IR 05000369/1988030

Insp Repts 50-369/88-30 & 50-370/88-30 on 880924-1020. Violation Noted.Major Areas Inspected:Operations Safety Verification,Surveillance Testing,Maint Activities & Followup on Previous Insp Findings

ML20206A572
Person / Time
Site:	Mcguire, McGuire
Issue date:	11/04/1988
From:	Croteau R, David Nelson, Vandoorn K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206A530	List: IR 05000369/1988030 ML20206A528 ML20206A555
References
50-369-88-30, 50-370-88-30, NUDOCS 8811150174
Download: ML20206A572 (9)

Text

, . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

km 40u UNITED STATES

. 'o NUCLEAR REGULATORY COMMISSION

'

y%* n REGloN li g ,j 101 MARIETTA STRE ET, *' * ATL ANTA, GEORGI A 30323

% d 4+....s Report Nos. 50-369/88-30 and 50-370/88-30 Licensee: Duke Power Company 422 South Church Street (narlotte, NC 28242 Facility Name: McGuire Nuclear Station 1 and 2 Docket Nos: '0 '59 and 50-370 License Nos: NPF-9 and NPF-17 Inspection Conducted: Se tember 24, 1988 - October 20, 1988

/AV//

Inspectors:.K. VanD'oorn, Senior

/

sident inspector

// /N

'Date Signed I 97l/l/ )

0.~Nerson, Resident spector

// lN

/ DMe Signed

/ WlYY

R. Crot au, P 'sidenfinspector

//kkW

/ Date Signed Approved by: @7' K'

T. A. Pe(bles, Section Chief Vh /l[V [W Dat6 Signed Division of Reactor Projects SUMMARY Scope: This routine unannounced inspection involved the areas of operations safety verification, surveillance testing, maintenance activities, and follow-up on previous inspection findirg Results: In the areas inspected, one violation was identified involving inadequate post nodificatione training (see paragraph 7) and one Technical Specification violation was identified (see paragraph 3).

$$kISONh O

bb f a

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _________ _______ _______

,

.

.

REPORT DETAILS Person Contacted  ;

Licensee Employess J. Boyle, Superintendent of Integrated Scheduling

• B. Hamilton, Superintendent of Technical Services

• T. McConnell, Plant Marager W. Reeside, Operations Engineer

• M. Sample, Superintendent of Maintenance  ;

'

• R. Sharp, Compliance Engineer J. Snyder, Performance Engineer

• B. Travis, Superintendent of Operations  :

P. White, IAE Engineer  ;

Other licensee employees contacted included construction craftsmen, technicians, operators, mechanics, security force members, and office personne * Attended exit interview Unresolved Items An unresolved item (UNR) is a matter about which more information is  ;

required to determine whether it is acceptable or may involve a violation or deviation. There were no unresolved items identified in this repor . Plant Operations (71707,71710)

,

The inspection staff reviewed plant optrations during the report period to [

verify conformance with applicable regulatory requirements. Cuntrol room logs, shif t supervisors' logs, shift turnover records and equipment removal and restoration records were routinely perused. Interviews were conducted with plant operations, maintenance, chemistry, health physics,  ;

and performance personne ;

Activities within the control room were n.ot.- .;c a ing shifts and at shif t changes. Actions and/or activities o .s ' .:re conducted as -  ;

prescribed in applicable station administrative o a cives. The complement of licensed personnel on each shift met or exceedeo the minimum required by Technical Specifications, i l

Plant tours taken during the reporting period included, but were not i limited to, the turbine buildings, the auxiliary buildinc, Units 1 and 2  ;

electrical equipment roond, Units 1 and 2 cable spread) raoms, and the ;

station yard zone inside the protected are During the plant tour l ongoing activities, housekeeping, security, equipment status and radiation ,

control practices were observe ;

i

.

. , - - . . _ . - - - . . _ - . _ . - r -

,

,

.

?

The inspectors held discussions with the licensee relative to control c'

overtime in accordance with Technical Specification 6.2.2. 3ased on an NRC violation issued at the Catawba station the licensee was attempting to provide improved controls for similar personnel at the McGuire Statio Essentially, the licenser jid not have formalized controls for exempt (non-hourly wage classifirstion) personnel prforming safety related work other than in the Operations grou The inspector agreed that the fitness-for-duty program adequately addresses control of supervisory personnel, however, hands-on workers, whether exempt or non-exempt, are required to be under an advance approval formalized program. The licensee agreed to implement this program. As an interim, until the complete formalized program can be developed, an internal memorandum was issued to require additional controls. The inspectors agreed that this would be an acceptable interim control. Also discussed was the requirement for the Station Manager or his Deputy to approve overtime in excess of the guidelines. The licensee requested that the Shift Engineer should be considered the Deputy for this purpose. The inspectors indicated that this would be acceptable only if the Shift Engineer position :s formally described as the deputy Station Manager for this function. Tht licensec  ;

stated that before allowing Shift Engineer approval the job function would be appropriately defined. It is noted that this change would be a change in a previous e xmiitment. (see response to violation 369,370/87-26-01 dated November 5, 1987) This report serves to document an NRC agreei to deviation from that commitment provided the above described program is implemented. The inspector also verified that the Qual;;.y Assurance Cepartment has also implemented control of overtime. Controls apr> ear to '

be adequate via QA Management procedure Nu11ber 203.05-QA-00 Licensee QA personnel indication that all personnel performing hands-on work were non-exempt personnel and overtime guidelines are rarely exceeded since  !

personnel are rotated to provide adequate QA coverage during busy period l Unit 1 Operations t Unit 1 bega'1 the retporting perio<i at 100% power. At 7:07 a.m., on I October 7, the unit sustained a turbine runback to approximately 60%

powe The runback was due to the loss of the operating main oil '

m p (M0P) on f'ed pump The M0P tripped on overload. The standby LP started, but not before oil pressure decreased to the point of dllowing the feed pump turbine stop valves to shut, thereby stopping  ;

the A feed r. um The operators responded to the decreased feed flow i by manually initieting the runback. An automatic runback did not initiate because a feed pump trip did not occu The A feed pump was subsequently restarted, and the unit returned to full power at 6.00 p.m., the same da In recent months both units have sustained transients without trips due ' prompt response by the control room operators. Especially noteworthy is the response to the Unit 1 transient of vetober 7  ;

(described above). During that transient the runback was sustaine$ i with the feed flow to the O steam generator in manual control. The [

NRC considers the ability demonstrated by control room personnel to correctly and promptly respond to plant events to be a strengt i

. , - - - - , - - . - - - - . . , - - - , , - ,, , . - - _ . .

_

'

.

.

.

At 9:00 p.m., on October 1;, Unit 1 began a controlled shutdown fo* the End-0f-Cycle (E0C) 5 refueling outage. The unit was off-line at 6:31 a.m., on Octob2r 12, and entered Mode 3 at 6:44 Shortly after entering Mode 3, the 18 month surveillance on the Annulus Ventilation (VL) system was conducted and determined that both trains of VE were inoperable. (See paragraph 4 for det;ils of the surveillance). Technical Specification (TS) 3.0.3. was entered at 7:00 a.m. If entered during Mode 1 operation TS 3.0.3. requires unit shutdown to commence within one hour with progression to HOT STANDBY (Mode 3), HOT SHUTDOWN (Mode 4), and COLD SHUTDOWN (Mode 5)

occurring within six hours, six hours, and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, respectivel The BASES for TS 3.0.3. states that if the plant is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower MODE of operation applies. In this case, the unit would be required to progress from Mode 3 to Mode 4 within seven hours (including one hour to initiate action), and then to Mode 5 in the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee's actions upon entering TS 3. were to continue with the shutdown as planned but imposing the TS 3.0.3. time limits based on an interpretation dated June 16, 198 This interpretation deteruined that the TS 3.0.3. time limits were cumulative, i.e., time not used to shutdown from Mode 1 could be applied starting at wl.3tever MODE was in effect upon entering TS 3.0.3. Based on this interpretation, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> were available to reach Mode 4. When Mode 4 was entered at 6:59 p.m., 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> and 59 minutes had elapsed since entering TS 3.0.3. This resulted in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ar.d 59 minutes in excess of that allowed being spent in Mode The 1983 interpretation became outdated in Juno,1988, upon the issuance of TS amendments 87 and 68 for units 1 and 2 respectivel These amendments added specific guidance to the BASES Tar TS 3. for the situation of entering 3.0.3. while in a MODE other than Mode Operations and Compliance persor.nel were unaware that the 1983 interpretation was outdat4d. The licensee stated that the 1963 interpretation should have been deleted based upon the change to the BASES, and is taking steps to correct the discrepancy. This problem is similar to the issue discussed in paragraph 7 concerning training following modifications in that Operations personnel were not infonned of a change that affects plant oper. tion. The excess time spent in Mode 3 is identified as a violation of TS 3. (Violation 369/8C-30-01)

The unit was placed in a partially drained condition in order to prepare for maintenance on October 1 Duri'~ the drain dawn, the operators monitor level in the reactor vesse. ndirectly by use of the Reactor Vessel Level Indication System (RVLIb), Operator Aids Computer (0AC) indication, and by a temporarily installed sight glas These indications did not perform as expected during the drain down.

. Level response was slugg'sh and inconsistent between the indicators.

]

o

____ _ _____ _______

-

.

,

The licensee approached the problem from a conservative standpoint and actually delayed the outage schedule for approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to ensure that accurate, reliable level indication existed. The NRC considers this conservative approach to be commendabl The unit remained shutdown in the E0C 5 outage for the remainder of the perio Unit 2 0.ocrations Unit 2 was operated at approximately 100% power for the entire period with no significant operational problem . Surveillance Testing (61726)

Selected surveillance tests were analyzed and/or witnessed by the inspector to ascertain procedural and performance adequacy and conformance with applicable Technical Specification Selected tests were witnessed to ascertain that current written approved procedures were available and in usc, that test equipraent in use was calibrated, that test prerequisites were met, that system restoration was completed and test results were adequate.

'

Detailed below are selected tests which were either reviewed or witnessed:

PROCEDURE EQUIPMENT / TEST PT/1/A/4400/01N Halon System Periodic Test for Diesel Generator and Turbine Driven CA Pump Room PT/2/A/4450/3C Annulus Ventilation System Performance Test During the Unit 1 shutdown for refueling, the 18 month surveillance required by TS 4.6.1.8.d on the Annulus Ventilation (VE) System was performed in accordance with station procedure PT/1/A/4450/3C, Annulus Ventilation System Performance Test. This surveillance determined that both trains of VE were inoperable because the portion of the surveillance v'ich tests the ability of the annulus to remain at negative pressure during the recirculation phase of VE operation failed. Upon starting, each train of VE is required to bring th? annuius atmosphere to a negative pressure of less than or eoual to 0.5 inches witer gauoe (W.G.) within 22 seconds; decrease pressure to -3.5 inches W.G. within 48 seconds; and upon reaching -3.5 inches W.G. , switching to the recirculation phase and keeping the pressure belcw -0.5 inches W.G. for greater than or equal to 278 seconds. However, during the test, the negative pressure could only be maintained for 258 seconds on train A. All other segments of the surveillance were satisfactor The licersee determined that excess leakage into the annulus may have been taking place through the seals on the doors to the annulus frou the auxiliary building. The licensee

_ _ - . .

- _ _ - _ _ _ _ _ _ _ - _ _ - _ _ _ _ _

.

,

declared both trains inoperable since door seal leakage would affect both trains. Repairs were conducted on the seals, but the test failed again

, for both trains. Finally, the seals were replaced and the test was successfully complete .

'he i corresponding doors on Unit 2 were subsequently inspected during the licensee's "Failed Surveillance Analysis" program. The Unit 2 door seals were determined to be suspect based on observed damage. The VE surveillance was performed and both trains tested satisfactorily, however, ,

the licensee is planning corrective maintenEnce to preclude unknown

'

inoperability in the futur No violations or deviations were identified Maintenance Observations (62703)

Routine maintenance activities were reviewed and/or witnessed by the resident intpection staff to ascertain procedural and parformanwe adequacy and conformance with applicable Technical Specifications.

' lhe selected activities witnessed were examined to ascertain that, where applicable, current wri' ten approved procedures were available and in use, that prerequisites were met, that equipment restoration was ccmpleted and i maintenance results were adequat The following maintenance activities were either reviewed or witnessed: ,

'

.

PT/0/A/4350/71 Diesel Generator Periodic Maintenance (Db 1B)

No violations or deviations were identified.

) Licensee Event Report (LER) Followup (90712,92700)

j The following LERs were reviewed to determiv whether reporting requirements have been met, the cause appears accurate, the corroctive actions appear appropriate, generic applicability has been considered, and f

whether the event is related to previous event Selected LERs wire chosen for more detailed review. The following LERs are considered closed: t LER 369/88-18 LER 369/88-21 LER 369/87-29 LER 369/88-22 .

!

(Closed) LER 369,370/88-19, Flow Rates of FSAR Could Not Be Achieved For ,

Unit 2 Hydrogen Skimmer System. This issue was the subject of Special "

Inspection Report 369,370/88-24 and corrective actions will be tracked in followup to the items opened in that repor (Closed) LER 370/88-09, Inadvertent Engineered Safety Features Actuatio This issue was documented in Inspection Report 369,370/88-23 and corrective actions will be tracked in followup to unresolved itec 88-23-0 ,. _ _ _ _ _ _ _ __ _ _ _ . - _ _ _ _ __

___ __ _ - - _ - _ _ - - _ _ .

-

.

. .

.

! Follow-up on Previous Inspection Findings (92702)  ;

'

The following previcusly identified items were reviewed to ascertain that the licensee s responses, where applicable, and licensee actions were in ;

compliance with regulatory requirements and corrective actions have been ,

complete Selective verification included record review, observations,

,

and discussions with licensee personne (Closed) Inspector Followup Item 169/87-30-01, Followup Letdown Line Failure / Transient, OEH Problem and MSR Relief Valves. Details of the findings and corrective actions are documented in LER 369/87-17.01. The ,

licensee actions appear appropriate, however, the inspectors partially attribute the cause of the transient to be personnel error rather than ,

totally attributable to a design deficienc ;

) (Closed) Unresolved Item 370/38-23-02, ESF Actuation. On July 24, 1988, a Unit 2 ESF actuation (feedwater isolation) occurred when the Low Tave :

setpoint was reached with the reactor trip breakers open in Mode 3. This i event was documenteo as Unresolved item 370/88-23-02 in Inspection L

Report 369,370/88-2 l

'

The 2SF actuation was primarily due to the fact that operations personnel were unaware that the Low-Tave setpoint had been changed during the outage. The licensee stated that training had not been conducted on the

, change due to personnel erro Operations Employee Training and i

Qualificaticn System (ETQS) personnel had delayed training on the ,

i modification in order to combine the training with training on other ;

j modifications, however, the responsible person was away from the station (

3 when the training package should have been circulated. Other items in the f l training package included modifications that did not require imediate j trainin i The licensee has several documents which specify the process for j implementation of Nuclear Station Modifications (NSMs) with respect to i j procedure changes and training. Duke Power Company Topical Report, ,

1 Ouke-1, Quality Assurance Program, section 17.2.3, Design Control, states ;

l that "prior to a modification being declared operable and returned to l service, all procedures governing the operation of the modif%ation are l reviewed and revised as necessar If the modifit.ation significantly j alters the function, operating procedure, or operating equipment, then 1 additional training is administered as necessary". The Nuclear Station l Modification Manual, section 7.8.7 states that "prior to returnirg a

! system to service, the following shall bc completed, as appropriate...

,

Personnel Training (and)... Procedure revisions". McGuire Station l Directive 4.4.1, Processing Nuclear Station Modifications, states that

"Before a modified structure, system, or component is declared operable.

l all procedures governing the operation of such systems shall be reviewed i and revisions processed as needed," however, training is not addressed.

j Operations Management procedure (OMP) 1-11, Operations NSM 1mplementn%n i

i

.

_ _ _ _ _ _ _ _ _ _ _ . ___

.

,

.

Process, section C.8 states that "durirg the modification process, the Projects Group Accountable Engineer shall notify the Operations NSM Coordinator in sufficient time to allow completion of the following prior to return to service of the modified system or component: A. Training of appropriate personnel; B. Processing of any procedure changes; and C. Filing of Interim Drawings in Control Room."

The OMP does not specifically require training and precedure changes to be complete prior to returning the item to service although Section implies this. OMP 1-11 also requires completing an "NSM Pracass Cecord" check list to track the status of the NSM and ensure training is conducted, drawings are updated, procedures are changed, et The training, however, is not required to be completed prior to returning a system to service and declaring it operable. In general, the action taken has been to issue the training package when the NSM is completed and return the system to service / declare it operable based ori the expectation that the training will be completed in the near future. It rr.ay be moriths before all shifts receive the training. No process exists to ensure that operators are aware of changes to the equipment prior to their assumption of licensed duties. Several of the instructions mentioned earlier imply that training will be conducted prior to restoring a modified system or component to operable statu The inspectors recognize that it is not practical to withhold returning a system to an operable condition until all litansee personnel are trained. it is, however, necessary to ensure l licensed personnel are aware of significant changes made to the plant.

l such as the lowering of the low-Tave Setpoint, prior to the assumption of licensed activities.

l l Ihe current practice of conducting training on NSMs is inadequate in this area and existing instructions do not provide adequate guidance. The inspectors censider the current process to ensure that operators are trained on station modifications to be a weaknes In the specific case of the feedwater isolation on July 24, 1988, personnel training was not conducted prior to declaring the low-Tave setpoint event is function operable identified following (the as a violattun modificationofof /TS-30-02) the syste .8.1. forThis failure to follow procedure (Nuclear Station Modification (NSM) Manual Saction 7.8.7.) and for inadequate procedures in that station administrative procedures appear to be inadequate in inplementation of the NSM Manual requirement . Exit Interview (30703)

The inspection findings identified below were sumarized on October 20, 1988, with those persons indicated in paragraph 1 above. The following i+.e:as were discussed in detail:

(OPEN) Violation 369/88-30 01, Violation of TS 3.0.3 for failure to place Unit 1 in Mode 4 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> upon entering TS 3.0.3 while in Mode (paragraph 3)

- __-____ ____ _ _ _ _ _ _ _ -_~

. _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ .___ _ _ _ _ -_ -_ ________ -____ - _ ____ __ - ______ _ _

.

o

, . *

.

t 8 (OPEN) Violation 370/88-30-02, Violation of TS 6.8.1 for failure to follow an administrative procedure with respect to training station personnel prior returning a modified system to service. (paragrai:h7)

A weakness was identified with respect to the licensees method for ensuring licensed operators are trained on modified systems prior to returning the systems to service. (paragraph 7)

,

A strength was identified in the area of operator responce to events and transients. (paragraph 3)

'

The licensee representatives present offered no dissenting comments, nor did they identify as proprietary any of the information reviewed by the

'

inspectors during the course of their inspectio l v

j i

i I

i

!

l

1 l

l l

l

!

I I