IR 05000336/1989016

Insp Rept 50-336/89-16 on 890616-0726.Violation Noted.Major Areas Inspected:Plant Operations,Surveillance,Maint, Previously Identified Items,Committee Activities,Emergency Diesel Generator Operation & Fuel Oil Sys

ML20246G271
Person / Time
Site:	Millstone, Hatch
Issue date:	08/21/1989
From:	Haverkamp D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20246G257	List: IR 05000336/1989016 ML20246G254 ML20246G264
References
50-336-89-16, NUDOCS 8908310284
Download: ML20246G271 (16)

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U.S.NUCLEARREGULATORYCbMMISSION

REGION I

Report N /89-16 Docket N _ License N DpR-65 Licensee: Northeast Nuclear Energy Company P.0. Box 270 Hartford, CT 06101-0270 Facility Name: Millstone Nuclear power Station, Unit 2 Inspection At: Waterford, Connecticut Dates: June 16 through July 26, 1989-Reporting Inspector: P. J. Habighort.t, Resident Inspector Inspectors: W. J. Raymond, Senior Resident Inspector P-. J. Habighorst, Resident Inspector Approved by: & 6. S @d h 6 M 8hlIET D. R. Haverkamp, Chief Date Reactor Projects Section 4A Inspection Summary:

Areas Inspected: Routine NRC resident and specialist inspection (138 regular hours', 21 backshift hours, and 3 deep backshift hours), of plant operations, surveillance, maintenance, previously identified items, committee activities, emergency diesel generator operation and fuel oil system, periodic reports, and Licensee. Event Reports (LERs).

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Results: No unsafe plant conditions were identified. One violation was identified for not verifying operability of the automatic test function of the engineered safety feature automatic actuation logic for about 8 years (Sec-

-tion 5.3). Two previously identified items were closed (Sections 3.1 and 3.2),

and one item was unresolved regarding apparent fire protection system smoke detector surveillance procedure errors (Section 5.5).

A licensee performance strength was noted in the effective implementation and quality of operation of the emergency diesel generator fusi oil system i (Section 6.0). i

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A performance. weakness was identified in the incomplete causal review of !

emergency diesel generator ' A' troubleshooting activities ar.d, in parallel, the i decision to conduct routine preventive maintenance items on the alternate )

emergency power source (Section 7.0).

890831026:4 DR 890821 ADOCK 05000336 i PDC  !

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f. J l ' TABLE OF CONTENTS o PAGE.

i 1.0 Persons' Contacted....................................................

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,ai i - 2.0 Summa ry o f Fac i l i ty. Acti v i t i e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l-3.0 Previously:Identi fied Items ( 92702) . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . 1 3.1 (Closed) Notice of Violation 88-07-06: ." Failure to Check Control Room Ventilation Radiation Monitor Response on' the Low and J

High Decade as Required Per Procedure"......................... ' .2 . (Closed). Notice of Deviation 88-07-05: " Failure to Subject the Control Room Ventilation Monitors to a. Source that is Fixed Reproducible Geometry Configurations Committed to in the Final S a f e ty An a l y s i s R e p o r t" . . . . . . . . . .. .. . . . . . . . . . . . .. . . . . . . . . . . -. . . . . 2 4.0- Facility. Tours (71707)... ........................................... 2 15'.0 Plant Operational Status Reviews (71707/71710/92701/93702)......... 2 5.1 Review 'of Plant Incident Reports (P1Rs) . . . . . . . . . . . . . . . . . . . . . . ... . 2 5.2' Operational Safety System Review.............-.........-.......... 3 5.3 : Engineered Safety Feature Actuation System (ESAS) Automatic Test l

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Inserter (ATI) Procedure (PIR 89-73) (Allegation RI-88-A-40).. 3 5.4 Steam Generator (SG) Mechanical Tube P1ugs...................... 5

' 5.5. Containment' Fire ' Alarms (PIR 89-46, 89-52, and 89-67)............ 5 l 6.0. Temporary Instruction (TI) 2515/100, " Proper Receipt, Storage, and I

' Handling of Emergency Diesel Generator (EOG) Fuel Oil" (255100).... 6

^ 7.0 Emergency Diesel . Generator (EDG) Operation (71707). . . . . . . . . . . . . . . . . . . 8 L .

L 8.0 Committee Activities (40500)........................................... 10 9.0' ObservationJof Maintenance (62703)................................... 10 10.0 Observation of Surveillance Testing (61726).......................... 11

'11.0 Periodic Reports (90713)............................................. 11 L .

L 12.0 Licensee Event Reports ( LERs) (92700) . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . .

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13.0 Management Meetings (30703).......................................... 12

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DETAILS'

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1.0 Persons Contacted

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Inspection findings were discussed periodically with the below personne S. Scace,-Millstone Station Superintendent J. Keenan,. Unit 2 Superintendent L.

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J. Riley, Unit 2 Maintenance Supervisor F. Dacimo, Unit 2 Engineering Supervisor-

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.J. Becker,1 Acting Unit-2: Instrument and Controls. Supervisor p J. Smith,- Unit 2 Operations Supervisor The: inspector also contacted other Operations, Radiation Protection, Chemistry, Instrument and Control, Maintenance, Reactor Engineering, and t

' Security personne l2.0 Summary of Facility Activities

.The unit' was at full power throughout the inspection perio + - On July 12,the licensee responded by letter to the NRC's request for a-mid-cycle shutdown' to conduct steam generator' eddy current testing (ECT)

examination. The licensee committed to the mid-cycle shutdown in the

. September / October.1989 time-frame. The' licensee will inform the staff on E

p the' specific shutdown date, and is willing to meet with the NRC staff to explain details'of the' inspection scope.and acceptance criteria. (see L- Report Detail 5.4).

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3.0 Previously Identified Items-(92702)

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3.1, sed); Violation 88-07-06, Failure to Check Control Room

,< Tation Radiation Monitor Response on the Low and High Decade as

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Hequired L

This item concerned the failure to adequately implement licensee pro-

'cedure SP 24048, " Control Room Ventilation Monitor Surveillance."

The-licensee responded by-letter dated July 15, 1988. The licensee's documented actions to prevent recurrence were: procedure revision; obtaining a source calibrator to provide accuracy and repeatability; licensee management meeting with technicians to stress importance of data collection and the necessity for procedural compliance; and independent review by the licensee Radiological Assessment' Branch

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(RAB) to programmatically determine compliance with design documents and regulatory requirements for radiation monitoring equipment. The l

. inspector reviewed performance of SP 2404 BA to the approved revision to i the procedure as_ documented in inspection report 50-336/88-22; and reviewed the initial sample in the RAB report for Millstone Procedure implementation was found adequate. This item is close ]

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I-i 2 3.2. (Closed) Deviation 88-07-05: Failure to Calibrate the Control Room i

Ventilation Monitors using a Recommended Source in a Fixed Reproducible Geometry Configuration as Committed to in the Final Safety Analysis Report (FSAR)

This item concerned lack of specificity.in procedure SP 2404 BA re-lative to ' source-to-detector distance and the concomitant uncertainty in detector calibration. The licensee's July 15, 1989 response documented actions to prevent recurrence. A General Atomic Model RT-10 radiation source was provided. The inspector verified the source is utilized, per SP 2404 BA, in a reproducible, fixed loca-tion, per procedure steps 6.1.2.1 and 6. The inspector witnessed the surveillance with inclusion of the source (RT-10) as documented in inspection report 50-336/88-22, and has no further question This item is close .0 Facility Tours (71707)

The inspector observed plant operations during regular and backshift tours of the following areas:

Control Room Containment Vital Switchgear Room Diesel Generator Room Turbine Building Intake Structure Enclosure Building ESF Cubicles Control room instruments were observed for correlation between channels, proper functioning, and conformance with Technical Specifications. Alarm conditions in effect and alarms received in the control room were dis-cussed with operators. The inspector periodically reviewed the night order log, tagout log, plant incident report (PIR) log, key log, and by-pass jumper log. Each of the respective logs was discussed with operation-departmen'c staff. No inadequacies were note During plant tours, logs and records were reviewed to ensure compliance with statio: orocedures, to determine if entries were correctly made, and to verify correct communication and equipment statu No inadequacies were note Selected aspects of site security were verified to be proper during in-spection tours, including s' ce access controls, personnel searches, per-sonnel monitoring, placement of physical barriers, compensatory measures, guard force staffing, and response to alarms and degraded conditions. No inadequacies were note .0 Plant Operational Status Reviews (71707/71710/92701/93702)

5.1 Review of Plant Incident Reports (PIRs]

The plant incident reports (PIRs) listed below were reviewed during the inspection period to (1) determine the significance of the events; (ii) review the licensee's evaluation of the events; (iii) verify the licensee's response and corrective actions were

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.;g ' proper; and . (iv) verify that the licensee reported the events in l

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accordance with applicable requirements, if required. The PIRs re-

-viewed'were: 89-46,.89-52, 89-67,'89-71, 89-72, and 89-73. The.fol-lowing items warranted inspector followup:

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PIRs 89-46, 89-52, and 89-67 (Report Detail 5.5)

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PIRs 89-71,~ 89-72 (Report Detail 7.0)

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- PIR 89-73 (Report Detail 5.3)

~ 5.2 ' Operational Safet'y System Review (71710)

On~ July 10,twoengineeringsafetyfeature(ESF)systemswerere-viewed to verify system operability. The systems reviewed were the Facility II Low Pressure Safety Injection and Containment Spray.Sys-4 tems. The review included proper positioning of accessible major flowpath values ~, proper indication and controls, and visual inspec-tion of proper lubrication, cooling, and other conditions. Refe r-ences utilized were:

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' Final Safety Analysis Report (FSAR)

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. Operating Procedures (SP) 2606D and 2604M

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Piping and Instrument Drawings (P& ids) 25203-26015 The systems were aligned 19 a standby operational mode. No inade-quacies were noted. The luspector included an independent verifica-tion of radiation levels of,the various levels in the auxiliary building in comparisonoto licensee's health physics survey maps for July 10.' No inadequacies were noted in the verification of radiation levels in areas reviewed by:the inspecto .3 -Engineering Safety Feature Actuation System (ESAS) Automatic Test Inserter ( ATI) Procedure (PIR 89-73) ( A11ecation RI-88-A-40)

On July 19, the' licensee documented.a technical specification (TS)

procedure deficiency. The procedure, SP-2403A, "ESAS Bistable Trip and ATI Test," is a monthly functional test to verify operability of the ATI for each ESAS bistable. The existing procedure to verify ATI operability was deficient with respect to the "hi-hi" containment pres-sure bistabl The ESAS contains one ATI that provides an automatic test capability for both the sensor cabinets and the actuation cabinets. The ATI generates dual,' 2 millisecond pulses which are routed to each channel bistable to simulate a momentary trip for test purposes. The signal follows through the ESAS normal signal path to the actuation modules output, where it is fed back to the ATI module to verify a successful tes ,

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Two bistables are normally pulsed simultaneously to satisfy the 2 out of 4 logic for the ESAS. One exception is the two containment pres-sure "hi" and two containment pressure "hi-hi" bistables. These four are pulsed simultaneously to verify that the Safety Injection Actua-tion. Signal (SIAS) prerequisite for CSAS is satisfie The requirement for the automatic actuation logic function test is in TS Table 4.3-2 item 2c. The ATI automatic actuation logic function test is required every 31 day Procedure SP-2403A did not address the test feature response for the CSAS bistables for all four ESAS channels. No record of verification of operability of the ATI feature was availabl The inspector discussed the performance of SP-2403A with licensee management on July 20. The licensee committed to conduct an in-service test to verify ATI response as it relates to the CSAS bist-able. The in-service test (IST 89-26) was approved by the Plant Operations Review Committee (PORC) at meeting 2-89-133 on July 2 The inspector was in attendance at the meeting. The licensee con-cluded no unreviewed safety question existed per 10 CFR 50.59 in the procedure's safety evaluation. The in-service test validated the licensee's need for a procedural improvement to SP-2403A to include the required monthly automatic actuation logic function test for the CSAS bistable The inspector concluded that this specific item is a TS surveillance violation. TS Table 4.3-2 item 2c, " Automatic Actuation Logic,"

requires the automatic test feature to be verified operable at least every 31 days. This requirement has been in effect since the effec-tive date of TS Amendment 53, April 9,198 Coupled with this TS surveillance violation is a licensee-identified item, LER 89-07, Missed Condensate Polishing Facility Radiation Monitor Source Check. This was a violation of the radiological effluent TS between February 1,1986 - March 22,1989 (see report detail 12.0). The inspector considers these events to be indicative of a. potential programmatic breakdown in verifying that surveillance procedures were properly revised to conform with required long-standing TS surveillance activities. Collectively, these events indicate a potential problem with assuring completion of required surveillance. Both were considered in the Notice of Violation (NC 89-16-01).

The nuclear safety significance for this missed surveillance is minimal based on: the ATI is a continuous electrical testing function for the ESAS circuitry; the CSAS bistable monthly functional surveil-lances (SP-2402P) were completed satisfactorily; and the ATI was found operable when surveille This item was identified to the licensee management by a licensee technician. That resulted in the plant information report (PIR)

I reviewed during this inspection. This item also was identified by the technician to the NRC as an allegation. Allegation disposi-tion will be addressed separately.

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At the. end ofl the previous ' inspection (report 50-336/89-11.LJune 15,

< 1989), the licensee was preparing a revised Justification for Con-tinued Operation (JCO) considering lower' reactor coolant' system-operating: temperature options, to extend the predicted lifetime of -

NX-4523 mechanical SG plugs. NRC-review of the l'.censee's JC0 1 response to NRC Bulletin 89-01, and to the NRC request (June 5,1989)

i for mid-cycle SG eddy current testing examination will be documented in'a1 subsequent inspection repor .5.5 Containment Fire Alarms (PIR 89-46, 89-52, and 89-67)

On May 14 June 1, and July 7, the smoke detector alarmed in the

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containment-east; electrical penetration. In each specific case, the licensee conducted an emergency containment entry. - No fire or smoke

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l - The east electrical penetration containment fire detection system l

consists of seven; smoke detectors (Fire Panel Zone 37). TS 3.3. requires.a minimum of five operable detectors in this zone. The

. electrical configuration of the smoke _ detectors was discussed with

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the licensee and independently checked per drawing number 25203-32019, Fire Protection Heat & Smoke Detectors. The seven 6etectors read out on one common alarm on the fire detection panel in the con-trol roou. The licensee indicated that no individual detector can be

- identified remotely as the cause for the common alar The inspector reviewed the Fire Hazards Analysis (Fire Area C-1) and drawing 25203-34306, Conduit Plan,- Fire Detection in Containmen No' inadequacies were note '

The inspector reviewed the most recent complete surveillance fo these smoke detectors. Licensee procedure SP-2618C, Fire Protection System Smoke Detector Test, was completed satisfactorily on March 4, 198 ~

Further licensee review into the performance of the containment smoke detectors is needed to determine the root cause of the alarms. NRC review of licensee actions will continu In follow-up of the PIRs, the inspector reviewed the surveillance procedure against TS requirements for fire detection instrument Apparent procedural errors (SP-2618C) were identified and were discussed with licensee engineering. No effect was identified on surveillance adequacy. This item is unresolved pending further evaluation of the significance of the apparent procedure error (89-16-02)

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6.0 Temporary Instruction (TI) 2515/100, " proper Receipt, Storage, and

' Handling of Emergency Diesel Generator (EDG) Fuel 011" (255100)

.The purpose of TI 2515/100 inspection was to. evaluate the licensee's-pro -

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' gram to assure quality of emergency diesel generator (EDG) fuel oil stored

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on the sit The inspector reviewed the EDG fuel oil supply system. Emphasis was

. placed on system design, licensee programs, and actions that ensure avail-ability and reliability of the EDGs. Three major functional areas were investigated: design.and maintenance of the fuel oil supply system; fuel oil: supply quality assurance; and quality services department . involvemen The design review traced the fuel oil' supply path from the storage tank to the engine mounted fuel pumps. The maintenance review examined procedural preventive maintenance (PM) actions that ensure flow of fuel' oil to the EDG The fuel oil supoly quality assurance covered licensee controls and analyses intended to assure required quality, and the quality seryhes department involvement in an overall. oversight of activities surrounding

- fuel quality. Documents reviewed were: surveillance, operation, and maintenance procedures; piping and instrument diagrams; the Final Safety Analysis Report (FSAR): technical specifications; and associated industry

- standards and NRC Regulatory Guide The diesel fuel: oil tank is a 25,000 ga'.lon underground storage tank.'

Fuel oil is transferred from the storage tank by two '25 gallon per minute-(gpm)~ oil transfer pumps to two 12,000 gallon (each)' diesel day tanks in l

the EDG building. Diesel' fuel oil is transferred by gravity from the day tanks-to an engine-driven fuel oil pump which supplies the EDG ejector .The fuel; oil overflow is collected in two clean oil storage tanks and pumped back to the oil tank FSAR Table 8.3-1 describes the diesel fuel oil system failure mode an-alysis'. Seismic calculations for the diesel generator components are described in FSAR section 8.3.2.2. The' inspector reviewed the licensee's failure analysis conclusions and basis for seismic calculations for EDG components and developed no further questions.

E The technical specification (TS) surveillance requirements for the EDG l fuel oil system are TS 8.3.1.1.b and TS 4.8.1.1.2.a.1 and 4.8.1.1. The requirements consist of a minimum capacity of fuel oil in the separate day tanks and a quarterly surveillance to acquire fuel oil samples per ASTM D270-65 and analyze the samples to the acceptance criterion of ASTM D975-7 The maintenance program developed by the licensee includes replacement of fuel oil duplex strainers on a six-month basis, cleaning the fuel oil day

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tank inlet / outlet Y-strainers each refueling, and day storage tank inspec-

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tion and ultrasonic testing every sixth refueling. The program is defined

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by licensee procedures MP2721J, " Periodic Inspection of Unit 2 Tanks,"

L MP2721J1, " Ultrasonic Testing of Tank Walls," and MP2701J-15, " Diesel l

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Generator Mechanical PMs." The non-TS surveillance SP-2672 checks for water accumulation on the bottom of the storage tank monthly. A quarterly pumping of approximately 10 gallons of diesel fuel from the bottom of the storage tank to remove any moisture accumulation is also being accom-plished at present. The pumping is controlled under the autom.ted work order (AWD) system, and not by a specific procedur The TS surveillance for acquiring and analyzing diesel fuel oil samples per ASTM-D270-65 and ASTM D975 1978 are defined in procedure SP2613 In addition to testing fuel oil parameters per ASTM D975-1978, the licensee has included specific gravity determination as recommended by the diesel manufacturer (Fairbanks - Morse) and impurity level as prescribed in ASTM-D2274-70. The above analysis conforms to a generic correspondence between the NRC and licensee by letter dated July 5, 1983 entitled "Clari-fication of Surveillance Requirements for Diesel Fuel Impurity Level Tests (Generic Letter 83-26)."

The inspector reviewed the licensee's internal response and actions for NRC Information Notice (IN) 87-04, " Diesel Generator Fails Test because of Degraded Fuel" dated January 16, 1987. The licensee's internally documen-ted planned actions as a result of IN 87-04 included replacement of fuel oil during the 1987 outage, updating the operations department purchase order (PO) to include fuel analysis to test for color per ASTM-D-1500, and increasing the duplex fuel filter replacement frequency. The inspector reviewed the status of the above licensee planned actions. One action was not completed, which consisted of an additional fuel oil analysis for color per ASTM-D-1500. The purpose for the analysis for color is to detect fuel degradation (organic sediment) during fuel storage. The sedi-ment is a direct result of oxidation of fuel oil. During the 1986 refuel-ing outage, the fuel oil supplier (Amerada Hess) had reported dark fuel oil and the licensee subsequently replaced the fuel oi As part of the internal corrective actions, the licensee was to establish the ASTM-D-1500 analysis and based on the analysis, a replacement schedule for the fuel oi In discussions with licensee personnel and review of operational surveillance, no establishment of fuel oil analysis ASTM-D-1500 was identified. At the end of the inspection period, the licensee committed to implement the analysis in a pre-existing procedure. The inspector has no further questions in regards to this matte The licensee's program to ensure EDG fuel oil reliability pursuant to industry codes and NRC Regulatory guides was reviewed by the inspecto The licensee complies with NRC Regulatory Guide 1.137 as it relates to:

fuel oil storage tank capacity design (FSAR 8.3.2.2.); in-service inspec-tion per section 7.3 of ANSI N195-1976 for portions designed to ASME Sec-tion III, subsection ND; sampling of new fuel prior to addition to storage tanks (SP-2613E), fuel oil sample acquisition (TS 4.8.1.1.2.b.), and moisture removal on a quarterly basis ( AWD pM), and fuel oil tank cathodic protection (MP 23468).

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The duplex. strainer located between the engine drive fuel oil pump and the EDG has a differential pressure indicator (PDI-7019) that provides an alarm locally at the EDG panel (C39/C38), and inputs into a common "D/G Trouble Alarm" in the control room, The alarms provide an indication of fouling of the strainer, in accordance with ANSI standard N195-1976. The inspector verified the alarm function and differential pressure indicator by in plant configuration and drawing descriptions on P&lDs 25203-226018 and 25203-30034. The differential pressure ind'cator is recorded hourly by operators during operation of the EDG. The inspector had no further questions on the strainer alar The inspector reviewed use of. fuel additives and fuel oil recirculation to prevent oxidation and bacterial growth in stored fuel oil. The licensee does not use fuel additives for the stored oil. The diesel manufacturer does not recommend a fuel additive because additive manufacturers will not identify the constituents of their products. The inspector reviewed the December 18 1986 correspondence between the vendor and the licensee and developed no further questions. The licensee does not have a direct recirculation system for fuel oi Indirectly, however, there is a con-stant gravity flow from the day tank to the ejectors to a clean fuel oil tank, and pumpir.g back to the _ day tank establishes a continuous filter flowpath. The licensee concluded that a fuel oil recirculation system should not be implemented because increased aeration could result in in-creased oxidation and formation of particulat Inspector review of maintenance including EDG tank inspections, duplex strainers, wye strainers, fuel oil transfer pumps, and cathodic protection for the last two years on both diesels found that the activities were conducted within prescribed tinie intervals, and that no major corrective maint9 nance was performed. Quality Service Department (QSD) involvement in the EDG fuel oil system was determined to consist of purchase order reviews for new fuel, and purchase records for sampling of fuel oil. The inspector had no further questions on these aspect In conclusion, the licensee acceptably maintains the quality and opera-tion of the fuel oil and the EDG fuel oil system. Goed involvement with the EDG manufacturer and responsiveness to past NRC correspondence was found. Procedural implementation of licensee-identified commitments as related to fuel oil clarity (ASTM-0-1500) has been don i.0 Emergency Diesel Generator (EDG) Operation (71707)

During the week of July 17, there were numerous start-ups of the emergency diesel generators as a result of under-excitation of EDG-A. A synopsis of 1 the events is attached in Table The licensee conducted unscheduled successful operation of EDG-A on July 26, and decided to bring in the vendor representative for future  !

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9-On July 24, the inspector discussed with licensee production test person-

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nel the troubleshooting of EDG-A. Licensee maintenance and production  ;

test-(PT) personnel repeired two items on EDG-A. The first repair was a' '

speed switch replacement during the ~ early afternoon on July 18. The speed switch' sends 125 VDC to the EDG generator.to flash the field based on two eng:ne speeds (250 RPM, 810 RPM); . As reported in the synopsis of events, EDG-A had two successful starts on July 18 after replacement of the' speed switch. Licensee management concluded that EDG-A was operable and <ade EDG-B inoperable for~ routine PMs. On July 19, at 6:36 a.m. , the licensee monitored relay, current and contact actuations in the EDG-A voltage control / excitation circuit. Successful operation was note On July 19 the same loss of excitation indication occurried on restart of EDG-A. The defect was attributed to the automatic voltage control circuit. On July 20, during continuity checks between the voltage regula-ting assembly and voltage control rheostats, the licensee identified cor-rosi6n on excitation and voltage control terminal boards TB 5 and TB- The' licensee repaired and replaced the terminal lugs. However, on a final unsuccessful run on July 20 at 7:18 p.m., EDG-A failed to achieve rated voltage / speed within'the required time interva On July 18 at 1:02 p.m., the licensee was operating EDG-B to comply with

'TS 3.8.1.1.a. During this surveillance run, the licensee opted to conduct

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an in-service test (IST) on the associated engine-driven air coolant pum The engine-driven air coolant pump provides a heat sink for two parallel scavenging air heat exchangers. The IST test procedure EN-21194 dictates an acceptable air coolant pump discharge pressure range between 8.5 and 9.4'psig. The discharge pressure recorded by the instrument (PI 8740) was 8.0 psig. At 1:30 p.m.-the licensee entered TS 3.8.1.1.d with both EDGs inoperable. At 3:20 p.m. the licensee completed an engineering evaluation (EN2-89-164) per ASME Section XI IWP-3230 (c), " Corrective Actions."

Section IWP-3230(c) states, " correction should be either replacement or repair per IWP-3111, or shall be an analysis to demonstrate that the condition does not impair pump operability and that the pump will still fulfill' its function. ." Licensee engineering calculation supported pump operability based on system performance during EDG operation. The licensee's root cause determination was a discharge pressure gauge mal-function. The licensee began to reduce power as TS requirements dictate

.at 3:30 p.m. At 4:20 p.m., the licensee was out of TS 3.8.I.1.d based on the engineering evaluation supporting operability of EDG-B.

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questioned the. licensee decision to restore EDG-A to operating status to conduct routine PMs on EDG-B. EDG-A was restored to operable status without fully evaluating the root cause of not achieving rated voltag Specifically, the failure on July 18 was the same as the failure on July 19 and, during the interim, the ",icensee had declared EDG-A operabl _ _ _ _ _ - _ _ _ _ _ -

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' The licensee representatives. stated . heir decision was safe and prudent based'on the information available at the time of-the event. Root cause determination' of corrosion on lugs for TB-5/6 for EDG-A and the slow.sta ~

time on the associated diesel on July '20 is. still under NRC revie The ~ inspector. concluded, based on acceptable surveillance on EDG-A, that no violation of' Technical Specification requirements existed; however, the decision was based.on'an incomplete causal review. Reliability and deter-

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mination of root cause of the events for EDG-A was not aggressively pur-

. sued prior to a~1icensee decision to perforn, routine PMs on the alternate emergency source of power. Licensee assurance that cause. determinations are. sufficient for required systems or components whose. operability is-in

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question,. prior to removing redundant systems or components from service

.for routine PMs,lwill be reviewed during rentine resident inspection .0 Committee Activities (40500)

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The intoector attended meetings 2-89-116, 2-89-120, 2-89-121, 2-89-123, and 2-89-133.of the Plant Operations Review Committee (PORC) or. June 16, June 28, June 28, July.5, and July-26. The irisp2ctor observed that the committees ' discharged their func: ?ons in accoriar.ce with regulatory requirements. The inspector observed a thoroup discussion of matters before the:PORC and a good regard for safety in the issues under consi-

.deration by.the committee In-service tests and.PIRs approved by PORC during these meetings were:

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'PIR 89-17, " Mounting Bolts on Reactor Building Component Cooling Water

(RBCCW) Heat Exchanger" closeou In-service test (T89-23), " Replacement of charging Header Flow Ori-fice."'

--- In-service test (T89-22), " Reduced Reactor Coolant System Average Tem-perature" tes In-service test (T89-26), " Auto Test Bistable Trip Test of Hi-Hi Con-tainment to ATI."

No inadequacies were note .0 Observation of Maintenance (62703)

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The inspector observed and reviewed selected portions of preventive and corrective maintenance to verify compliance with regulations, use of ad-

. ministrative and maintenance procedures, compliance with codes and stsnd-ards, proper QA/QC involvement, use of safety tags, personnel protection,

-and equipment alignment and retest. The following activities were in-cluded:

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M2-89-08129 - Repair.of auxiliary feedwater pump "A" on July 1 ,

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M2-89-09138 - Troubleshoot and repair of' emergency diesel K generator "A" speed control circuit on July 1 M2-88-08216 - Station air compressor PMs on July 1 No inadequacies were identifie .0 Observation of Surveillance Testing The inspector observed portions of and reviewed the following completed surveillance tests to assess performance in accordance with approved procedures and Limiting Conditions of.0peration, removal and restoration of equipment, and deficiency review and resolutio SP-2401K, "High Power Calibration-Variable Trip Setpoint"

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' SP-2403A, " Engineering Safety Actuation System (ESAS) By-stable-Trip Test

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IST 89-22 " Power Operation at Reduced Reactor Coolant System Average Temperature"

. On July 3, the inspector reviewed enlibration and functional test of the variable high power trip calcula or for reactor protection channel 'A'.

The routine surveillance was conducted per the technical specification quarterly surveillance frequency by experienced personnel. The inspector independently verified that measured values met the acceptance criteri Test procedures were followed and personnel were knowledgeable of the system and procedure. requirements. No inadequacies were identifie . On July 13, the inspector the technical specification required monthly functional test on ESAS channel 'B.' The inspector independently verified that measured values met the acceptance criteria, and observed implementa-tion of a non-intent procedural change and communication between operators and technicians. The test procedures were adhered to and personnel were knowledgeable of system and procedure requirements. Good initiatives were undertaken by the personnel to identify and implement improvements to

.SP2403A procedural steps. No inadequacies were note '

11.0 periodic Reports (90713)

'Upon receipt, periodic reports submitted pursuant to technical specifi-cations were reviewed. This review verified that the reported information was valid and included the NRC required data. The inspector also ascer-tained whether any reported information should be classified as an ab-normal occurrence. The following reports were reviewed:

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Monthly Operating Report, May 1989

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Monthly Operating Report, June 1989

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Startup Test Report for Cycle 10, July 24, 1989 No inadequacies were noted.

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12.0 Licensee Event Reports (LERs) (92700)

Licensee Event Reports submitted during the period were reviewed to assess LER accuracy, corrective actions, and compliance with 10 CFR 73 reporting requirements, and to determine if there were any generic implications or

1f.further information was required. The LER reviewed during the inspec-tion period was:

--' LER.89-007, " Missed Radiation Monitor Source Check"'

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On June 13, the licensee concluded that the condensate polishing facility (CPF) radiation monitor had been operating in violation of TS 3.3 (without

' conducting a source check) between February 1986 and March 1989. The source check for the CPF. radiation monitor was a requirement imposed in

'1986, but was omitted from the controlling surveillance procedure SP 2617 The licensee's Nuclear. Review Board (NRB) identified the discrepanc The. licensee implemented the appropriate changes to SP 2617A in March 1989 to reflect a. source check surveillance. The licensee conducted a review of completed functional checks and calibration forms betwcen February 1986 - March 1989 and concluded no deficiencies existed which would have made the monitor incapable of accurately monitoring a radio-active discharg The. licensee reported. corrective actions that include a present practice of additional review of TS changes to ensure all required surveillance

' changes have been completed. In report detail 5.3, another example of a long-standing TS requirement that was not accurately reflected in surveil-lance test activities was identified. The inspector considers both events to indicate that a review of long-standing TS requirements v actual surveillance activities is needed. Licensee management acknowledged-the inspector's concern. The. effectiveness of the licensee response to this matter will be. reviewed during routine resident inspectio .0 Management Meetings (30703)

Periodic meetings were held with station management to discuss inspection findings during the inspection period. A summary of findings was also discussed at the conclusion of the inspection. No proprietary information

.was covered within the scope of the inspection. No written material was given to the licensee during the inspection perio _ _ _ - _ - - _ _ _ _ - _ - _ - - _ - _ - - _ _ _ . _ _

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DATE- ' TIME- LICENSEE ACTIONS

' July '18 0444 EDG-B was scheduled for routine preventive maintenance and TS required surveillance. Therefore, EDG-A was started as

. required per TS. EDG-A did.not achieve rated voltage and the " Ready to Load'.' control room annunciator did not illuminat ' July ' 18 ;0445 .TS action statement 3.8.1.1.a was entered by the licensee, and the EDG-B was successfully ru July 18 -

0745l Restart of.EDG-A was unsuccessful, in that automatic-

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voltage control was not establishe July 181 130 EDG-B was. started in compliance with TS 3.8.1. _

Licensee review of In-Service-Inspection (ISI) concluded -

that the EDG-B engine-driven air coolant pump discharge oressure was out of specification. At 1:30 p.m. (1330),

$ th EDGs were declared inoperable and TS S.8.1.1.d was entered.

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July-18 1620 Licensee notified NRC Operations Center per 10 CFR 50.73 of plant shutdown required per TS. At approximately 3:45 p.m. (1545), EDG-B was declared operable based on engineer-ing' evaluation of the ISI results of the EDG-B engine-driven air coolant pum July 18 1430 Unsuccessful start of EDG-A; attributed to the voltage regulation proble July 18 1756 Two successful starts of EDG-A; no root cause identified 1831 for previous failures to star EDG-A was declared oper-

.able at 7:40 p.m. (1940).

July - 19 - 063 EDG-A was started successfully for surveillance run to remove EDG-B from service for scheduled prevent maintenanc . July 19 0805 EDG-B declared inoperable for preventive maintenance.

i Licensee entered TS 3.8.1.1.a action statemen July 19 1414 EDG-A started successfully in compliance with TS 3.8.1. D . July 19 1820 EDG-B started and ran successfully; minor oil leak on lube oil filter cover identified and corrected.

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Table 1 2 DATE TIME LICENSEE ACTIONS

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July 19 2202 EDG-A started successfull July 20 0245 EDG-B ran successfully. Both diesels declared operable by the license July 20, 0308. Entered TS 3.8.1.1.a to repair an air box cover gasket leak on EDG- July 20- 0415 Repaired _ air box gasket- leak, pre-lubed EDG-A, unsuccess-ful run.and declared inoperable due to voltage and speed oscillatio Licensee remained in TSAS 3.8.1. ' July 20 0425 Unsuccessful run of EDG-A, same problems as noted on July.18 at 4:44 a.m. (0444):and 2:30 p.m. (1430).

July 20 1026. EDG-B run successful in compliance with TSAS 3.8.1. July 20 1918. EDG-A' unsuccessful run. No voltage or excitation problems noted, but diesel took 27.7 seconds for ready to load annunciate (requirement is less than 20 seconds).

July. 20 1927 Two successful runs of EDG- July 21 - 0200 Started EDG-B in compliance with TS 3.8.1. July.21 1148 EDG-A started with no problems note l .1206 July ' 21 1330 Licensee declared both EDGs operable, and out of TSAS 3.8.1. July 26 0548 Two successful runs of EDG-A.

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