IR 05000335/1991004
| ML20138F642 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/15/1991 |
| From: | Crlenjak R, Elrod S, Jape F, Michael Scott NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20138F614 | List: |
| References | |
| 50-335-91-04-01, 50-335-91-4-1, 50-389-91-04, 50-389-91-4, NUDOCS 9610180019 | |
| Download: ML20138F642 (23) | |
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jag afo u UNITED STATES f 'o
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NUCLEAR REGULATORY COMMISSION I O"
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REGION 11
$ 101 MARIETTA STR EET, *
s ATLANTA, GEORGI A 30323
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Report Nos.: 50-335/91-04 and 50-389/91-04 Licensee: Florida Power & Light Co 9250 West Flagler Street i Miami, FL 33102 Docket Nos.: 50-335 and 50-389 License Nos.: DPR-67 and NPF-16 Facility Name: St. Lucie 1 and 2
, Inspection Conducted: January 23 - March 18, 1991 Inspectors E ,
4 of S. A. Elrod,'Seni r Resident Inspector Date Signed
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. A. Scott,' Resident Inspector a4 u. 4, Date S'igned '
A f1 M k W N/2-/7/ ~~ *-
Fr Jape, S ion pief Datd Signed'
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Approved By: ,
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R. V.Krlbnjak, 866 tion Chief Date'Sig6ed
- Division of Reactor Projects
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SUMMARY
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Scope:
This routine resident inspection was conducted onsite in the areas of plant operations review, maintenance observations, surveillance observations, review of special reports, review of nonroutine events, and followup of previous inspection finding Results:
The Unit 1 shutdown to test control element assemblies (CEAs) was well controlled. Unit 1 also had three events that were well handled. They resulted in licensee event reports (LERs) and a special emergency diesel generator (EDG)
report. Certain maintenance and surveillance activities resulted in challenges to the operators or safety systems. These included automatic initiation of auxiliary feedwater (AFW) during operation, dropping of a CEA during shutdown testing, e d four of eight reactor trip breakers opening simultaneousl uimmpsak 9610180019 910415 PDR 0 ADOCK 05000335 PDR
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l Operator responses to plant events were well handle .
Within the areas inspected, the following non-cited violations (NCVs) were identifie NCV 335,389/91-04-01, Specification of Improper Thread Sealant in Safety-related Applications, paragraph 2 NCV 335,389/91-04-02, Inadequate Control of Post-Maintenance Tests, ,
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NCV 335/91-04-03, Failure to restore 1B Component Cooling Water Pump Missile Shield After Maintenance, paragraph 2 NCV 389/91-04-03, Failure to Scope Change a Nuclear Plant Work Order Controlled Test of 2B EDG Field Control Circuits, paragraph l l
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REPORT DETAILS
l - I l Persons Contacted l 1 l
Licensee Employees i l
D. Sager, St. Lucie Site Vice President _
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- G. Boissy, Plant Manager J. Barrow. Fire Prevention Coordinator
- C. Burton, Operations Superintendent R. Church, Independent Safety Engineering Group Chairman
- H. Buchanan, Health Physics Supervisor
- D. Culpepper, Site Engineering Supervisor
- R. Dawson, Maintenance Superintendent
- * R. Engimeier, Site Quality Manager l * R. Frechette, Chemistry Supervisor l C. Leppla, I&C Supervisor L. McLaughlin, Plant licensing Superintendent
- A. Menocal, Mechanical Maintenance Supervisor
- 0. Oliver, Material Management Superintendent L. Rogers, Electrical Maintenance Supervisor N. Roos, Services Manager 3 C. Scott, Outage Management Supervisor
- D. West, Technical Staff Supervisor J. West, Operations Supervisor
. W. White, Security Supervisor
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G. Wood, Reliability and Support Supervisor
- * E. Wunderlich, Reactor Engineering Supervisor i .
I Other licensee employees contacted included engineers, technicians, l operators, mechanics, security force members, and office personne NRC Employees l
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- S. Elrod, Senior Resident Inspector i * M. Scott, Resident Inspector
- * R. Marston, Radiation Specialist F. Jape, Section Chief
- Attended exit interview l
Acronyms and initialisms used throughout this report are listed in the last paragrap . Review of Plant Operations (71707)
Unit 1 began the inspection period at power but shut down for one day on January 28 for NRC-required full length exercising of the CEAs. The unit i
ended the inspection period in day 48 of power operation.
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Unit 2 began and ended the inspection period at power - day 102 of power operatio During this period, the licensee made several significant personnel l assignment Mr. C. Burton was appointed Operations Superintendent, M l J. West was appointed Operations Supervisor, and Mr. A. Menocal was i appointed Mechanical Maintenance Superviso Plant Tours The inspectors periodically conducted plant tours to verify that monitoring equipment was recording as required, equipment was properly tagged, operations personnel were aware of plant conditions, and plant housekeeping efforts were adec,uate. The inspectors also determined that appropriate radiation controls were properly established, critical clean areas were being controlled in accordance with procedures, excess equipment or material was stored properly, and combustible materials and debris were disposed of expeditiousl During tours, the inspectors looked for the existence of unusual fluid leaks, piping vibrations, pipe hanger and seismic restraint settings, various valve and breaker positions, equipment caution and danger tags, component positions, adequacy of fire fighting equipment, and instrument calibration date Some tours were conducted on backshifts. The frequency of plant tours and control room visits by site management was noted to be adequat The inspectors routinely conducted partial walkdowns of ESF, ECCS and support system Valve, breaker, . switch lineups and equipment conditions were randomly verified both locally and in the control roo The following accessible-area ESF system walkdowns were made to verify that system lineups were: in accordance with licensee requirements for operability and equipment material conditions were satisfactory: Unit 1 and 2 CCW platforms, Unit 1 SFP, 1B EDG, Unit 1 and 2 cable spreading rooms, and Unit 1 and 2 battery room During the walkdown of the Unit 2 CCW platform, the 2B CCW heat exchanger was found leaking from the mechanical joint between the shell and the ICW inlet channel head. The minor 24-drop-per-minute leak posed no threat to unit operation. The weld adjacent to this joint was of recent interest due to weld problems discussed in irs 335,389/90-30 and 90-31 (LER close out). Due to those considerations, the normal leak repair option of retorquing the mechanical joint fasteners was not performed. NPWO 3803/62 was generated to repair the joint during the next refueling outage. This long term planning was acceptabl By the end of February, the leakage had stopped on its ow During a walkdown of the Unit 1 CCW platform on February 28, two of six connector plates were found missing from one end of an I-beam supporting the IB CCW pump missile shield overhead. A plastic half gallon jug of lubricating oil labeled with a marking pen was
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j also found stored in the web of a -side bea The licensee
. immediately removed the oil, manufactured new plates, and restored _
, the missile shield to its desig The other missile shields were
examined and found correc The licensee determined that the connection plates had been removed during missile shield disassembly I to support NPWO 3240/61 between June 13 and 26,1988. Licensee
- engineering evaluation of the as-found missile shield operability
showed that the missing plates degraded the missile shield somewhat l but it continued to provide design protection levels.
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Licensee review - of several maintenance procedures dealing with
! equipment protected by missile shields showed that the procedures did l -
not clearly restore missile shields to their design following removal l for equipment maintenanc This is contrary to TS 6.8.1 wr > ,i
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- requires that procedures be established and implemented to caer i . activities recommended in Appendix A of Regulatory Guide 1.33. The
- licensee subsequently revised these procedures to include the proper 4 requirements and independent verification of completed action.
. This violation is not being cited because the criteria cited in
! section V.G.1 of the NRC Enforcement Policy were satisfied. This
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item is identified as NCV 335/91-04-03, Failure to Restore the IB CCW Pump Missile Shield After Maintenance, i l
} During a walkdown, the 2B battery rack plastic rail insulation was j i found cracking into large flakes. This unusual condition was pointed out to the licensee management for evaluation. The licensee plans to i replace the side. rail covers during the next refueling outage and the l l bottom rail covers whenever the batteries are next removed from the ;
- racks.
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! On February 6, the thermal overload / bypass switch for Unit 2 HCV
- 3627, located in MCC 2A6, was found by the inspector in the
- maintenance-test position vice the TS-required overload bypass
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position. This placed Unit 2 into a 72-hour LC0 action statement per TS 3.4.5.2, ECCS Subsystems - T avg greater than or equal to 325 F.
, Checking switch position was an 18 month surveillance per TS 4.8.4.a.
i but the position was routinely checked daily by the operators. This
! switch appeared to have been mispositioned when the MCC was masked
! for painting earlier that da An operator immediately restored the
. correct switch positio All other switches were found to be correctly positioned.
l - During a walkdown of 2B EDG, a new black thread sealant was observed applied'to pipe threads on the nipple attaching the starting air tank
- relief valves to the starting air tanks, an ambient temperature i application. The sealant container indicated that the sealant, named
PRI-102N, should be stored below 20 degrees Fahrenheit and that the use temperature range was 150 - 1000 degrees Fahrenheit. Review of l storage requirements showed that the licensee did not implement these i directions. The vendor informed the licensee that the storage
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temperature requirements were to extend shelf life, that in the 80 -
- 100 degrees Fahrenheit range, the material would at least provide thread lubrication for the threaded joint, and that the material would not harm the stainless steel fittings. The inspector found the licensee's understanding and control of this sealant to be
, inadequate. The threaded nipples were replaced several times before i
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joint leaks were stopped, however these minor air leaks did not make the EDGs inoperable.
I Subsequent licensee review found that the planners were improperly I
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specifying this sealant because AP 0010507, Rev 2, Control of Chemicals and Materials for Maintenance of Plant Systems, did not identify the limiting applications of several compounds and also did not clearly identify which systems were meant by "RCS" or " Fuel Pool" l or " Secondary". This is contrary to TS 6.8.1 which requires that procedures be established and implemented covering activities recommended in Appendix A of Regulatory Guide 1.3 The Regulatory
, Guide recommends written procedures for limiting the concentration of agents that may cause corrosive attack or fouling of heat transfer
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surface It also recommends procedures for maintenance that can affect the performance of safety-related equipment. AP 0010507, Rev 2, Control of Chemicals and Materials for Maintenance of Plant Systems, was the licensee's vehicle for ensuring appropriate use of chemicals and materials in maintenance. These items were correcte This violation is not being cited because the criteria cited in section V.G.1 of the NRC Enforcement Policy were satisfied. This item is identified as NCV 335,389/91-04-01, Specification of Improper Thread Sealant in Safety-Related Application Plant Operations Review The inspectors periodically reviewed shift logs and operations records, including data sheets, instrument traces, and records of equipment malfunction This review included control room logs and auxiliary logs, operating orders, standing orders, jumper logs, and equipment tagout records. The inspectors routinely observed operator alertness and demeanor during plant tours. They observed and evaluated control room staffing, control room access, and operator performance during routine operations. The inspectors conducted random off-hours inspections to assure that operations and security
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performance remained at acceptable levels. Shift turnovers were l observed to verify that they were conducted in accordance with approved licensee procedure Control room annunciator status was l verified. Except as noted below, no deficiencies were observed.
l l During this inspection period, the inspectors reviewed the following
tagouts (clearances):
l 1-1-107 MV 14-3 Unit 1 CCW Pump Suction Cross Tie,
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1-1-129 1A2 Circulation Pump and Water Box,
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1-2-34 'TCB 5 Unit 1 Reactor Trip Breaker, and 2-2-108 2B EDG Replace Starting Air Pipe Nipple The inspectors reviewed quality assurance activities and findings concerning control room operations to determine if the objectives were being met. The following activities were reviewed:
Quality Assurance Audit Performance Monitoring Report - November QSL-0PS-90-780, of December 20, 1990; Quality Assurance Audit QSL-0PS-90-773, Refueling Sequencing Activities, of December 20, 1990;
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Quality Assurance Audit QSL-0PS-90-766, Class 1E 4XV Breaker and Cubicle Modification, of December 28, 1990; and Quality Assurance Audit Performance Monitoring Report - October, QSL-0PS-90-772, of November 16, 199 These audit reports containad two findings that were minor. The overall scope of the activities reviewed and observed appeared to be i extensiv '
Unit I was shut down to hot standby, Mode 3, on January 28 to full stroke exercise the CEAs. This was the second time this was accomplished on this unit. The exercise was last accomplished on October 27, 1990, as discussed in IR 335,389/90-3 The applicable procedures in effect for the shutdown, required mode change testing, and CEA exercise were:
OP 1-0030128, Rev 7, Reactor Shutdown to Hot Standby; OP 1-0030125, Rev 22, Turbine Shutdown - Full Load to Zero Load; OP 1-0030150, Rev 43, Secondary Plant Operational Checks &
Tests; and L01-0-40, Rev 0, Testing of Original Desian Type #1 Control Element Assembl The shutdown, Unit l's 217th, was controlled and relatively uneventfu At the point of switching from the main feedwater regulating valves to the 15-percent capacity feedwater regulating valves, the A train main feedwater regulating valve was found to leak -
by when closed. Its associated block valve was then shut to limit main feed flow to the A SG. Several feedwater heater level control valves required some monitoring by operators. CEA number 45 had some
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mid-travel indication problems during CEA insertio These were
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minor problem '
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! During CEA exercising, with Unit i shut down and stable, a reactor
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operator's personnel error during non-related simultaneous testing !
generated an inadvertent reactor trip signa The operator was performing a loss-of-turbine trip test, OP 1-1400054, when he turned
! a wrong switch, completing the reactor trip logic. The "A" channel l
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high-startup-rate subchannel .was out of service and had been I
!' previously placed in the tripped position. The operator reached for i l a "B" channel linear power trip test switch but instead turned the j i "B" channel high-startup-rate test switch. This satisfied the trip l
- logic. The TCBs opened as designed, dropping the one CE Equipment
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functioned properly during this event. The only result of the error
- was that the CEA being exercised was inserted into the core to join .
'I the other fully-inserted CEAs. The licensee made the proper event l notifications. The licensee also involved their human factors
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personnel in the event review preceding a written LE l
During after-shutdown inspections of the Unit 1 containment, the
. . licensee .found boric acid on the lagging of RCS loop check valve
- V 3247. Site personnel removed the lagging, inspected the valve, and found that the disk-hinge-pin end caps were leaking one-half to one
]- quart of water per hour.
- Based on the following considerations and prior experience, the
licensee deferred repair but left the lagging off the valve.
f FPL valve. drawing 8770-1216 (Atwood & Morrill drawing 21152-H), j i showed that the valve components were all constructed of ' 1 1 corrosion resistant material, which meant that the boric acid
! would not deteriorate the valve.
4 Attempts to tighten the hinge pin cap fasteners would have j . probably aggravated the leaks.
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- Repair of the valve would have required plant . shutdown to cold i conditions and partial drainage of the RCS.
- The present leakage would probably not increase greatly and was well below the TS-allowed leak rate.
! Leaving the lagging off the valve would facilitate future
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inspection It also would allow the leakage to flow
, immediately to floor drains instead of potentially running down i the lagging interior to drip on previously unaffected j components, After the CEA exercise, the licensee restarted Unit 1 on January 2 . The turbine output breaker was closed at 3:12 a.m. Later checks of
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containment radioactive particulate and gas levels indicated no
- upward trendin At 100 percent power on January 30, the IB heater drain pump discharge valve failed closed, which tripped the heater drain pum Operators reduced reactor power fast enough to prevent a reactor trip and stabilized the plant at 93 percent pgwe Evaluation of the 1B heater drain pump discharge valve's internal
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trim indicated that the lower guide / skirt had eroded to the point I that valve internals caught on the inside of the valv The
! resultant stem forces caused the valve stem to snap outside the valve l
body. No valve parts escaped the valve body. The "B" train heater drain valve was repaired in conjunction with vendor and engineering input. The valve had not been inspected since about 1982 when the valve trim was modified per a PC The valve was placed on an inspection schedule. Importantly, the 1A valve trim did not have a skirt to catch, had been inspected in 1990, and was scheduled for inspection at the next refueling outage. The mechanical maintenance department generated a root cause and corrective action package for future referenc While performing the Unit 1 monthly AFAS D channel surveillance test, I&C technicians found that the 1-3 initiation relay-light was not lit. The concern was that there may have been no power in one of two paths to this relay. The surveillance was stopped and NPWO 6151/61 was written to investigate the no light / relay concer NPWO 6151/61 did not invoke procedure AP 0010142, Unit Reliability -
Manipulation of Sensitive Systems, that would have caused more shop preparation time and maintenance management pre-implementation l revie The NPWO work was performed by the technicians who had been i performing the surveillance and who had initially discovered the i proble During troubleshooting, the D channel was placed in bypass, I which bypassed the actuation logic circuits but not the initiation l circuits where the troubleshooting was being performed.
l Troubleshooting under the NPWO opened one of two power paths to the
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1-3 relay in an attempt to locate a bad screw-type fuse (three in each of two paths). The technicians inadvertently unscrewed a fuse in the other power path, which deenergized the 1-3 relay. Once the 1-3 relay was deenergized, the 1C AFW pump circuitry was actuated and the pump started. The operators immediately realized that the pump had started, had the technicians re-install the fuse, and then stopped the pum No injection of CST water occurre The licensee I
made notifications per 10 CFR 50.73 and was preparing an LER. Site management has increased the site sensitivity to the use of the sensitive systems procedur On February 12, the licensee performed the quarterly stroke test on Unit 1 MV 09-11, one of two AFW injection valves available for the 1C AFW pum It passed the test, requiring a few seconds longer to
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4 stroke than the previous test but within the acceptance criteria of
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AP1-0010125A, Rev 18. Surveillance Data Sheets, Data Sheet 8 The valve had ast been M0 VATS tested in March 1990.
On February 15, the licensee was making cold weather preparations for an impending cold front with potentially subfreezing conditions. On l this day, the systems engineer toured the steam trestle space containing MV 09-11. On February 16, a Unit 1 operator checked shut MV 09-11 by turning the control room hand switch to closed with the valve already in the closed position. This check shut was to prevent
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l potential valve leakage due to changes in valve clearances or valve i position differences caused by ambient temperature changes (cooling). l Remotely checking the valve shut was an acceptable operation with i this valve because the actuator's torque switch should prevent j overtorqu At about noon on February 17, a non-licensed operator found the valve's handwheel, with the thrust bearing plate attached, laying on the floor below the valv The plate was normally bolted to the valve actuator by four 5/16 inch bolts. The bolts had been broken by the stem force resulting from valve overtorque. Both the i actuator stem and valve stem had been bent, and the actuator stem was '
completely disengaged from the actuato The stem overtravel distance taken up by the bending was approximately 1-1/4 inch, l equating to about 20 to 25 seconds of actuator operatio In i summary, after being checked shut, MV 09-11 would not have re-opened I electrically or manuall The licensee made the appropriate notifications in accordance with 10CFR50.73 requirements and is generating an LER on the event. The impact of the valve failure was l that the 1C AFW pump could pump only to the 1B steam generato Each l 100-percent-capacity motor-driven pump could pump to both steam i generators if require The licensee removed, repaired, and tested the MV 09-11 actuator utilizing NPWO 5239/61 and procedure MP 0940075, Rev 1, Maintenance l and Repair of Limitorque Valve Actuators Type SMB 000. A separate NPWO replaced damaged valve trim parts. The licensee did not find a l root caus I Actuator disassembly revealed no cause. The torque switch was bench tested satisfactoril The spring pack was in good shape j and was not hydraulically locke l Nothing found in the valve itself was implicated in the failur l The 120 V DC contactor for the actuator was examined and teste l Visual and manual inspection revealed free travel, no contact 1 corrosion, and no excessive contact pittin Contactor actuation timing was about 20 ms (50 ms usually indicates problems).
l The rebuilt valve and actuator with its unadjusted torque switch I were re-assembled and M0 VATS teste Testing indicated
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satisfactory operation and did not pinpoint a root cause for the
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i The licensee discussed the problem with the actuator vendor who
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did not offer any suggestion l The valve was returned to service on February 1 The licensee replaced the torque switch on February 21 and, when it becomes i available, will replace the contactor as a conservative measure. The contactor had a July 1991, delivery dat Retesting after each
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component replacement was again satisfactory. A caution tag was
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installed on the control room hand switch for MV 09-11 stating that
- _ electrical personnel must be at the valve during routine operatio This conservative measure will remain in effect until the new
- contactor is installe On February 19 at 10
- 30 am, with Unit 1 at 100 percent power, the 1B CCW pump tripped for no apparent reason. Operations personnel ,
changed the valve lineup and placed the 1C swing CCW pump into '
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- operation within a half hour in accordance with ON0P 1-0310030, Rev
- 1, Component Cooling Water - Off Normal Operation. During the transition, the unit was in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO.
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Root cause investigation of the pump trip revealed an unusual relay location. The CCW pump motor breaker cubicle door had a number of relay devices installed on it such that there was insufficient room
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for the overcurrent relay. That relay had been installed on the door
- of the adjacent breaker cubicle, which served the B train HPSI pum This condition existed on the A train also. Though the overcurrent relays were marked to identify which cubicle they protected, the identification markings were smal Nothing on the cubicles l
. themselves identified the relay function. The historical information '
l regarding these relays resided in the electrical group's comon
- knowledg The sensitive system marking program re-instituted j
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several months ago did not add markings to this relay. NPWO 4405/61 administratively controlled the installation of a ground test device
- in the IB HPSI pump breaker cubicle. The licensee was able to
- establish that, when electricians subsequently reinstalled the HPSI pump breaker, the door with the attached overcurrent relay was not open quite far enough and the overcurrent relay was struck hard enough by the breaker front to trip the 1B CCW pump.
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Initial investigation found that the relay was seismically qualifie Corrective actions concerning this condition will be addressed in IR 335,389/91-0 On February 20, at 10:37 p.m., with Unit 1 at 85 percent power and with the IB CCW pump out of service, the 1C CCW pump trippe At least six annunciators alarmed in the control roo Operators confirmed that it was a pump trip and understood that the cause was probably electrical. Attempted restart of the 1C pump produced
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{ sparks from the motor shrou Operators immediately initiated l . plant-condition-oriented corrective action and cross tied the CCW
! headers by 10:40 p.m. This' configuration provided cooling flow to
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both A and B train components using the 1A CCW pump and both A and B
'CCW heat exchangers. By 11:15 p.m., CCW flow to non-essential loads was isolated to increase flow to safety-related _ load CCW temperature was monitored to ensure FSAR-specified cooling was occurring. With the failure to restart the 1C pump, the licensee entered an action statement per TS 3.7.3. The licensee expedited returning the 1B CCW pump to service by 5:30 a.m., then exited the TS action statement. Operations ' was considering possible procedure changes to address operator actions when only one pump is availabl The 1C CCW pump motor was removed and shipped for rewind due to an L apparently failed phas The vendor has also been tasked with root cause identificatio Repair time was to be approximately four week On February 25, the Unit 2 reactor protection system channel B main 15 ampere fuse blew and tripped open four of the eight reactor trip circuit breaker Since no other protection channel inputs were degraded, this did not trip the unit. The operators coordinated well the plant staff investigation and the recover RPS channel B was repowered and restored to service in two hours. The cause was found to be a cooling fan flow-indicating light bulb being changed. It had I no inline resistance or fuse and was powered directly_ from the electrical suppl The unusual bulb .and socket design did not )
inhibit an arc across the bulb base and evidence of such an arc was l plainly visibl The licensee was coordinating a. potential design change with the NSSS vendo Technical Specification Compliance Licensee compliance with selected TS LCOs was verifie This included the review of selected surveillance test results. These verifications were accomplished by direct observation of monitoring
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instrumentation, valve positions, and switch positions, and by review ,
l of completed logs and records. Instrumentation and recorder traces '
were_ observed for abnormalities. The licensee's compliance with LC0 action statements was reviewed on selected occurrences as they '
happene The inspectors verified that related plant pwadures in use were adequate and complete (except as noted above), and included ;
the most recent revision Physical Protection
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The inspectors verified by observation during routine activities that
! security program plans were being implemented as evidenced by: proper i display of picture badges; searching of packages and personnel at the plant entrance; and vital area portals being locked and alarme .~ - .- - _ -
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3 11 Aside from the operator error during the Unit 1 Turbine trip test,
- operator performance was goo Several Unit 1 events were well handled by
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the staff.
. Surveillance Observation (61726)
Various plant operations were verified to comply with selected TS requirement Typical of these were confirmation of TS compliance for reactor coolant chemistry, RWT conditions, containment pressure, control a
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room ventilation, and AC and DC electrical source The inspectors verified that testing was performed in accordance with adequate procedures, test instrumentation was calibrated, LCOs were met, removal and restoration of the affected components were accomplished properly, test results met requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The surveillance tests observed and problems encountered are discussed belo During the performance of 2B EDG governor oil PM starts, the electrical maintenance staff noted that the diesel would accelerate to its normal -~-
start rpm but would only load to about 2000 K The 2B2 hydraulic governor control limit switch had faile The licensee generated special report L-91-55 (10 CFR 50.36) of February 15, 199 NPWO 4407/62 controlled the 2B2 diesel governor limit switch replacement and tested the functionality of the switch during a normal surveillance run per OP 2-2200050, Rev 27, Emergency Diesel Generator Periodic Test and General Operating Instruction The NPWO contained specific FRG-approved instructions for post-repair-switch testin These were utilized conjunctively with the surveillance tes With the engineer present, a non-licensed operator performed the test at the diesel's local pinel. The testing proved that the new switch was operating satisfactorily. This was the third failure of the 2B EDG in its last 100 start During this testing, the licensee noted that the associated 125 V ground annunciator would temporarily illuminate and then clear when the EDG was started. Investigation revealed a partial ground on the 28 generator field control circuit boards. Troubleshooting indicated that the ground was not degrading and did not affect adequate generator field strength or required EDG output. The problem was discussed with FRG members. The FRG agreed that the circuits would operate as desire Since the new board required extensive calibration and would not be available for the existing time window, a satisfactory surveillance was performed. The EDG was declared back in service on January 1 The electrical department and the technical support staff developed a repair game plan and an extensive post-repair test procedure for the repair and testing of the 2B EDG field control circuits at its next scheduled surveillanc FRG-approved NPWO 5767/62 controlled the repairs J
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- that removed the ground fault and also contained tht pust-repair test i . procedure to use in conjunction with OP 2-2200050 identified abov The repaired 28 EDG was tested on January 30 with electrical department and technical support personnel at the EDG. During this test, control room operators ran the test instead of personnel at the EDG local pane The operations personnel made wording revisions to the electrical department NPWO and performed the test slightly differently than originally approved. They did not have the electrical staff submit the
- revisions for FRG approval as a scope change per section 8.6 of AP 0010432, Rev 48, Nuclear Plant Work Orders. This is contrary to TS 6. ,
which requires that procedures be established and implemented covering :
activities recommended in Appendix A of Regulatory Guide 1.33. The i Regulatory Guide recommends written procedures for maintenance that can l affect the performance of safety-related equipment. Procedure AP 0010432, l Nuclear Plant Work Orders, specified that scope changes occurred when work l was required outside the scope of the approved NPWO work description and I that scope changes to NPW0s required the same level of approval as the I 1 original documen l i-The 2B EDG NPWO changes did not reduce test stringenc One change
- increased the initial EDG loading to reduce the likelihood of a reverse
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power trip. The other noteworthy change made the heat run EDG loading consistent with the surveillance procedure 0P 2-2200050 loading valu The actual surveillance test was completed satisfactorily and overall EDG operation was excellen When apprised that the NPWO had been inappropriately changed by the operations staff, the licensee completed a NPWO scope change and obtained FRG re-approva The appropriate personnel were counselled by plant management on the above AP requirements. The licensee was discussing using a separate procedure for testing in lieu of a NPWO addendum in the i futur This licensee-identified violation is not being cited because of the criteria cited in section V.G.1 of the NRC Enforcement Policy were satisfie This item is identified as NCV 389/91-04-03, Failure to Scope Change a NPWO Controlled Test of 2B EDG Field Control Circuit i Testing per OP 2-1400054, Rev 2 Reactor Protection System - Loss of Turbine Hydraulic Fluid Pressure Low, was performed on February 1. The inspector observed the satisfactory completion of this surveillanc Good
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communication was exhibited during its performanc During this inspection period, electrical maintenance performed lubrication PMs on Unit 1 MV 14-3 and 14-4 actuators. The valves open to the suction of the 1C CCW pump from the A and B train CCW return line NPW0s 4351/61 and 4352/61, respectively, controlled the PMs and required cycling of the valves for functional testin AP 1-0010125A, Rev 18, Surveillance Data Sheets, sheet #88, provided acceptable valve stroke times consistent with ASME Code Section XI. Cycling and stroke times on these valves were acceptabl _ _ - . . - - - .
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These valves were of interest for several reason NRC Information Notice
- 90-73, Corrosion of Valve-to-Torque-Tube Keys in Spray Pond Cross Connect Valves, discussed problems with Pratt valves in submerged application Currently, the licensee has this notice under review for possible action.
- At this site, two such valves are used in a submerged application. A
- number of Pratt valves such as these, which are not submerged, are used
- throughout both units. They are exposed to.the weather and a salt-laden 2 environment in many instances. Previously, two similar air operated i non-submerged Pratt valves froze in place while in a non-safety-related, nearly static, temperature control application on the open blowdown heat
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exchangers. Due to heavy corrosion, t a $ tem bushings welded to the valve bod The bushings were below the 11p of the valve's side such that
- standing moisture could exis MV 14-3 and 14-4 do not have the same
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configuration but could experience salt intrusion between the stem and packing cap or strongback. At the time of the PMs, both MVs exhibited no corrosion at this joint.
i On March 4, the inspectors witnessed the Unit 2 MSIV and MFIV periodic i
tests per OP 2-0810050, Rev 14, Main Steam /Feedwater Isolation Valve Periodic Test. Concurrently, MFIV PM 20-M-0018, Rev 22, was observed on HCV 09-2A using NPWO 207 This PM performs hydraulic system maintenance such as changing the oil filte Test and PM preparation, coordination, and control were excellen During this observation, several small instrument air leaks were observed, l The persons participating in the surveillance thought others would report l these leaks. No one did. The maintenance supervision, when informed,
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- took corrective action to have the systems re-examined, leaks addressed,
and the staff counseled concerning management expectation '
Aside from the NCV discussed, overall surveillance activities were well executed.
- MaintenanceObservation(62703)
Station maintenance activities involving selected safety-related systems
. and components were observed / reviewed to ascertain that they were
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conducted in accordance with requirements. The following items were considered during this review: LCOs were met; activities were l
) accomplished using approved procedures; functional tests and/or l calibrations were performed prior to returning components or systems to I service; quality control records were maintained; activities were l
accomplished by qualified personnel; parts and materials used were properly certified; and radiological controls were implemented as
, require Work requests were reviewed to determine the status of .
. outstanding ' jobs and to assure that priority was assigned to I i safety-related equipmen Portions of the follcwing maintenance
activities were observed:
NPWO 5487/62 on Unit 2 administratively controlled repacking of MV
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08-19B, a main steam atmospheric dump valve. Repacking w'as necessary l
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, to prevent steam damage from a minor packing leak._ The valve was
! - satisfactorily repacked in accordance with procedure GMP M-0043, Rev l
7. Valve Repackin NPWO 5756/62 on Unit 2 administratively controlled valve actuator testing of MV 08-198. The valve parameters were acceptable per the testin The above repacking, the cause for the testing, had caused a slight'and expected reduction in the driving torque on the valv NPWO 7766/61 on Unit 1 administratively controlled the replacement of FT 09-2C,1C AFW pump flow transmitter. The technicians utilized
- vendor instructions to accomplish the change-out. The change-out was ,
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based on the information provided in NRC Bulletin 90-01, Loss of l Fill-0il in Transmitters Manufactured by Rosemount, that discussed i transmitter internal oil leaks that may-cause dysfunctio The replaced FT had not shown any functional abnormalities during its
,- last monthly calibratio Parts and "0" ring grease, a shelf life j item, used during the work were well controlled. The FT was tested
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in accordance with good shop practice and procedure I&C 1400064F, Rev j i 15. Installed Plant Instruments (Flow), Appendix "C". '
NPWO 5716/61 on Unit 1 administratively . controlled the repair of TCB number During an RPS logic matrix test, this TCB failed to close '
(remained in a safe position). The electrical shop replaced an "X" l type anti-motoring relay with a new one having supposedly appropriate credentials / pedigre That action was supposed to repair the breaker, however the breaker still would not clos l The day shift personnel that had replaced the relay did not normally work with these GE Model AK 2-25 breaker The non-licensed operator that had placed the TCB into test position for the day crew had just transferred to Unit 1 for refamiliarization. A' spring loaded sleeve
- around the racking shaft had hung up -on the shaf t's drive pin. The >
l pins receive the notches of the speed wrench that slips over the
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shaf t end when racking the breaker. When the sleeve is normally L driven in around the shaft during racking (in or out), the breaker is i in a tripped state due to the sleeve's depressed positio The ( non-licensed operator and day shift electrical personnel did not i remember.the effect of the sleeve hanging up on the drive pi Peak shift (or second shift) normally did repairs and PMs on these particular breakers. When peak shift came on duty, they immediately mentioned the sleeve hanging up as an option for the dysfunction and proved that to be the case. The breaker tested satisfactorily after the sleeve was positioned properly.
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During the TCB 5 repair, a new engineering effort became apparent.
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, Material engineers had recently reclassified certain types of repair parts with new procurement levels and requirements. In the case of l
this replacement "X" relay, it had been changed- from a commercial procurement level to a quality classification that dovetailed with
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electrical class E-1 and included vendor-provided documentatio . This particular relay was not safety-related by function since it
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closed the breaker. The reclassification for the relay was a conservative actio The initial replacement relay drawn from stores had not been reclassified under the new program, but existed in tne stock . system under the same vendor-provided part number as the upgraded relay Prior to returning the breaker to service, the electrical department realized this and located the correct, upgraded relay purchased from the same vendor who built the breaker. The new or second relay did not fit the mounting bracket on the breake The new relay was
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physically different from both the original and initial replacement relays, which were twins. A new bracket had to be installed with the new rela The licensee corrected their stock system part identification for the relay. The licensee expected more procurement upgrade program implementation problems of this typ NPWO 1920/61 administratively controlled work on the lube water strainer SS-21-3Al for the Unit 1 ICW pumps. Multiple strainer parts were replaced and cleaned, and the strainer was returned to service on February 8. On February 11, three days after the equipment was returned to service, the QI 11 post-maintenance test form, part of the NPWO package, was brought to the Unit 1 control room for operations department performanc The mechanical maintenance group used a procedure form from QI 11-2 to track test requirements and completion for components being repaired. The required testing was a visual inspection of the i component during operation with no evidence of leakage. Subsequent review showed that when operations valved the strainer back into service, the non-licensed operator who would have normally performed this type of test actually observed strainer operation and reported its condition back to the control roo The results of the observation were not formally documented on the QI 11 form that arrived in the control room three days late The Journeymans' Work Report pages appended to the NPWO detailed that operations personnel were on hand to verify that the strainer backflush feature worked properl Procedure 1-M-0018, Rev 19, Mechanical Maintenance Safety-Related Preventive Maintenance Program, Appendix A, had been completed verifying that the mechanic observed the proper backflush cycle and that there was no external leakage observe This duplicated the QI 11 form requirements but was documented by the wrong department. On February 11, the NRC inspector also observed that there was no strainer leakage. In sunnary, it was apparent that the specified testing, the operations department observation of satisfactory strainer operation, had occurred but the operator had not been formally tasked to do this as a test function nor had the test been formally documente This was thought to have been an isolated cas . _ . _ _. __ . - _ _ _ . _ _ _ _. _ . _ . . _ _ . . _ . _ . _ _ _ _ _ _ _ . . _ _
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This is contrary to TS 6.8.1 which requires that procedures be
. established and implemented covering test activities of safety related equipment. The TS and the FSAR identified the ICW system as safety relate The applicable procedure involved, QI 11-PR/PSL-2, Rev 20, Mechanical Test Control, required that testing of the component be completed prior to returning it to service. Procedure sections 5.7, 5.8, and 5.16, step 3, addressed return to service requirements.
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! This situation was mitigated by the informal operations actions when l valving-in the strainer and the mechanics' documentation of their
! action Licensee review identified that the specified l post-maintenance test may not actually be a factor in determining l
operabilit The coordination process was modified to provide t
operations control of post maintenance testing.
l This licensee-identified violation is not being cited because the l criteria cited in Section V.G 1 of the NRC Enforcement Policy were j satisfied. This item is identified as NCV 335,389/91-04-02, Failure
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to Follow Post Maintenance Test Control Procedures.
l l Aside from the concerns addressed in the NCVs and the error in AFAS l maintenance, maintenance activities were well controlled.
l 5. Review of Periodic and Special Reports (00713)
l Paragraph 3 discussed a special report issued by the licensee on the 282 l governor control switch failur The report properly identified the 2B
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EDG failure (TS 4.8.1.1.3) and identified satisfactory corrective action . Onsite Followup of Events (93702)
Nonroutine plant events were reviewed to determine the need for further or
, continued NRC response, to determine whether corrective actions appeared l appropriate, and to determine that TS were being met and that the public health and safety received primary consideration. Potential generic impact and trend detection were also considered. Section 2 of this report covered several events at the plant, as follows:
Inadvertent Unit 1 trip with 1 CEA withdrawn, MV 09-11 failure on Unit 1, 1B CCW pump trip on Unit 1, i 1C CCW pump motor failure on Unit 1, and Inadvertent AFAS partial actuation on Unit ,
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l l Followup (92701)
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. Followup-of Unresolved Items 1) (Closed - Unit 1) URI 335/89-02-02, Upgrade of E0P Training for !
Operator This . item addressed the failure of the licensed operator training program to address the unique identification of Regulatory Guide 1.97 instrumentatio Although the instrumentation in the control room was appropriately identified, the simulator instrumentation was not identified and the E0Ps did not specifically reference this unique identification or its use. A walkdown of the simulator facility accomplished during the EDSFI (NRC IR 335,389/91-03)
demonstrated that the regulatory guide instrumentation had been ,
appropriately identified in the simulator. A review of selected !
E0P procedures and the appropriate simulator lesson plan, Accident Instrumentation, Rev 0, demonstrated that the training program had effectively addressed this issue. Based on.the -
above, this item is closed.-
2) (Closed - Units 1 and 2) URI 335,389/88-30-02, Correlation Between Air and Steam on Safety Relief Valve Setpoint At the time this unresolved item was issued, it. appeared that bench testing of safety relief valves did not include the necessary adjustment for setting the setpoint cold. Since that time, the licensee has- completed an engineering study to verify l the correlation between-cold and actual operating temperature -
l setpoint setting The engineering study . contains several recommendations which are currently under review by the licensee. The procedure for setting the setpoint includes a 30 psi adjustment to account for the difference between cold- and hot setpoin A refueling outage is currently scheduled for Fall of 1991. The setpoints of the code safety valves are to be checked during this outage. Results of this surveillance activity will be reviewed to determine if the correlation is adequate. This unresolved item is close Followup of Previously Identified Items
, (Closed - Units 1 & 2) OPN 335,389/88-29-01, Inplant Diesel Instrumentation Calibration.
! This item was initiated to track inspector review of the calibration
! status of local instruments used in operating EDGs. The specific
- surveillance observed involved 1A ED Local temperature indicators were of particular interes Since that time, all the applicable operating and maintenance procedures have been revised so this followup was more comprehensive than the initial item statement.
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The inspector reviewed the following documents: i
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MP 0990060, Rev 4, Calibration Check of Installed Metering Equipment; I MP 0970025, Rev 5, 18 Month Calibration of Emergency Diesel l Generators Wattmeters; l
OP 1-2200050, Rev 51. Emergency Diesel Generator Periodic Test and '
General Operating Instructions; OP 2-2200050, Rev 27, Emergency Diesel Generator Periodic Test and General Operating Instructions; Unit 1 and Unit 2 Instrument Lists regarding EDGs; PWO 0140/61, completed 3/1/90, Unit 1 FYP 0159; PWO 8203/61, completed 3/10/90, Unit 1 FYP 0307; PWO 7452/61, completed 9/26/89, Unit 1 MTSI-044;
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PWO 8195/62, Unit 2 FYP 0595, FYP 0594; PWO 8169/62, completed 10/24/90, Unit 2, FYP 0569B; PWO 8170/62, completed 10/25/90, Unit 2, FYP 0570; PWO 8173/62, Unit 2 FYP 0573; PWO 8172/62, Unit 2 FYP 0575; PWO 7966/62, completed 5/4/90; and PWO 6489/62, completed 8/8/8 This' review concluded that the Unit 1 and Unit 2 EDG electrical meters and instruments were identified on lists for periodic calibratio All the Unit 1 EDG electrical meters and instruments had been calibrated. All the Unit 2 EDG electrical meters and those instruments that were of operational importance had been calibrate The licensee was actively enhancing the periodic calibration list for the Unit 2 EDG The operating procedures were satisfactory but had some human factors weaknesses in instrument identification. The licensee subsequently reissued the operating procedures with significantly enhanced instrument identificatio This item is close . Followup of Corrective Actions for Violations and Deviations (92702)
(Closed - Unit 1) VIO 335/89-02-01, Failure to Calibrate Six Regulatory Guide 1.97 Instrument .
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This item addressed six instrumentation loops which were not calibrated as
- required by Regulatory Guide 1.97. These items were not appropriately
. entered into a tracking progra !
The corrective actions' indicated in the licensee response to the NRC, dated April 3,1989, have been completed. The identified instrumentation
- was entered into the Planned Maintenance Program and calibrate The six i . instruments and loops referenced in the report were entered into the 3 Planned Maintenance Program as demonstrated by review of the Nuclear Job -
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. Planning System Planned Maintenance Schedule, dated February 21, 199 i
The individual instrument / loops were calibrated by the licensee when
, identified by the NRC inspection team as discussed in the originating 1 report, IR 335,389/89-02. Licensee action to correct the identified issue and prevent recurrence was adequate. This item is close . Exit Interview (30703)
The inspection scope and findings were summarized on March 29, 1991, with those persons indicated in paragraph 1 above. The inspector described the
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areas inspected and discussed in detail the inspection findings listed
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tgj Proprietary material is not contained in this repor Dissenting
[ comments were not received from the licensee.
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Item Number Status Description and Reference i
335,389/91-04-01 Closed NCV - Specification of Improper Thread
! Sealant in Safety-Related Applications, paragraph 2 ,389/91-04-02 Closed NCV - Failure to Follow Post Maintenance Test Control Procedures, paragraph 4.
- 335/91-04-03 Closed NCV - Failure to Restore 1B CCW Pump Missile Shield After Maintenance, paragraph 2a.
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389/91-04-03 Closed NCV - Failure to Scope Change a NPWO-
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Controlled Test of 2B EDG Field Control Circuits, paragraph ,389/88-29-01 Closed OPN - In-plant Diesel Instrumentation Calibration, paragraph 7 ,389/88-30-02 Closed URI - Correlation Between Air and Steam
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on Safety Relief Valve Setpoints, i
paragraph 7 i 335/89-02-01 Closed VIO - Failure to Calibrate Six Regulatory j Guide 1.97 Instruments, paragraph 8.
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335/89-02-02 Closed URI - Upgrade of E0P Training for
- Operators, paragraph 7 . Abbreviations, Acronyms, and Initialisms AC Alternating Current AFAS Auxiliary Feedwater Actuation System AFW Auxiliary Feedwater (system)
AP Administrative Procedure ASME Code American Society of Mechanical Engineers Boiler and Pressure Vessel Code avg average CCW Component Cooling Water CEA Control Element Assembly l CFR Code of Federal Regulations CST Condensate Storage Tank DC Direct Current DPR Demonstration Power Reactor (A type of operating license)
ECCS Emergency Core Cooling System EDG Emergency Diesel Generator ,
EDSFI Electrical Distribution System Functional Inspection ;
E0P Emergency Operating Procedure i ESF Engineered Safety Feature l F Fahrenheit FPL The Florida Power & Light Company FRG Facility Review Group FSAR Final Safety Analysis Report FT Flow Transmitter l FYP Five Year Plan I GE General Electric Company !
GMP General Maintenance Procedure I HCV Hydraulic Control Valve HPSI High Pressure Safety Injection (system)
I&C Instrumentation and Control ICW Intake Cooling Water IR [NRC] Inspection Report KV Kilovolt (s) .
KW Kilowatt (s) l TS Limiting Condition for Operation
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LC0 LER Licensee Event Report LOI Letter of Instruction MCC Motor Control Center (electrical distribution)
MFIV Main Feed Isolation Valve M0 VATS Motor Operated Valve Test System MP Maintenance Procedure ms millisecond MSIV Main Steam Isolation Valve MTSI Maintenance Tracking System MV Motorized Valve NCV NonCited Violation (of NRC requirements)
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NP Nuclear Production Facility (a type of operating license)
- NPWO Nuclear Plant Work Order NRC Nuclear Regulatory Commission NSSS' Nuclear Steam Supply System ONOP- Off Normal Operating Procedure 0P . Operating Procedure-0PN Open Item PCM Plant Change / Modification PM Preventive Maintenance PWO Plant Work Order QI Quality Instruction RCS Reactor Coolant System
- Rev Revision rpm Revolutions per Minute RPS Reactor Protection System RWT Refueling Water Tank SFP Spent Fuel Pool SG- Steam Generator S Saint TCB Trip Circuit Breaker TS Technical Specification (s)
URI [NRC] Unresolved Item-V Volt (s)
VIO Violation (of NRC requirements)
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