgeable of their systems and modifications that had taken place or were planned for them.
Review of NCRs revealed engineering provides adequate support to operational concerns and
. problems.
There appears to be excellent interface between site engineering, corporate engineering and consu'Itant engineering.
8904200187 S90410 PDR ADOCK 05000335
REPORT DETAILS Persons Contacted Licensee Employees
- J. Barrow, Operations Superintendent
- G. Boissy, Plant Manager
- S. Brain, Independent Safety Engineering Group
- H. Buchanan, Health Physics Supervisor
- C. Burton, Operations Supervisor
- C. Crider, Outage Management Supervisor
- D. Culpepper, Site Engineering Supervisor
- R. Dawson, Assistant Plant Superintendent, Electrical B. Dean, Technical Staff Supervisor, Electrical
- R. Frechette, Chemistry Supervisor
- J. Harper, guality Assurance Supervisor
- K. Harris, St. Lucie Site Vice President R. Kulauich, System Engineer
- C. Leppla, ISE Supervisor J. Martin, Start-Up Engineer
- W. McGavic, guality Assurance Representative
- L. McLaughlin, Technical Staff
- K. Mohindroo, Electrical/IKC Supervisor, JPN M. Raldi ris,'" Electrical Lead Engineer, JPN
- R. Riha, Nuclear Engineering, JPN
- L. Rogers, Electrical Maintenance Supervisor
- C. Swiatek, Technical Staff
- S. Valdez, Technical Staff Supervisor
- T. Vogan, Engineering Manager, JPN
- E. Weinkam, Licensing Supervisor, JPN
- D. West, Technical Staff Supervisor
- J. West, Operations
- C. Wilson, Mechanical Maintenance Supervisor
- D. Wolf, I8C Engineering Supervisor, JPN
- E. Wunderlich, Reactor Engineering Supervisor Other 'licensee employees contacted during this inspection included craftsmen, engineers, technicians, and administrative personnel.
Other Organizations R. Gonzalez, ISC Engineering Supervisor, EBASCO NRC Resident Inspector
- M. Scott, Resident Inspector
- Attended exit interview Acronyms and initialisms used throughout this report are listed in paragraph.
Modification Control Program (37700)
a
~
PC/M 162-285, Enhancement To Diesel Generator Lube Oil System Unit 2 During the PSL2 fall 1987 refueling outage the subject modification re-arranged the DGLOS soak back system into two separate subsystems.
This enhancement also deleted and recalibrated various pressure indicating devices and replaced four check valves.
The DGLOS was provided with recalibrated pressure indicating switches that perform both control alarm and indicating functions.
This enhancement also incorporated a 3/4 inch flow path to maintain a
low pressure flow of lube oil to the engine oil gallery during the standby mode of operation for the 2A diesel generator.
The subject enhancement coupled with PC/M 142-283 were implemented to alleviate a
problem that has occurred in other plant's diesel generator engines when rapid start was required shortly following a hot shutdown.
During this period, oil will drain back into the engine sump and some of the oil from the strainer box will be siphoned into the cooler creating voids in the system.
Consequently, because of the voids and the lower viscosity of the hot oil, the oil wi 11 not flow to the turbocharger thrust bearings with sufficient pressure on the fast start.
This scenario could cause wiping of the bearing metal so that cumulative damage from several similar starts could result in turbocharger failure.
The inspectors conducted discussions with and queried knowledgeable diesel generator S/U and system engineers concerning the design, functional aspects of the subject modification, and the supporting documentation contained in the modification package.
PC/M documents reviewed in detai I to determine their technical and prograomatic adequacy included:
the subject modification's design basis and design analysis documentation; completed
CFR 50.59, Appendix R, environmental and service evaluations performed; contractor construc-tion work process sheets and related gC inspection records; and the post modification testing records.
All mechanical joints received functional pneumatic bubble leak pressure testing and inspection conducted in accordance with FPLs Procedure No.
ASP 29.
Upon completion of all modifications, the diesel and its subsystems were satisfactorily service tested (Mechanical S/U Test Document 162-285-100, ISC S/U Test Document 162-285-300)
to verify their adequacy prior to operations.
The inspectors verified that revis-ions required to the FSAR, pertinent plant drawings and procedures (operations, maintenance and training) were properly identified by the PC/M and either have been or are in the process of being revised.
The implementation of this PC/M did not required a
change to the plant T The inspectors physically walked down and inspected the installed DGLOS (2A) modification and verified the hardware installation matched applicable drawing No. 2998-G-093, Revision I and reference drawing No. JPE-M-136-285-108, Revision 1.
The latter reference drawing changes the diesel generator system designation number from 17 to
and renumbers all valves, components and instruments with this new designation.
The retagging process is currently in progress and being accomplished under PC/M 136-285.
The inspectors verified that the Unit 2 control room drawing file contained both of these pertinent SRDs as required.
Based on review of PC/M 162-285 and associated changes, the technical adequacy and design change process appear to be satisfactory.
PC/M 051-286, Instrument Air Upgrade - Unit 2 The PC/M provides the details for the installation of two new air compressors (2C and 2D),
two new desiccant air dryers (including prefilter and afterfilter packages)
and removal of the existing desiccant air dryer and afterfilter package which does not have sufficient capacity to accommodate the new compressors.
For normal operation one of the two new 100 percent capacity air compressors and one new air dryer will operate continuously and the other serves as a
100 percent backup.
The existing compressors (2A and 2B) will remain as backups in the case of loss of offsite power; since only these compressors are capable of being loaded on the diesel generator.
The inspectors examined the status of completed work for this modifi-cation since it was under installation during the current Unit 2 outage.
Both new Atlas/Copo air compressor units and their respec-tive Pall Pneumatic dryers with associated instrumentation were found positioned and anchored down on their prepared reinforced concrete pad foundations.
Craftsmen were in the early stages of installation and welding of new piping (designed to ANSI B31. 1, 1973 Edition requirements)
pipe supports and electrical conduct.
No electrical power cable nor instrumentation wiring had been pulled or terminated to date.
The completed work examined appeared to be a
quality nature (ie. meeting code requirements),
well managed, and in agreement with the modification package.
The inspectors reviewed the subject modification package to determine the adequacy of the evaluations performed to meet
CFR 50.59,
CFR 50.49, and ALARA requirements; verify that the subject PC/M was reviewed and approved in accordance with TS and administrative controls; ensure that the subject modification work completed to date was installed in accordance with the PC/M package; ensure applicable plant operating documents (drawings, plant procedures, FSAR, TS, etc.),
were reviewed and the need for applicable revisions to reflect the subject modification identified; and adequate post modification test requirements were specified and scheduled prior to operatio Inspection of this modification to the above listed review criteria resulted in no violations or deviations being identified.
PC/M 275-288, MOV Thermal Overload Modification IEN 84-13, Potential Deficiency in Motor Operated Valve Control Circuit, was generated by the NRC to alert licensees to a specific design in the circuitry used for control and annunciation of certain safety related MOVs.
Pursuant to RG 1. 106 requirement, which states that the TOL should not preclude completion of a safety function, a
bypass feature around the TOL was provided for normal MOV operation.
The TOL was enabled only for test or maintenance activities at which time it could activate on annunciator trouble contact and alert the operator to an equipment degraded condition.
This design, under TOL bypass condition, precluded timely detection of a failure of a safety related motor.
Licensee management in response to the concerns identified in IEN 84-13, developed and implemented-PC/M 275-288 for the AFW Pump 2C Turbine.
The scope of the design change involved modifying the control circuit for PSL2 AFW Pump 2C Steam Valve MV-08-3 such that annunciator G-46, located on RTGB-202, will alarm upon actuation of the TOL device.
This alarm will occur whether the TOL bypass switch is in the normal/
bypass or maintenance/test position.
Based on discussions with licensee management, the inspectors determined that this modification package was in the process of being installed in the field.
An independent design review of the PC/M package was therefore performed and arrangements made for the inspectors to perform field inspection of the installation.
The inspectors did not identify any design deficiencies based on review of Part 1, Engineering, of the PC/M package.
The following drawings, specified in Section 11.0 of the design change package, defined the scope of the hardware changes required to achieve the design objectives:
PC/M DRAWING NUMBER BCS-275-288.3000 BCS-275-288.3001 BCS-275-288.3002 BCS-275-288.3003 BCS-275-288.3004 REV DESCRIPTION/TITLE BRIEF Schem Diag Aux FW Pump 2C Turbine Schem Diag Aux FW Pump 2C Turbine Aux FW Pump 2C Steam Valve MV-08-3 Aux FW Pump 2C Steam Valve MV-8-3 Aux FW Pump Turbine Driver Wiring Diag Sh
of 3
BCS-275-288.3005 BCS-275-288.3006 BCS-275-288.3007 BCS-275-288.3008 BCS-275-288.3009 Condensate Feedwater Ann
"G" Sh
RTGB 202 Aux FW PP 2C Turbine Ann I/M As-Build Notes W/D Panel Assy Sh I & 2 W/D Panel Assy Sh
The inspectors verified, based on review of the above drawings, that the hardware changes shown were consistent with the design scope and design objectives.
Drawing number 2298-B-327, Sheet 32, General Notes, shows the contact development for TSW-632.
Although this drawing is not referenced in the PC/M package, it is required to verify the technical adequacy of 'the changes shown on the referenced drawings.
Licensee management provided the inspectors a copy of this drawing at their request, for use during the independent design review.
The inspectors determined that drafting errors concerning the description of TSW-632 escutcheon were identified by the licensee and corrections were made to drawing number BCS-275-288.3001.
The inspectors verified, by use of the drawing they had requested, that unintended logic changes to the control circuit had not been introduced by the prior drafting error.
However, a potential Human Factor problem could have arisen, during use of drawing BCS-275-288.3001, because of the erroneous TSW-632 escutcheon description shown on the electrical elementary to define different equipment operating modes.
The inspectors performed a field inspection of the work completed under PC/M 275-288 and verified for selected components that the as installed condition matched the as designed drawings.
Within this area no violations or deviations were identified.
PC/M 006-287, NRC Bulletin 85-03, MOV Position Indication IEB 85-03, Motor Operated Valve Common Mode Failure During Plant Transients Due to Improper Switch Setting, was issued by the NRC on November 15, 1985.
It required licensees to develop and implement a
program that ensured valve operator switches are selected, set, and maintained properly for certain safety related MOVs.
In response to IEB 85-03, licensee management developed and implemented PC/M 006-287 for PSL2.
The project scope included modifications to safety related MOVs in the AFW and HPSI systems to achieve the following:
(i)
Increase the close to open torque bypass limit switch setting to 20-25 percent of the opening strok (ii) To rewire the limit switch rotors such that the closed position indicating lights will be wired to a rotor other than the one used for actuating the open torque bypass limit switch.
(iii) MOVs identified by IEB 85-03, Item b, as having two rotor limit switch assemblies will be modified to have four limit switch assemblies to facilitate design objectives (i) and (ii).
(iv) Existing MOVs having four rotor limit switch assemblies wi 11 be modified by internal wiring changes only to achieve design objectives (i) and (ii).
(v)
Provide guidelines for selecting and setting thermal overload relays for MOVs identified in IEB 85-03, Item b.
Part No. 1, Engineering, of the PC/M package specified requirements concerning Design Bases, Design Analysis and documented the Nuclear Safety Evaluation performed in accordance with the requirements of
CFR 50.59.
The inspectors performed an independent design review of the PC/M package and verified that the design process included applicable codes and standards as design inputs for preparation of the design change package.
Section 1.2, System Performance Require-ments, specified a setting of 20-25 percent for the close to open torque bypass limit switch and provided a'asis for this switch setting.
This section further specified that the MOV switch setting policy will be uniform for all safety related valves and wi 11 be established by implementation of PC/M 002-287.
The requirements of the T.S.
and applicable design bases described in Chapter 6 and
of the FSAR were addressed, in Section 2.0, Design Analysis.
Equipment on the E(ML impacted by installation of PC/M 006-287 were also addressed in this Section.
Additionally requirements for the provision of Certificates of Conformance from the vendor for replacement parts were specified.
Based on the review of Part No. I, Engineering, of PC/M 006-287 no design deficiencies were identified.
Additional reviews of PC/M 006-287, Part No. 2, Construction, were performed by the inspectors to verify that the hardware changes were consistent with the,design scope.
Design output documents reviewed during this efforts were specified in the PC/M package Section 11.0, Drawings and Vendor Manuals.
The inspectors verified that hardware changes involving modifying MOVs having two rotor limit switch assemblies were correctly performed.
Reviews of selected CWDs and electrical elementaries were performed to verify wiring changes.
Procurement activities associated with these types of modifications were assessed by review of Purchase Order No.
C53137 37302 and the Certificates of Conformance provided by the vendor for replacement parts.
No design deficiencies were identifie Modifications involving only wiring changes to MOVs having four rotor limit switch assemblies were reviewed by the inspectors to verify conformance with the design objectives.
The following selected drawings were reviewed during this effort.
PC/M Drawin No.
Descri tion/Title BCS-006-287.3017 BCS-006-287.3016 Refuel Water Tank Valve MV-07-1A Refuel Water Tank Valve MV-07-18 BCS-006-287.3018 Reactor Sump Valve MV-07-2A BCS-006-287.3019 Reactor Sump Valve NV-07-28 Pursuant to review of the above drawings the inspectors determined that wiring changes,
-which appeared to be outside the scope of PC/N 006-287, were being made at the RTGB and the MCC compartments.
Discussions with licensee engineering personnel revealed that the wiring changes shown involved trouble contacts required for input to the Isolation Cabinet annunciator.
These changes were necessary to convert the annunciator inputs from normally-open to normally-closed, ie. from "a" to "b" contact state.
The inspectors further determined that the above logic change to the annunciator trouble contacts resulted in the Recirculation 2A and 28, indication lights being continuously lit at the Bypass Indication Display Module.
Corrective action for this deficiency was discussed with licensee management.
Pursuant to these discussions, licensee management committed to completing corrective action prior to the end of the present RFO by implementation of PC/M 284-288, Instrumenta-tion Changes for Human Factors Concerns.
The root cause appears to be failure to modify the appropriate bypass logic card to compensate for the change of state of the annunciator trouble contacts.
Based on additional discussions with licensee engineerings personnel, and review of selected sheets of drawing number 2998-8-327, the inspec-tors determined this issue to be on isolated event.
Review of PC/N 005-187, implemented for Unit 1, verified that a similar situation did not exist.
PC/M package, Part No. 3, S/U/Maintenance was reviewed by the inspec-tors to verify the technical adequacy of the post-modification test requirements and test acceptance criteria.
A field inspection of selected equipment was also performed to verify that the installed equipment was consistent with the as-design drawings.
Based on completion of the above activities, and discussions with licensee engineering personnel, no design deficiencies were identifie e.
PC/M No. 047-287 Replacement of Pressurizer PORV Solenoid Valves PC/M No. 047-287 was initiated to reduce PORV internal leakage.
The existing PORV's assemblies for valves V-1474 and V-1475 contained an internal gasket which formed a part of the valves pressure boundary.
The replacement solenoids utilize a welded pressure boundary seal instead of gaskets.
This change was identified by the licensee as a
vendor design improvement to reduce leakage.
The inspectors reviewed the modification package,'endor documentation and procurement records to determine technical and procedure adequacy of the package.
The modification package consisted of three parts that contained pertinent information about the intended design change.
Part No. I provided information in the following areas:
Design Bases; Design Analysis; Safety Evaluation; Affected Document Checklist; References and Attachments.
Part No.
2 contained information pertaining to construction:
Construction/Implementation Scope; Special Instructions; Equipment and Material; Drawings and Vendor Manuals and Specifications for Implementation.
Part No.
3 contained information pertaining to S/U/Operation/Maintenance:
S/U Testing and Operating Maintenance Guidelines.
The information in each part was very detailed and adequately addressed all possible regulatory concerns.
The inspectors interviewed responsible engineers who were very knowledgeable of the changes being make and the system operations.
The inspectors verified that the design package addressed Eg concerns and procurement require-ments.
A review of procurment documentation, design requirements and FSAR requirements indicated the licensee had done detailed research in assembling the modification package and assuring proper equipment was selected.
The inspectors verified that all seismic concerns were addressed.
The inspectors reviewed the TS and the S/U testing require-ments specified in the modification package and determined that system operability would be demonstrated, once the specified testing is complete.
f.
PC/M No. 078-187 REA 86-091 Replace Pressurizer Level and Pressure Controllers This PC/M was initiated per REA 86-91 after it was determined that the old controllers (Fischer
& Porter)
were obsolete.
Just as in PC/M 47-287 the package was very detailed and adequately addressed all'egulatory and safety concerns.
3.
Responsiveness to Nonconformance The inspectors reviewed open and closed NCR's to determine how engineering responded to. problems identified in the plant.
The inspectors noted the amount of engineering input required varied with each NCR.
Those NCRs that had the potential to cause an operational concern were evaluated and responded to in a expedient manner.
This was noted in a review of NCR 2-178, which was initiated on 2-22-89.
The NCR was issued following an
inspection of fitting ES-4-SP-1, a
65 degree elbow on extraction steam line 20ES4 to the 4B Feedwater Heater.
An inspection performed as part of the 1989 Unit 2 erosion corrosion inspection program identified a
minimum wall thickness of 0.238 'inches.
This reading violated the licensee's screening criteria of 0.270 inches.
Engineering reviewed the NCR and provided a initial response on 2-23-89.
Additional examination of area was performed to verify initial readings.
A final engineering
, disposition of NCR 2-187 was provided on 3-7-89.
The 'iicensee's engi-neers used available data to
. determine an erosion/corrosion rate of approximately 0.60 inches or 60 mills for an 18 month fuel cycle.
Based on the rate of erosion/corrosion that could occur during the next operat-ing cycle engineering concluded the wall thickness for fitting ES-4-SP-I would fall below the minimum allowed operating thickness.
The licensee was replacing the fitting and associated piping under PC/M 218-288 at the time of the inspection.
This responsiveness to the problem identified under 2-178 and other NCRs reviewed illustrates management desire to identify and resolve problems that could potentially result in operational concerns.
Exit Interview The inspection scope and results were summarized on March 10,1989, with those persons indicated in paragraph l.
The inspectors described the areas inspected and discussed in detail the inspection results listed below.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Acronyms and Initialisms AC AFW ALARA ANSI CWD DC DGLOS EBASCO EQML FPL FSAR HPSI ISC IEB IEN JPN MCC MOV Alternating Current Auxiliary Feed Water As Low As Reasonably Achievable American National Standards Institute Control Wiring Diagrams Direct Current Diesel Generator Lube Oil System Electric Bonds and Shares Company Environmental Qualification Master List Florida Power and Light Final Safety Analysis Report High Pressure Safety Injection Instrumentation and Control'nspection
.and Enforcement (NRC) Bulletin Inspection and Enforcement (NRC) Information Notice Juno Plant Nuclear Motor Control Center Motor Operated Yalve
NCR NRC PC/M PORV PIS PSL2 REA RFO RG RTGB SRD S/U TOL TS TSW Nonconformance Report Nuclear Regulatory Commission Plant Change Modification Power Operated Relief Valve Pressure Indicating Switch Plant Saint Lucie - Unit 2 Request For Engineering Assistance Refueling Outage Regulatory Guide Reactor Turbine Generator Board Selected Reference Drawing Start-Up Thermal Overloaded Technical Specifications Test Switch