IR 05000416/1982013

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IE Insp Rept 50-416/82-13 on 820118-0216.Noncompliance Noted:Failure to Follow Preoperational Test Procedure
ML20054D864
Person / Time
Site: Grand Gulf 
Issue date: 03/01/1982
From: Hardin A, Wagner A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20054D831 List:
References
50-416-82-13, NUDOCS 8204230457
Download: ML20054D864 (5)


Text

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NUCLEAR REGULATORY COMMISSION o g a REGION 11 [ 101 MARtETTA ST., N.W., SUITE 3100 o,% e ATLANTA, GEORotA 30303

Report tio. 50-416/82-13 Licensee: Mississippi Power and Light Company Jackson,its Facility flame: Grand Gulf Docket No. 50-416 License No. CPPR-118 Inspector: [[ Im J//!8L _a_s A. E. llagner g Date Signed ' Approved by: N m' J///8L A. K. Hardin, Acting Section Chief Date Signed Projects Section 1B, Division of Project and Resident Programs SUMMARY Inspection on January 18 - February 16, 1982 Areas Inspected This routine, announced inspection involved 82 resident inspector-hours on site in the areas of Preoperational Test Schedule, Preoperational Test 111tnessing, Schedule review, Plant Task and THI Task Action Plan Implementation.

Resul ts Of the 5 areas inspected, no violations or deviations were identified in 4 areas; 1 item of violation was found in 1 area (Failure to Follow Procedure, paragraph 9.). 8204230467

. . , REPORT DETAILS 1.

Persons Contacted Licensee Employees

  • C. K. McCoy, Plant ibnager
  • J. W. Yelverton, Quality Assurance Supervisor
  • M. A. Lacey, QA Representative
  • J. C. Bell, QA Representative C. R. Hutchinson, Startup lbnager Other licensee employees contacted included 2 technicians and 4 operators.
  • Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on February 16, 1982, with those persons indicated in paragraph 1 above.

The licensee had no comments regarding the inspection findings.

3.

Licensee Action on Previous Inspection Findings Not inspected.

4.

Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions.

New unresolved items identified during this inspection are discussed in paragraph 9.

S.

Preoperational Test Schedule The inspector reviewed the revised testing schedule dated 1/26/82.

The schedule appeared to reflect the current status of testing and the latest project schedule for the completion of testing.

Representatives of NRC Region II office and the resident inspector met with senior management to discuss construction plans for Grand Gulf Nuclear Station.

It was disclosed that certain construction activities would take place on Unit 2 as work on Unit 1 is completed.

l No violations or deviations were identified within the areas inspected.

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6.

Plant Tour The inspector toured portions of the control building, auxiliary building, containment and standby service water structure.

The inspector observed the following activities in progress: hot work; housekeeping; equipment preser-vation; fire equipment; clearances; maintenance; instrumentation; com-munciations and equipment controls.

No violations or deviations were identified within the areas inspected.

7.

Inspector Followup Items (Closed) Open Item 81-13-03 - The inspector reviewed the revised references in the FSAR tables. The revised data correctly references LPCS data.

There are no further questions concerning this item.

This item is closed.

(Closed) Open Item 81-15-04 - The licensee reviewed FSAR transient information with the NSS supplier.

!* was determined that no changes are required for the infomation supplied in the FSAR.

Additional information Wds provided to aid in the classroom instruction of operators. There are no further questions. This item is closed.

8.

Tl11 Task Action Plan Implementation A review was conducted of the procedures and actions implementing the-requirements of the THI Task Action Plan. These requirements are delineated in NUREG 0660 and 0737.

The licensee has responded to the NRC by letters AECM 81/387 of October 2,1981, AECil 81/153 of June 12,1981 and AECM 81/276 of August 19, 1981 describing the implementation or providing an implement-ing procedure for the plan item.

A.

The following items were reviewed with no comments noted and are closed: (1) I.D.1 Control Room Design (2) II.D.1 Relief and Safety Valves

' (3) II.E.4.1 Containment Dedicated Penetrations - Hydrogen Control B.

The following items were reviewed with comments as noted: (1) 1.C.7 NSS Vendor Review of Law Power Test Procedures . This item has not been accomplished.

. (2) II.D.3 Relief and Safety Valve Indications ! l The testing program does not contain provisions for the dynamic l testing of the installed indicating devices.

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l i .h (3) II.F.2 Inadequate Core Cooling Instruments i flississippi Power and Light Company has adopted and followed the BWR Owners Group generic guidelines for the implementation of ! Grand Gulf Emergency Procedures.

It is their position that no

further instrumentation is required.

The NRC staff has concluded l that there will be additional instrumentation required.

The i safety evaluation related to the operation of Grand Gulf Nuclear

Station Units 1 and 2, NUREG-0831, states in section 22.2, II.F.2, ! that additional instrumentation and supporting documentation ! addressing these requirements be incorporated by June 1983.

They , will be accomplished in accordance with Regulatory Guide 1.97.

t 9.

Preoperational Test Witnessing i i The inspector witnessed the conduct of portions of preoperational test . 1C71PT01 " Reactor Protection System Preoperational Test". The test was , observed for conformance with Grand Gulf Startup Manual Chapter 5000 and , 7000. The inspector witnessed the conduct of two safety-related surveil- ! lance procedures in support of the preoperational test. The surveillance procedures are 06-IC-1C71-R0078, Revision 0, " Turbine Stop Valve Trip Fluid , Low Pressure, Channel B Calibration "and 06-IC-1B21-R-0682, Revision 0,

" Reactor Vessel Water Level (Level 3 & 8) (RPS/RHR) Channel B Time Response".

' The surveillances were observed for conformance to the Grand Gulf Nuclear

Station Operations Manual, Volumes 1 and 7, and the MPL-Topical-1A.

During ' the conduct of these activities the following observations were made.

" ! A.

During the conduct of surveillance procedure 06-IC-1C71-R-0078 the k inspector noted that TCN number 3 was missing.

Checking the attached ' TCN's it was noted that TCN 4 contained two pages.

The second page was marked TCN 3.

There was no approval page for TCN 3.

This item is unresolved (416/82-13-01) pending review by the licensee to determine the location of TCN 3 cover sheet.

B.

During the conduct of surveillance procedure 06-IC-1C71-R-0078 the inspector noted that the technicians were using a proposed TCN 5 to the , procedure. The proposed TCH was not incorporated into the procedure.

The technician reading the procedure was flipping back and forth between the procedures and proposed TCN 5.

The technician performing the procedure clarified several steps which appeared to be confusing to the reader.

In addition, several procedural steps were added to TCN 5 t by the technicians during the procedure performance.

It was noted that TCN 5 cover page was not dated and contained only the signature of the technician performing the procedure.

When asked about the necessary approval,_ the inspector was -told that approval of the TCH was not required until after the procedure is completed.

In addition,the after-the-fact approval of TCN's is common practice for instrument surveillance procedures as directed by plant management.

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The failure to obtain approval prior to performing the TCN is a . violation of administrative procedure 015-02-2, Revision 4, paragraph 6.4.1(a) for minor changes which requires approval by a knowledgeable member of plant staff in addition to the person changing the procedure.

Also the inspector questioned the scope of the changes being classi-l fied as minor changes (see pragraph D below).

Paragraph 6.2.1 of the i administrative procedure states "All directives shall be strictly

adhered to."

This procedure could not have been strictly adhered to

! since it was not complete and correct at the time of performance.

These actions also are not in accordance with paragraph 5.2.2 of

ANSI 18.7-1976 which the licensee has committed to in the Quality i Assurance Topical Report. This will be identified as violation '

416/82-13-02, Failure to follow procedure.

C.

Upon review of surveillance procedure 06-IC-1C71-R-078 it was noted that the reference in paragraph 6.3 was incorrect. The transmitter

installed is a Schaevitz transmitter vice the Alphaline instruments referenced. This is the second instance where an incorrect technical ! reference has been used in the preparation of maintenance directives.

l (0 pen Item number 416/81-22-03 involving limitorque valves is still r open.) This is designated open item 416/82-13-03 pending review by the j licensee to determine the adequacy of technical references used in the ,. ' preparation of maintenance directives.

D.

During the review of the proposed TCN 5 there appeared to be changes which went beyond the scope of minor corrections.

Examples are the ' test method changes, plant condition clarifications (operating mode requirements) and numerous correction changes.

The individual pro-

posing the change was of the opinion that these changes were minor in nature and did not require handling as a major change.

The inspector is concerned that the differentiating criteria is ambiguous to i personnel in the field performing maintenance activities.

This is designated open item 416/82-13-04 pending review by the licensee to , determine the adequacy of the criteria provided.

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