IR 05000416/1982018

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IE Insp Rept 50-416/82-18 on 820216-0310.Noncompliance Noted:Failure of Assistant Plant Manager to Review Administrative Procedures
ML20053E387
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 03/23/1982
From: Butcher R, Hardin A, Wagner A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20053E358 List:
References
TASK-1.C.7, TASK-2.D.3, TASK-2.F.1, TASK-2.K.1, TASK-TM 50-416-82-18, NUDOCS 8206070856
Download: ML20053E387 (8)


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UNITED STATES 8'

NUCLEAR REGULATORY COMMISSION o

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,E REGION 11 101 MAHlETT A ST, N W., SUIT E 3100 0,

[g ATLANTA, GEORGIA 30203

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Report flo. 50-416/82-18 Licensee: flississippi Power and Light Company Facility flame: Grand Gulf Docket flo. 50-416

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License flo. CPPR-118 Inspection at Grand Gulf site near Port Gibson, Mississippi Inspecto s:

[6 T/12/91 A. G. Wagner Date Signed N,

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R. Butcher Date Signed

[/rw[.m 3//J/Jd Approved by:

A. Hardin, Acting Section Chief, Division of Date Signed Project and Resident Programs Suit!!ARY Inspection on February 16 - March 10,1982 Areas Inspected This routine, announced inspection involved 110 inspector-hours on site in the areas of IE Circular follow up, IE Bulletin follow up, TMI Task Action Plan Implementation, As-built comparison, Preoperational Test Witnessing, System Turnover Review, System Jurisdictional Controls, Quality Assurance Monitoring, Plant Tour, and Plant Maintenance Review.

Results Of the 10 areas inspected, no violations or deviations were identified in 9 areas; one item of noncompliance was found in one area (Failure to follow procedure, paragraph 7).

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8206070856 820527 PDR ADOCK 05000416 G

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DETAILS 1.

Persons Contacted Licensee Dnployees

  • C. K. McCoy, Plant Fhnager
  • C. L. Stuart, Assistant Plant Manager

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  • J. W. Yelverton, Quality Assurance Supervisor
  • L. C. Daughtery, Plant Quality Supervisor
  • M. A. Lacey, QA Consultant
  • J. C. Bell, QA Engineer
  • R. Roma, Test Supervisor
  • R, McAnuity, Test Supervisor
  • Attended exit interview 2.

Exit Interview

The inspection. scope and findings were summarized on March 10, 1982, with those persons indicated in paragraph 1 above. The licensee had no comments i

regarding the violation. The plant manager commented in reference to paragrapa 14 herein that these procedures had not received the review committed to by MP&L in regard to field TCN's made to instrument surveillance procedures.

3.

Licensee Action on Previous Inspection Findings Not inspected.

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Unresolved Items Unresolved items are matters about which t e information is required to i

determine whether they are acceptable or may involve violations or devia-l tions. New unresolved items identified during this inspection are discussed

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in paragraph 14.

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S.

IE Circular Follow-up The inspector reviewed the actions taken by the licensee with regards to the following IE Circulars.

Documentation of circular review for applicability and corrective actions were reviewed.

a.

The inspector had no comments concerning the licensee actions and the following IE Circulars are closed:

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l 80/03 81/08 l

80/10 81/10 l

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2 b.

The licensee has not completed review and corrective actions for the following items. These items remain open:

80/11 81/05 81/13 80/22 81/07 81/14 6.

IE Bulletin Follow-up The inspector reviewed the actions taken by the licensee with regards to the following IE Bulletins.

Documentation of bulletin review for applicability, suggested corrective action, technical evaluation and corrective actions were reviewed.

a.

The following bulletins have been responded to by the licensee. These responses have been reviewed and there are no further questions. These items are closed 80-03 81-02 b.

The following bulletin has been responded to by the licensee. This response is currently under review:

80-11 c.

The licensee has not comoleted review and corrective actions for the following bulletins:

79-02 79-14 79-27 80-24 79-07 79-15 80-06 81-01 7.

D11 Task Action Plan Implementation A verification was conducted of the actions implementing the requirements of the THI Task Action Plan. These requirements are delineated in NUREG 0660 and 0737.

The licensee ::s responded to the NRC by letters AECM 81/387 on October 12,1981, AECM 81/153 of June 12, 1981 and AEQt 81/276 of August 19, 1981 describing the implementation or providing an implementing procedure for the plan item. The NRC staff has reviewed the responses and have provided evaluations in NUREG 0831, Safety Evaluation related to the Operation of Grand Gulf Nuclear Station, Units 1 and 2 (SER). The following items were reviewed with comments as noted:

f a.

I.C.7 NSS Vendor Review of Low Power Test Procedures. This item has

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not been accomplished and will remain open.

b.

II.D.3 Relief and Safety Valve Indication The licensee committed to the installation of a pressure sensing device in the Safety and Relief valve exhaust line.

This installation to provide positive indication that the valve is open. A field verifi-cation was performed on the installation. The mechanical components k

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have been installed. The electrical modifications have not been completed in the indication circuitry. The licensee had not identi-fied in his preoperational and startup testing programs the required static and dynamic verification tests.

This item remains open.

II.F.2 Inadequate Core Cooling Instruments c.

The licensee has responded with their concurrence with the BWR Owners Group position.

The Owners Group endorses generic guidelines for the development of plant specific emergency procedures.

It is their

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position that no further instrumentation is required.

It was concluded fran the staff review that there will be additional instrumentation required.

The SER states in section 22.2, II.F.2 that additional instrumentation and supporting documentation addressing these require-ments be incorporated by June 1983 in accordance with Regulatory Guide 1.97.

This item remains open.

d.

II.K.1 IE Bulletins on Ikasures to Mitigate SBLOCA's and Loss of F. W.

Accidents.

(1)

Item 5.

The following observations were made in regards to the licensee response as outlined in the FSAR. This item remains open.

(a) The inspector reviewed the Protective Tagging Procedure for

the use of miniature tags on control panels.

It does not contain a requirement for using minature information tags.

During a control room tour large information tags were in use.

(b) The inspector reviewed administrative procedures 01-S-06-12,

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Revision 3 and 01-5-07-1, Revision 5 for incorporation of the requirement that procedures for surveillance testing and maintenance will include provisions to ensure proper valve alignments for engineered safety features functioning upon

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return to normal. Neither procedure had incoporated this requirement.

(c) The following requirements were not incorporated into the plant administrative procedures:

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When possible, Operations will perform a functional test or Surveillance Operability Test following maintenance on any safety related system.

When such tests are not possible, a complete valve and electrical lineup will be performed within the tagged boundary and a partial functional test will be performed where possible to provide assurance that systems are in fact functional af ter maintenace.

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During periodic tours, Operators and Supervisory

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personnel will conduct spot checks of fluid system and electrical line-ups.

System line-up changes, other than those covered by

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step-by-step ; procedures will be logged and abnormal line-ups will be covered during shift turnover.

(2)

Item 10. The inspectorIreviewed the following administrative

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i procedures verifying that require:nents for safety related system operability status is assured as outlined in the SER.

01-S-06-02, Revision 4 01-S-06-12, Revision 3 This item is closed.

(3)

Item 22. This item is not completed.

(4)

Item 23.

The staff has reviewed the licensee response and has concluded in the SER that no additional comitments are necessary.

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This item is closed.

e.

II.K.3 Final Recommendations of B&O isk Force (1)

Item 138.

The staff has concluded in the SER that no modifications

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are required for this item., This item is closed.

,f (2)

Item 15. The inspector has verified documentation of completion

of the required modification.

The requirements for testing the modification are included in the preoperational test. This item is closed.

(3)

Item 22.

This inspector,hks verified documentation of completion

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i of the required inodification.

The requirements for testing the modification are included in the preoperational test. This item

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is closed.

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(4)

Item 24.

The Grand Gulf design includes room coolers for safety-

related pump rooms. No modifications are required for this item.

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This item is closed.

.(5)' Item 27. The inspector has verified the installation of the required r'eference level modifications. The incorporation of the

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common water level reference for the Safety Parameter Display

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System will be performed in THI Action Plan Item I.D.2.

This item

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is closed.

During the review;of Admi'listrative Procedures 01-5-06-02, Revision 4, Audit of: 0perators and 01-S-06'-03, Revision 5, Control of System Temporary

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Alterations, it was noted that they were not reviewed by the assistant plant s

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7, manager. Administrative Procedure 01-5-02-02, Revision 6, Control and use of the GGNS Operations Manual paragraph 6-2-8 requires that administrative.

procedures be reviewed and approved by appropriately designated plant f management.

In the above cases, the fluclear Support Manager reviewed the procedure for himself and the Assistant Plant ihnager.

This will be identified as violation 416/82-18-01, failure to follow procedure.

The inspector did

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not review all approved administrative procedures for additional examples.

8.

Comparison of 'As-Built Plant to FSAR Description

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The High Pressure Core Spray (HPCS), Low Pressure Core Spray (LPCS). and

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Combustible Gas Control System were inspected by direct observation to determine that the physical installation was in agreement with the P&ID's dnd the system descriptions contained in the FSAR.

Portions of the systems, such as the pump suction lines that originate in the suppressiog pool or the minimum flow and test return lines that discharge back into the suppression pool, could not be verified since the suppression pool was filled with i

water. There were two problems noted. Approximately One-half of the valves were missing identification tags and had to be verified by loc. ' ion in the system.

The installation of identification tags assist operators during component operations, they minimize personnel exposure in' radiation areas and reduce operational errors.

This will be carried as inspectgr follow-up item 416/82-18-02.

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The P&ID's do not show, nor do they identify, isolation valves in piping that leads to instruments.

This has been previously identified and is carried as inspector follow-up item 81-25-03.

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Preoperational Test Witnessing

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The inspector witnessed the conduct of portions of precperational test 1C71PT01, Reactor Protection System Preoperational Test.

The test' was observed for conformance with Grand Gulf Startup tknual Chapter 5000 and 7000. Du' ring the conduct of the Separation Test both the 'A' and 'B'

solenoids of the outboard Main Steam Isolation Valvos deenergized.

The test was stopped and a startup field report was submitted in accordance with the

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startup manual requirements.

No violations or deviations were identified within the areas in,spected.

10.

System Turnover Reviews S

l The turnover packages for portions of the Process Radiation.,ilonitoring and tne Emergency Lighting System were reviewed for confonntn'celto the require-ments of Grand Gulf Startup thnual Chapter 7000 and Bechtel; Checkout and Turnover Organization ihnual Chapter 4, section 16.

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fia violations or deviations were identified within the areas inspected.

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System Jurisdictional Controls

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Portions ci the Process Radiation ilonitoring System and the Emergency Lighting System were visually spot checked to verify system tagging had been accomplished as required by the Grand Gulf Startup flanual Chapter 5000, paragraph 4.4.

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

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12.

Quality Assurance Monitoring i

The inspector reviewed the quality assurance monitoring activities in the preoperational test area.

The activities were reviewed for conformance with Quality Assurance Procedures Manual, Chapter 18.20.

The following reports

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were reviewed.

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ItAR 82/09 Preoperational Test 1C885T0i

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IlAR 82/12 Plant Safety Review

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There was one deficiency noted during the conduct of the monitoring audit.

The docunientati'on of the deficiency and the corrective actions were con-

tained in CAR 477.

The CAR was reviewed to ensure that corrective actions have been appropriately completed.

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No violations or deviations wer identified within the areas inspected.

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13.

Plant Tour

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p The inspector toured portions of the control building, auxiliary buildi,ng, containment and diesel generator' structures. The inspector observed the i

following activities in prpyres's': hot work; housekeeping; equipment

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preservation; fire equipment and communications.

No violations or deviations were identified within the areas inspected.

14. Plant liaintenance Review < '

The inspector reviewedi the records for the conduct of the followin'g maintenance activity MW0's:

IN5524 approved 3-4-82

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IN5517 approved 3-4-82

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1N5518 approved 3-4-82 IN5516 not satisfactorily completed 1N5046 approved 3-4-82

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IN5039 approved 3-2-82

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IN5040 approved 3-2-82 l

l These activities require the conduct of instrument. response tests.

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activities were observed for confonnance to the Grand Gulf Nuclear Station l

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Operations Manual, Volume 1 and 7 and the MPL-Topical-1A. The following discrepancies were observed.

a.

IN5524, IN5517, IN5518 and 1N5516 did not have the procedural require-ment correctly incorporated into data sheet, paragraph 5.16.26.

Three of the four procedures did not indicate that the prerequisites were met for performing the procedure.

b.

1N5046 TCN #3 changed the note in Data Sheet II but was not correctly transcribed in the data package.

Step 5.16.24 was deleted in the data package and marked TCN #3 but was not included in the approved copy of TCH #3.

c.

1N5039 TCN #2 made approximately twenty changes to the data sheet.

Approximately ten of these changes were not entered on to the data sheet. Step 5.15.14 had the level point changed from 8 + 1 to 9 + 0.5 and was annotated TCN #2.

TCN #2 did not include this change.

d.

1N5040 did not include TCN #2 step 5.15.3 change.

The inspector was not informed prior to the review that these procedures had not had the final review for the TCN problems identified in I&E inspection report 50-416/62-13.

However, each contained the_ dated signature of the I&C superintendent. The inspector is concerned that plant staff personnel have not been provided appropriate guidance as to the significance of signature sign-offs on official plant records. This item is considered unresolved l

pending further review by the licensee and the NRC. Unresolved Item 416/82-18-03.

The corrective actions for TCN errors will be reviewed after the licensee has responded to previously opened violation 416/82-13-01.

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