IR 05000338/1993029

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Insp Repts 50-338/93-29 & 50-339/93-29 on Stated Date.No Violations Noted.Major Areas Inspected:Plant Status,Ler Followup,Safety Verification,Maintenance Observation, Surveillance Observation & Cold Weather Preparations
ML20059G353
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 01/12/1994
From: Belisle G, Garner L, Mcwhorter R, Taylor D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059G349 List:
References
50-338-93-29, 50-339-93-29, NUDOCS 9401240120
Download: ML20059G353 (16)


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o - UNITED STATES

/pnarc,% NUCLEAR REGULATORY COMMISSION y* 4 REGION 11 q . % 101 MARIETTA STREET, N.W., SUITE 2900

j ATLANTA, GEORGIA 3020199

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Report Nos.: 50-338/93-29 and 50-339/93-29 ,

Licensee: Virginia Electric & Power Company 5000 Dominion Boulevard Glen Allen, VA 23060 ,

Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7 ,

l Facility Name: North Anna 1 and 2 Inspection Conducted: November 21 - December 18, 1993 Inspectors: e#72 F / /L!9 R. D. McWhorteMenior fesident Inspector Date Signed b~ A=1A ka er- I /Yll ~

D.'R. Taylor ~ ret 4 dent Idspector D4te Signed N C& // /

Date Signdd L. W. Garner, Pr'536ct Engineer Approved by:

  1. N G. A. Belisle, Section Chief Date Signed Division of Reactor Projects SUMMARY Scope:

This routine resident inspection was conducted on site in the areas of plant status, operational safety verification, maintenance observation, surveillance observation, cold weather preparations, Licensee Event Report followup, and ,

action on previous inspection items. Inspections of licensee backshift activities were conducted on November 21 and 22, and December 2, 12, 13 '

and 15, 199 Results:

Operations functional area A weaks 's identified concerning computerized technical specification accuracy, i..- ...pectors identified several minor deficiencies when comparing the computerized technical snerifications to a controlled copy and found that plant administrative or ' ,:1d computerized technical specification use for safety-related pur poses varagraph 3.b). ,

l 9401240120 DR 940112 ADOCK 05000338 '

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t 2-Maintenance functional area

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A strength was identified concerning the licensee's response to problems identified during two surveillance tests. Troubleshooting and repairs following a reheater intercept valve failure to shut during turbine valve testing were prompt and efficient (paragraph 4.a). Also, troubleshooting into the cause for the failure of _the 2H emergency diesel generator to start during a simulated loss of off-site power test was prudent and thorough ,

(paragraph 5.a).

A weakness was identified for not implementing a vendor recommendation ;

concerning emergency diesel generator fuel injection nozzle collar orientation (paragraph 4.b).

Plant Support functional area A weakness was noted in that the licensee failed to resolve a Licensee Event i Report concerning a degraded voltage relay failure until twice reviewed by the :

inspectors (paragraph 7.a).

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REPORT DETAILS

, Persons Contacted

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Licensee Employees

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L. Edmonds, Superi.sendent, Nuclear Training J. Hayes, Superintendent of Operations D. Heacock, Superintendent, Station Engineering G. Kane, Station Manager

  • P. Kemp, Supervisor, Licensing
  • W. Matthews, Assistant Station Manager, Operations and Maintenance J. O'Hanlon, Vice President, Nuclear Operations D. Roberts, Supervisor, Station Nuclear Safety
  • R. Saunders, Assistant Vice President, Nuclear Operations D. Schappell, Superintendent, Site Services -

R. Shears, Superintendent, Maintenance

  • J. Smith, Manager, Quality Assurance A. Stafford, Superintendent, Radiological Protection
  • J. Stall, Assistant Station Manager, Nuclear Safety and Licensing Other licensee employees contacted included engineers, technicians, operators, mechanics, security force members, and office personne NRC Resident Inspectors
  • R. McWhorter, Senior Resident Inspector
  • D. Taylor, Resident Inspector L. Garner, Project Engineer
  • Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragrap On November 30, 1993, the NRC Chairman, Dr. Ivan Selin visited the North Anna Power Station. Dr. Selin toured the plant and met with licensee management and the inspectors to discuss plant status and current issues -

at the facility. Dr Selin was accompanied by members of his staff, and several members of the People's Republic of China National Nuclear Safety Administration. Region II management accompanying Dr. Selin included the Regional Administrator, Mr. S. D. Ebneter, and the Reactor Projects Branch Chief, Mr. M. V. Sinkul . Plant Status

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Both Unit I and Unit 2 operated the entire inspection period at or near i 100% powe l

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3. Operational Safety Verification (71707)

The inspectors conducted frequent control room tours to verify proper staffing, operator attentiveness, and adherence to approved procedure The inspectors attended daily plant status meetings to maintain awareness of overall facility operations and reviewed operator logs to verify operational safety and compliance with TS. Instrumentation and safety system lineups were periodically reviewed from control room indications to assess operability. Frequent plant tours were conducted

.9 observe equipment status, fire protection program implementation, radiological work practices, plant security, and housekeeping. DRs were reviewed to assure that potential safety concerns were properly reported and resolved, Licensee On-Site Organization Changes On December 1, 1993, the licensee announced that Mr. W. Matthews, Superintendent, Maintenance, had been appointed to the position of Assistant Station Manager, Operations and Maintenance. He replaced Mr. R. Enfinger, who had been transferred to an off-site position with the company. On December 17, 1993, the licensee q announced that Mr. R. Shears, Superintendent, Outage & Planning, .

had been appointed to replace Mr. Matthews as Superintendent, Maintenance, Computerized TS Deficiencies On December 6, 1993, the inspectors reviewed the computerized version of TS which were available for general use on the site's i LAN system. The inspectors compared the computerized version with ;

controlled TS copies. The following deficiencies were identified in the Unit 2 computerized TSs: 1

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Page 7-26, a parenthesis was missing in an equation for determining the sampling size for snubber inspections

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Page 7-24, "no" was typed for "not" ,

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Pages 7-23 and 7-24, the revision date was incorrec In addition, the inspectors identified that page 3 of the Unit 2 License had not been updated to reflect seven amendment numbers issued after Amendment 150. These observations were provided to the license On December 9, 1993, the inspectors were informed by the licensee that these specific items had been corrected, and a line-by-line verification had been initiated. The inspectors verified that the above items had been properly revised. During this latter verification, the inspectors additionally identified that another equation in the snubber inspection specification used a backslash (\) symbol instead of the division (/) symbol. This observation was also provided'to the licensee, and the inspectors later verified that the error was correcte .

The inspectors reviewed computerized TSs usage by operations personnel. Discussions with on-shift personnel revealed that the computerized TSs were not relied upon when LC0 action statements were entered. Instead, printed.TS controlled copies were use The inspectors also found that the licensee classified the computerized TSs as a non-safety related computer code. The inspectors reviewed VPAP-0306, Station Software Control, revision 4, and found that non-safety related computer codes may maintain data for use in safety-related applications without'being verified prior to use. The inspectors concluded that although operators did not rely on the computerized TS, there were no administrative restrictions on their potential safety-related usag ,

The inspectors deemed that the number of errors identified in the small sample reviewed (less than 20 TSs) reflected a lack of attention to detail and cast doubt on the computerized TSs'

validity. Not accurately establishing or maintaining the '

computerized TSs when combined with the fact that they could potentially be used without verification for safety-related applications was considered a weaknes c. Unit 1 Pressurizer Pressure Controller On December 7,1993, during a control room tour, the inspectors found that the Unit I narrow range pressurizer pressure strip chart recorder indicated a small step downward change in pressure followed by an immediate recovery to normal. Inspectors questioned the on-shift CR0 who stated that the response was not expected, but that it had possibly occurred before and might have been previously investigated by I&C and/or engineerin The inspectors identified to licensee management that operation in this manner appeared abnormal and questioned if such operation.was desirable. As a result of the inspectors' questions, a preliminary event review was performed, and W0 018649 was issued for I&C to examine the pressurizer pressure controller setting *

After review, operations personnel informed the inspectors that grid voltage fluctuations with two pressurizer heaters in :.crvice had raised pressure and resulted in the controller providing an open signal to the pressurizer spray valves. However, due to previous leakage problems with the spray valves, the controller had been adjusted to null out small open signals. As a result, the spray valves did not begin to open until a 10% demand signal was present and then rapidly opened to 22%. At the close of the inspection period, the licensee was continuing to evaluate the controller's operation and the possible need for corrective '

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4 J EDG Walkdown On December 8, 1993, while performing a routine inspection of the Unit 2 EDGs, the inspectors noted that a grease fitting-for the

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2J EDG fuel oil pump drive housing was painted over. Station lubrication and PM procedures were reviewed, and the EDG maintenance engineer was contacted. No PM was . identified which required using the fitting for lubrication. A vendor manual review did not identify any lubrication recommendations for the fitting. The licensee's maintenance engineer indicated that he would discuss the subject with the vendor and establish, if necessary, an appropriate lubrication schedule for the fittin The inspectors considered this action to be appropriat Licensee NRC Notifications 1) On November 22, 1993, the licensee notified the NRC as required by 10 CFR 50.72 concerning the notification of off-site authorities. Specifically, the licensee notified the Commonwealth of Virginia concerning chromate discharges into Lake Anna from a CCW leak. The leak was from a SG blowdown tank vent condenser, which was later repaired by the licensee. The inspectors reviewed this notification and verified that there were no NRC safety-related concerns associated with the even ) On November 28, 1993, the licensee notified the NRC as required by 10 CFR 50.72 concerning the notification of off-site authorities. Specifically, the licensee issued flood warnings to the highway departments of surrounding counties. The flood warnings were in accordance with plant procedures following large discharges from the Lake Anna Dam due to heavy rains. The inspectors reviewed this notification, inspected the situation at the dam, and verified that there were no NRC safety-related concerns associated with the even ) On December 18, 1993, the licensee notified the NRC as required by 10 CFR 50.72 concerning the notification of off-site authorities. Specifically, the licensee notified the Commonwealth of Virginia concerning the transport off-site of a plant employee requiring medical attentio The inspectors reviewed this notification and verified that there were no NRC safety-related concerns associated with the even No violations or deviations were identifie +

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4. Maintenance Observation (62703)

Station maintenance activities were observed and reviewed to verify that :

activities were conducted in accordance with TS, procedures, regulatory guides, and industry codes or standard ,

' Turbine EHC System Repairs On December 3, 1993, the inspectors' observed planned maintenance to repair an oil leak on the EHC actuator for 2-MS-TV-10, the Unit 21C Main Turbine Throttle Valve. The repair was planned under WO 00276928-01 and coordinated with surveillance test 2-PT-34.3, Turbine Valve Freedom Test, revision 15, which '

fulfilled TS 4.7.1.7.2.a requirements. The inspectors judged that the plan to perform the maintenance during the surveillance test '

was good because it avoided an unnecessary transient on the plant '

to establish conditions to shut the throttle valve for

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maintenanc t During PT performance, the inspectors and the licensee observe that the number 2 left intercept and reheat stop valves did not close when the test push button was depressed. The inspectors witnessed troubleshooting which quickly identified the problem to be a misaligned limit switch for opposite side valves. The limit switch was aligned, and the test was satisfactorily complete The inspectors reviewed the maintenance and confirmed that the problem affected only the test circuitry and did not affect valve closing circuit operability. The inspectors concluded that the troubleshooting and repairs were prompt and efficient. The inspectors considered the licensee's efforts in responding to the problems identified during testing as a strengt '

After PT completion, the licensee used the test circuitry to shut the throttle valve in preparation for the leak repai Maintenance personnel removed the enclosure cover for the hydraulic actuator to repair the reported oil leak. However, examination by maintenance personnel failed to locate any oil leaks inside the valve enclosure, and no maintenance was require The inspectors inquired why the effort was made to plan and to set up for the maintenance when no problem appeared to exis Licensee management responded that an employee had noted oil seeping out of the actuator enclosure cover and appropriately :

initiated a WR. Actual leak presence could not be confirmed until- !

conditions were set for the maintenance and the cover was remove After no leak was found, it was then concluded that the oil :

leaking from the enclosure cover was residual oil trapped under '

the actuator bedplate from prior leaks-during startup following a :

recent outage. The inspectors considered the licensee's actions to be appropriat I

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b. EDG Vendor Manual Reconnendations On December 9, 1993, an EDG vendor manual recommendation was selected by the inspectors to verify that vendor recommendations were properly incorporated into maintenance procedures and implemented. SIL dated July 14, 1986, was selected since it contained two recommendations, one of which could be visibly verified on the EDG The SIL first recommended a change to the torque value for the fuel injector nozzle adapter stud nuts from 35-40 ft-lbs to 20-25 ft-lb The inspectors verified that upgraded maintenance-procedure 0-MCM-0701-23, Cleaning And Adjustment Of Emergency Diesel Generator Injection Nozzles, revision 0, effective .

September 8, 1993, appropriately contained this recommendatio The second recommendation concerned fuel injector nozzle collar orientation. The SIL stated, "Further testing in our laboratory has shown for best results the injection nozzle collar should be installed with the studs in the horizontal position. Since this is impossible, a 15* to 25* from the horizontal position will be i satisfactory." The inspectors were unable to locate a procedure containing this recommendatio Procedure 0-MCM-0701-23 provided instructions for fuel injection nozzle removal but did not require the adapter collar which orients the studs to be removed or 1 aligned. An EDG inspection revealed that the injection nozzle

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collars were installed without attention to orientation, in that, the angles varied from 0* to nearly 90' from the horizonal. This i was discussed with the cognizant maintenance engineer and personnel associated with the procedure and vendor recommendation J

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upgrade efforts. No station procedure was identified that implemented this recommendatio Procedure 0-MCM-0701-27, Repair )

Of Emergency Diesel Generator Cylinder Liners, revision 0, also provided instructions to remove and reinstall the adapter collar !

which orients the studs; however, the orientation recommendation i was again not addresse The licensee identified that backup material utilized in preparing upgraded maintenance procedures contained vendor manual portions including the SIL dated July 14, 1986. This SIL copy had the torque change sentences highlighted but the portion involving the stud orientation was not highlighted. No documentation was included in this backup material to justify not including the stud j orientation recommendation in the appropriate procedures. The i cognizant procedure writer was no longer employed by the licensee i and thus, was unavailable for comment. In addition, no engineering documentation was found that justified not implementing the recommendatio On December 15, 1993, the maintenance engineer informed the inspectors that the EDG vendor had been contacted concerning this recommendation. The vendor indicated that this recommendation was I

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not a mandatory requirement. However, the licensee elected to -

i revise appropriate procedures to address this recommendation and

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issued W0s to horizontally orient the fuel injection nozzle collar studs, where practical . The three procedures revised were 0-MCM-0701-23, 0-MCM-0701-27, and 0-MCM-0701-18, Repair of Emergency Diesel Generator Connecting Rod Bearings. On the same date, the 1H EDG was removed from service for routine maintenanc At that time, the fuel injection nozzle collar studs were re-oriented in accordance with the SIL recommendation. The three remaining EDGs will be corrected during their next scheduled maintenance periods. At the reporting period's end, the licensee was :ontinuing to evaluate the programmatic significance, if any, of tne failure to incorporate this recommendation into the maintenance procedure The inspectors concluded that the licensee's failure to incorporate a vendor SIL recommendation into procedures, or document why it was not incorporated into procedures, was a weakness. The inspectors judged that the licensee's actions taken after problem identification were goo No violations or deviations were identifie . Surveillance Observation (61726)

Station surveillance testing activities were observed and reviewed to verify that testing was performed in accordance with procedures,. test '

instrumentation was calibrated, LCOs were met, and any deficiencies identified were properly reviewed and resolve , Emergency Diesel Generator Fast Start Test On November 24, 1993, the inspectors observed licensee personnel performing 2-PT-82.2A, 2H Diesel Generator Test (Simulated Loss Of Off-Site Power), revision 33. The test fulfilled TS 4.8.1.1. requirements and was performed to demonstrate 2H EDG operability in fast starting and loading from a simulated loss of off-site powe The EDG was to be started by pushing in and holding test switch 43F-2ENSH03 which was located in cabinet 2-EP-CB-28H in the instrument rack room. The inspectors and the licensee observed that when this switch was pushed, the EDG failed to start. A licensed operator was immediately dispatched to the instrument rack room and verified the proper test alignment and switch positions. A second operator independently verified the sam The licensee promptly gathered a team to investigate the reason for the failed test and to plan corrective actions. The investigation postulated the probable cause to be associated with "

the test push button switch or a test relay contact. To confirm this, a troubleshooting procedure was written and approved by SNS0 Using the procedure, the failure was found to be caused by the operator not having the " twist and push" style push-to-test

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button totally in the clockwise position. This prevented the button from being fully depressed and, as a result, prevented i energizing all associated contacts. The inspectors observed the troubleshooting and verified that the licensee was able to -

duplicate the exact indications observed during the test failur The licensee and the inspectors concluded that the failure was due to personnel not being familiar with the switch's operation. To address this condition, the licensee revised procedures to require that personnel operating the switch be electricians, who were more experienced with this particular switc Following the troubleshooting,'the test was completed satisfactorily, an(' the EDG was returned to an operable statu The inspectors considered the investigation into the cause for the EDG failure to start to be prudent and thorough. The inspectors considered the licensee's efforts to be a second example of a strength in responding to problems identified during testin b. Low Head Safety Injection Pump Test On December 1, 1993, the inspectors observed licensee personnel performing 2-PT-57.1A, Emergency Core Cooling Subsystem - Low Head Safety Injection Pump (2-SI-P-1A), revision 25. The test fulfilled TS 4.5.2.f.2 requirements and was performed to demonstrate LHSi Pump 2-SI-P-1A operability. Recent procedure modifications also provided guidance to measure the amounts and effects of entrained gasses within the LHSI system. The licensei was tracking the amount of entrained gasses in the system due '-

past relief valve failures associated with high pressure peaks a pump startup due to the gasse The inspectors observed system venting prior to testing using vents installed during the recent Unit 2 refueling outage. It was noted that approximately four liters of total gasses were released. This was significantly higher than recently experienced on Unit I during similar testing following vent installation. The licensee primarily attributed this to the fact that this was the first time the test had been performed following the outage and compared the results to Unit 1, which also had high gas volumes during the first test following outag lhe inspectors also observed the pre-test briefing and actual test performance. The test was well planned and executed, with good coordination by the operators, test engineers, and instrumentation and maintenance personnel. The test data was reviewed and all measured parameters were verified to have fallen into acceptable ranges for demonstrating pump operabilit :

One problem observed during the test by both the inspectors and licensee personnel occurred when all three relief valves on the pump discharge lines lifted momentarily after pump starting. A subsequent review of strip chart recorder data revealed that pump

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discharge pressure peaked at approximately 384 psig after ,

l starting, well above the relief valves' setpoin Post-test

! venting resulted in an estimated 20 liters of entrained gasses in the lines. This confirmed that the probable cause of the pressure surge was entrained gasses. The inspectors reviewed pressure surge history and agreed with the licensee's evaluation that system operability was not impacted by the problem. However, the inspectors. expressed concern that the system was susceptible to material failures which could be caused by the high pressure pea DR N-93-1867 was submitted, and the licensee will continue to evaluate the problem of entrained gasses causing startup pressure surges. The licensee is considering increasing the test frequency to better evaluate this problem. Inspectors will continue to track this item under IFI 50-338,339/93-27-02, which was opened during the previous inspection period, ho violations or deviations were identifie l l Cold Weather Preparations (71714)

The inspectors reviewed the licensee's preparations to protect safety-related systems against extreme cold weather. The inspectors found that the licensee performs seasonal maintenance and inspections for equipment which could be affected by severe cold weather through various annual PMs, pts and by monthly performing 0-G0P-4, Cold Weather Protection, revision The inspectors verified that the PM requirements were performed by reviewing completed W0s 00268990, 00268992, and 00267999. Further, the inspectors independently assessed outside equipment areas by walkdowns using 0-G0P-4. The inspectors inspected outside tank areas and areas housing safety-related equipment in the MSVH, AFW pump house, and quench spray pump house. Overall, the inspectors found that the licensee's procedures properly identified deficiencies and that appropriate corrective actions were being take The inspectors concluded that sufficient administrative requirements >

existed and were being properly implemented to protect safety-related equipment from failure due to freezing condition However, the inspectors identified several minor problems. First, administrative discrepancies were found in work documentation. Work I packages were identified where required equipment checks were not !

recorded as being performed. These checks were later found to be ;

documented in other work package Second, during a Unit 2 MSVH '

walkdown per 0-G0P-4, the inspectors identified that the heating steam y

. valve to unit heater 2-HV-UH-600 was shut. This condition was conveyed to the shift supervisor who later informed the. inspectors that the condition was also identified by an operator during the most recent ,

0-G0P-4 performance. The inspectors noted that the valve's position was ;

not placed into the abnormal status log until noted by the inspector l Third, a problem with 0-G0P-4 was found in that it included checks for j the RWST level transmitter enclosures, but did not check the casing '

cooling storage tank level transmitter enclosures. The above items were discussed with appropriate licensee personnel who initiated corrective l

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actions. The inspectors did not consider the items to be significant, but noted that freeze protection activity organization and documentation

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could be improve . Licensee Event Report Followup (92700)

The following LERs were reviewed and closed. The inspectors verified that reporting requirements had been met, causes had been identified, corrective actions appeared appropriate, and generic applicability had been considered, (Closed) LER 50-339/91-06: Failure to Place Inoperable Degraded Voltage Relay in Trip Within One Hour This LER concernst an event on September 5, 1991, where a timer actuation relay for an emergency bus degraded voltage protection channel failed during testing in addition to the equipment failure, the licensee could not install jumpers within one hour to meet TS 3.3.2.1 requirements due to task complexit Immediate corrective actions included replacing the failed relay Additional corrective actions by the licensee were to evaluate.the need for a periodic relay replacement program and to initiate a TS amendment to extend the time required to place an inoperable channel in tri ,

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The inspectors reviewed the licensee's evaluation concerning the necessity for a periodic relay replacement program. On November 22, 1993, the inspectors attended an SOB meeting where the subject relay failure was discussed. Investigations into the relay failure revealed a different root cause than that stated in the LER. Maintenance engineers performed experiments and concluded if .

the relay was de-energized and allowed to' cool off, and then re-energized, it would bind in the de-energized state. If allowed to return to its normal operating temperature (approximately four hours), the relay would work properly. Based upon these results, the engineers concluded that a relay replacement program was unnecessary. The inspectors considered this action to be appropriate. Additionally, the inspectors reviewed in detail the possible effects of this new failure mechanism on degraded voltage circuit operability, and concluded that the licensee had completed all necessary. action The inspectors also evaluated this LER's closure histor The LER was previously reviewed by inspectors and addressed in.NRC Inspection Report Nos. 50-338,339/93-08. At that time, the inspectors determined that the licensee had incorrectly resolved the LER by relating the failure to a Westinghouse Part 21 notification. Based upon the inspectors' determination, the licensee initiated further evaluations to assess corrective actions. Additionally, the inspectors noted that the TS amendment had not been completed. The LER remained open pending corrective action completio I

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During this review, the inspectors noted that the LER still had not been fully resolved, in that, the TS amendment had not yet )

been issued. The proposed change had been put into a package with >

similar proposals to other instrument specifications. This package was scheduled for submittal to the NRC in mid-1994. The l inspectors considered this action to be appropriate but expressed

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concern about the length of time involved to complete the corrective action. In addition, the licensee had not recognized that an LER supplement was necessary due to the relay testing results discussed on November 22. Questioning by the inspectors concerning commitments for relay replacement prompted the licensee to recognize that the LER cause and corrective actions required revision. The inspectors judged the licensee's failure to resolve this LER until twice reviewed by inspectors to be a weakness in plant supor b. Safety Valve Setpoint LERs

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(Closed) LER 50-338/92-02: Pressurizer Safety Valve Setpoint Out of Tolerance Due to Setpoint Orift

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(Closed) LER 50-339/92-03: Pressurizer and Main Steam Safety Valve Setpoints Out of Tolerance Due to Setpoint Drift

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(Closed) LER 50-338/93-02: Pressurizer and Main Steam Safety Valve Setpoints Out of Tolerance Due to Setpoint .

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These three LERs concerned pressurizer and main steam safety valve failures where the lift pressure found during testing failed to meet TS limits within i one percent. Immediate corrective action l was to refurbish the valves and adjust the setpoints to meet the -

TS limit To preclude repeated TS complia, roblems with main steam safety valves, the licensee submitted T5 changes to allow a wider band of lift pressures (i three percent). These changes were approved and issued as Amendments 174 and 155 to Unit I and Unit 2 TS, respectively. The inspectors verified that the TS change was complet To preclude repeated TS compliance problems with pressurizer ,

safety valves, the licensee considered submitting TS changes to allow a wider band of lift pressures (i three percent). This wider band would also have required draining the loop seals to-

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ensure the valves' operation in a steam environment. The licensee

deferred loop seal modifications pending the completion of an NRC review of a Westinghouse Owner's Group report (WCAP-12910)

concerning generic safety valve issues addressed by IN 89-90 with Supplements 1 and 2. The licensee informed the inspectors that the NRC concurred with Westinghouse that draining the loop seals

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was unnecessary to address generic issue Since the loop seal draining was not required, and since a significant safety analysis margin would be expended, the licensee chose to discontinue efforts to expand the TS band for pressurizer safety valves. The licensee met with inspectors and provided information that confirmed that all issues discussed by IN 89-90 were being properly addressed, including using a stem position indicator during safety valve testing. The inspectors also noted that safety valve testing during the most recent Unit 2 outage had not identified any setpoint problems. The inspectors concluded that the licensee had completed appropriate actions to minimize the potential for recurring pressurizer safety valve setpoint drift-problem (Closed) LER 50-339/93-04: Inoperable Reactor Coolant Pump Trip Circuit Due to a Potential Single Failure This LER was written to document a Unit 2 condition where two out of three DC power cables for the RCP bus UF reactor trip circuits were located on the same neutral cable tray. Licensee immediate corrective actions were addressed in NRC Inspection Report No ,339/93-23. Additional corrective action included cable rerouting under DCP 93-018 which was completed during the Unit 2 refueling outage ending in October 1993. The inspectors considered this action appropriat . Action on Previous Inspection Items (92701)

The following previous inspection item was reviewed and closed:

(Closed) URI 50-339/93-23-01: IEEE 279-1971, Review of UF RCP Trip Circuitry This item was opened for continued review concerning the acceptability of Unit 1 DC power cable routing to RCP bus UF reactor trip circuits. A ,

condition was discovered during the licensee's DBD review process where DC power cables to all three channels of RCP bus UF reactor trip circuits were routed through a common conduit. The licensee reviewed the condition and considered it to be acceptable as documented in safety evaluation 93-SE-0T-76, dated September 20, 1993. This was based primarily on the point that there was no one creditable single failure which could affect more than one cable / channe The inspectors reviewed the safety evaluation and discussed the condition with a regional specialist inspector. On December 2, 1993, a phone call was held between the inspectors and the licensee to discuss the evaluation. The inspectors did not agree with all aspects of.the evaluation, but accepted the licensee's conclusion that this item was not a safety issue. Those conclusions were based on the following:

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In order for the protective circuitry to fail to carry out its design function, a single failure involving two of the three power i

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cables would have to occur simultaneous with an under frequency condition. The simultaneous occurrence of these conditions was '

improbabl If a single failure of the protective circuitry occurred, the failure would be quickly detected by an auxiliary operator during normal rounds. Indicating lamps are available locally at the under frequency relays which provide indication that power is available to each relay. Operator logs have been modified to regularly check the lamp The inspectors noted that although no safety issue existed, the as-found condition was still not in agreement with the UFSAR and, therefore, did not meet the licensing basis. The licensee indicated that they recognized the disagreement, and that this item was under review for either submitting a change to the UFSAR or modifying _ the cable routing during the next refueling outage. These actions were in accordance wit CFR 50.59 requirements as implemented by the licensee using VPAP-3001, Safety Evaluations, revision 2. The inspectors also expressed concern that a formal JC0 needed to be prepared and approve The licensee responded that VPAP-3001 permitted the safety evaluation alone to address the effect of deficiencies on operability in situations where compensating actions were not required. The inspectors reviewed the requirements for safety evaluations and JCOs and concluded that the 7.icensee had initiated the proper action j Exit Interview The results were summarized on December 22, 1993, with those individuals I identified by an asterisk in Paragraph 1. The inspectors described the ,

areas inspected and discussed in detail the inspection results addressed )

in the Summary section and those listed belo l Tvoe Item Number Status Description l

LER 50-339/91-06 Closed Failure to Place Inoperable Degraded l Voltage Relay in Trip Within One l Hour (paragraph 7.a)

LER 50-338/92-02 Closed Pressurizer Safety Valve Setpoint Out of Tolerance Due to Setpoint 'l Drift (paragraph 7.b) i LER 50-339/92-03 Closed Pressurizer and Main Steam Safety Valve Setpoints Out of Tolerance Due ;

to Setpoint Drift (paragraph 7.b)

LER 50-338/93-02 Closed Pressurizer and Main Steam Safety Valve Setpoints Out of Tolerance Due to Setpoint Drift (paragraph 7.b)

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LER 50-339/93-04 Closed Inoperable Reactor. Coolant Pump Trip Circuit Due to a Potential Single Failure (paragraph 7.c)

URI 50-339/93-23-01 Closed IEEE 279-1971, Review of UF RCP Trip Circuity (paragraph 8)

Proprietary information is not contained in this repor Dissenting comments were not received from the license . Acronyms and Initialisms AFW Auxiliary feedwater CCW Component Cooling Water CFR Code of Federal Regulations CR0 Control Room Operator DBD Design Basis Document DC Direct Current DCP Design Change Package DR Deviation Report EDG Emergency Diesel Generator EHC Electro-hydraulic Control I&C Instrumentation and Controls IEEE Institute of Electrical and Electronics Engineers IFI Inspector Follow-up Item IN Information Notice JC0 Justification for Continued Operation LAN Local Area Network LC0 Limiting Condition for Operation LER Licensee Event Report LHSI Low Head Safety Injection MSVH Main Steam Valve House NRC Nuclear Regulatory Commission PM Preventive Maintenance PSIG Pounds Per Square Inch Gage PT Periodic Test RCP Reactor Coolant Pump RWST Refueling Water Storage Tank SG Steam Generator SIL Service.Information Letter SNS0C Station Nuclear Safety and Operating Committee SOB Station Oversight Board *

TS Technical Specification UF Underfrequency UFSAR Updated Final Safety Analysis Report URI Unresolved Item WO Work Order WR Work Request 7