IR 05000416/1982040
| ML20058C049 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 06/03/1982 |
| From: | Cantrell F, Scott D, Wagner A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058C004 | List: |
| References | |
| 50-416-82-40, IEB-80-06, IEB-80-6, NUDOCS 8207260239 | |
| Download: ML20058C049 (12) | |
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y[s** "'%<k' g UNITED STATES NUCLEAR REGULATORY COMMISSION y )') g REGION 11
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y - C 101 MARIETT A ST.. N.W.. SUITE 3100 o, f[ ] - j
ATLANTA. GEORGI A 30303
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Report No. 50-416/82-40 Licensee: Mississippi Power and Light Company Jackson, MS Facility Name: Grand Gulf Docket No. 50-416 License No. CPPR-118 1/
f 2P f' L Inspectors:
u A. G. Wagner f
Date Si<fned
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't-Lt D. E. Scott gateAigned 4tly 6/ /b Approved by:_F. S. Cantrell, Sectijf hief, Division of Da'te Signed _
Project and Resident Programs SUMMARY Inspection on April 19 - May 14,1982 Areas Inspected This routine, announced inspection involved 183 inspector-hours on site in the areas of IE Bulletin follow-up, IE Circular follow-up, preoperational test witnessing, previous enforcement follow up, Inspector follow-up items, pre-operational test results review, control room operations, temporary alterations, plant tour and plant operations procedure review.
Results Of the nine areas inspected, no items of noncompliance or deviations were identified in eight areas; one item of noncompliance was found in one area (failure to follow procedure, paragraph 3).
8207260239 820714 PDR ADOCK 05000416 O
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DETAILS
I 1.
Persons Contacted Licensee Employees
- C. L. Stuart, Assistant Plant Manager
- J. W. Yelverton, Quality Assurance Manager j
- M. A. Lacey, Quality Assurance Supervisor
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C. R. Hutchinson, Startup Manager G. A. Johnson, Operations Superintendent R. G. Keeton, Shift Superintendent G. D. Lhamon, Shift Supervisor C. V. Hicks, Shift Supervisor
J. C. Roberts, Startup Supervisor
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Other licensee employees contacted included technicians and operators.
- Attended exit interview
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2.
Exit Interview The inspection scope and findings were summarized on May 14, 1982, with e
those persons indicated in paragraph 1 above. The licensee had no comments regarding the inspection findings.
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l 3.
Licensee Action on Previous Inspection Findings (Closed) Unresolved 416/82-13-01. Surveillance procedure 06-IC-1C71-R-0078
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i and attached TCN's were superceded by procedure 06-IC-1C71-R-1002. This i
procedure incorporated the requirements of the superceded procedure. There l
l are no further questions concerning this item. This item is closed.
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(Closed) Violation 416/82-18-01.
The inspector reviewed the changes delineating signature authority for plant management.
The changes meet
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current regulatory requirements.
However, utilizing these actions reduces the effectiveness of the review process and could allow the exercise of '
approval authority by an uninformed alternate.
(0 pen) Violation 416/81-56-03. The inspector was informed that this item is ready for closure. The inspector has not been provided with a list of review actions as stated in licensee memo for the resumption of testing.
This item remains open.
(0 pen) Violati;_ 416/82-13-02. The inspector was informed that this item is
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ready for closure.. The inspector requested copies of revised surveillance procedures conducted after changes were incorporated.
The inspector was informed that they were not available. This item remains open.
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(0 pen) Violation 416/81-56-02.
The inspector conducted a review of -the controls for temporary alterations.
This review was conducted to verify
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j compliance with plant administrative procedures 01-S-06-3, Control of System Alteration, Revision 6.
The review consisted of a verification that log
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i sheets were properly authorized, authorized tags were properly hung, tags
observed in the plant were properly authorized and alterations in the plant were properly authorized. Minor comments were discussed and resolved with on shift management. The following procedural violations were noted during
the plant walk through.
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a.
Four leads were lifted in panel H13-P871 in ESF logic division I for the Combustible Gas Control System.
b.
Logic Relay XK 808 was removed in panel H13-P877 in ESF logic division III for HPCS diesel generator system.
c.
A Test gage was connected across Rosemount Transmitter E12FTN007A for RHR ' A'.
I d.
Signal leads were disconnected from containment penetration system pressure transmitter 1R60PSN010 These alterations were not documented as required by paragraph 6.1 of Administrative Procedure 01-S-06-3.
This is a violation designated 416/82-40-01.
This is the fourth violation of the ter..po ra ry alteration requirements identified by the NRC staff in the last ten months.
The inspector reviewed the corrective actions to prevent recurrence and
supplemental actions taken by MP&L as described in their letter AECM 82-76
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of March 5, 1982.
These actions have been ineffective to prevent j
recurrence. Item 416/81-56-02 remains open.
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4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
IE Bulletin
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The licensee has submitted corrective actions in response to IE Bulletin
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80-06 to NRR for review.
The staff has completed their review without additional comments.
The inspector has held discussions with responsible licensee representatives, reviewed supporting documentation of the i
implementing work and test procedures. There are no further questions. IE
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Bulletin 80-06 is closed.
6.
Preoperational Test Procedure Witnessing Portions of preoperational test 1E71PT01 Integrated ECCS and LOP and special test 1E71SP01, Integrated ECCS and LOP Special Test, were observed.
The tests were observed for conformance -with Grand Gulf Startup Manual Chapter 5000 and 7000.
Minor comments concerning the tests were discussed with
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licensee representatives, i
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1 No violations or deviations were identified.
7.
IE Circular follow-up A review was conducted of 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 action. The following IE Circulars are closed.
80-22 81-05 81-04 81-07 b.
The licensee has not completed review and corrective actions for the following items.
80-11 81-13 81-14 8.
Licensee Identified Items (Closed) Item 416/CDR 81-45, "Transamerica Delaval Standby Diesel Generator" (10 CFR 50.55(e)). The final report was submitted on April 15, 1982. The report has been reviewed and determined to be acceptable.
The inspector held discussions with responsible licensee representatives, reviewed supporting documentation, and observed representative samples of work to verify that the corrective actions identified in the report have been completed.
(Closed) Item 416/CDR 81-48, " Incorrect cable terminations" Region II was informed of a potentially reportable deficiency (10 CFR 50.55(e)).
This item involved incorrect terminations of heater leads inside a breaker cabinet. The inspector reviewed a subsequent evaluation by the licensee which determined the item to be non-reportable.
(Closed) Item 416/CDR 81-52, " Nonconforming Safety Relif Valve Components."
Region II was informed of a
potentially reportable deficiency (10 CFR 50.55(e)).
This item involved non pressure retaining components which did not meet code requirements. The inspector reviewed a subsequent evaluation by the licensee which determined this item to be non-reportable.
(Closed) Item 416/CDR 82-02, " Defective Valve Springs" Region II was informed of a potentially reportable deficiency (10 CFR 50.55(e)).
This item involved Transamerica Delaval valve springs which were found to be defective at another facility.
The inspector reviewed a subsequent evaluation by the licensee which determined this item to be non-reportable.
(Closed) Item 416/CDR 82-03," Powerstrut and Superstrut Nut and Bolt Test Failures." Region II was informed of a potentially reportable deficiency
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I (10 CFR 50.55(e)).
This item involved testing failures of the nuts and bolts used in Powerstrut and Superstrut hangers at other facilities.
The inspector reviewed a subsequent evaluation by the licensee which determined the item to be non-reportable.
(Closed) Item 416/CDR 82-08," Unqualified M and T.E. Equipment." Region 11 was informed of a potentially reportable deficiency (10 CFR 50.55(e)). This item involved the use of unqualified M and T.E. by startop personnel. The inspector reviewed a subsequent evaluation by the licensee which determined the item to be non-reportable.
(Closed) Item 416/CDR 82-09,
" Loss of Penetration Closure Records."
Region II was informed of a
potentially reportable.. deficiency
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(10 CFR 50.22(e)). This item involved the loss by a subcontractor of the records involving closure of plant penetrations. The inspector reviewed a subsequent evaluation by the licensee which determined this item to-be non-reportable.
9.
Inspector Follow-up Items (Closed) Item 416/82-13-03. The maintenance procedure has been reviewed and revised to reflect the use of a Schaevity in place of the original Alphaline installed.
(Closed) Item 416/80-21-09. The design verification test has been included in preoperational test 1Z77PT01.
This test has been incorporJted by reference into the ECCS test. It will be performed with the ECCS test.
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(Closed) Item 416/81-18-01.
The SRC charter has been reworked.
The SRC will function as described in the Unit 1 technical specifications.
(Closed) Item 416/81-32-02.
This item was closed by inspection activities documented in inspection report 50-416/82-28. However, it was erroneously listed as 416/81-13-02 which is still open.
(Closed) Item 416/82-13-01. The TCN was incorporated into a revision of the'
procedure. There are no further questions. This item is closed.
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(0 pen) Item 416/81-32-03.
This item was brought to the' inspector for closure. Upon review of the procedure it was found that the procedure cover sheet still contained the LCO designation blocks. This item r.: mains open.
(Open) 416/82-13-04.
The licensee has responded to this NRC concern.by stating. "The use of af ter the fact TCN's which led up to this item has since been disallowed.
Currently all TCN's must have,two (2) opproval signatures prior to usage." This does not address the concern exprersed.
Major and minor TCN's are still allowed by the plant adrei ni striti ve procedure. It does not provide guidance consistant with ANSI 18.7.
Th i's item remains open.
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On May 6 the senior resident inspector met with the Senior V. P. Nuclear of MP&L. The meeting was to discuss the apparent lack of responsiveness to NRC open items, lack of depth and the need for operations support of QA's effort to close these items for fuel load.
It is the inspectors understanding that these items would be reviewed and appropriate action taken.
10.
Preoperational Test Results Review a.
The following completed preoperational test procedures were reviewed for conformance with Grand Gulf Startup Manual Chapters 5000, 7000, FSAR Chapter 14, Regulatory Guide 1.68 and licensee commitments.
(1) 1F11PT02 Horizontal Fuel Transfer System, approved April 2,1982.
(This includes tools and fixtures) Minor comments were resolved with licensee representatives.
(2) 1R21PT02 Load Shedding and Sequencing, approved March 22, 1982.
Minor comments were resolved with licensee representatives.
b.
The following completed preoperational and acceptance tests were reviewed for comformance with Grand Gulf Startup Manual Chapters 5000 and 7000.
(1) IC91AT01 Balance of Plant Computer, approved April 14, 1982 (2)
1L21 AT01 125/250 Volt DC System (BOP), approved February 26, 1982.
(3)
1L21AT02125 Volt Battery System, approved March 23, 1982.
(4) IN22AT02 Condensate Precoat Filter, approved April 22, 1982.
(5)
IN62AT01 Condenser Air Removal, approved March 2,1982.
(6) SN72AT01 Chlorination System, approved March 29, 1982.
(7)
1P43AT01 Turbine Building Cooling Water, approved March 3,1982.
(8) SP66AT01 Domestic Water, approved April 6,1982.
(9)
1R61PT01 Radio Communications, approved March 5,1982.
(10) 1R61PT02 Public Address, approved April 9,1982.
(11) 1T41AT01 Auxiliary Building Ventilation, approved March 3,1982.
(12) 1T42PT01 Fuel Handling Area Ventilation, approved March 29, 1982.
(13) SZ12AT01 Control Building Ventilation, approved March 2,1982.
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l 11.
Control Room Operations The. inspector observed the conduct of operations in the control room. The
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e observations were made to verify operator compliance with control room procedures. Conpliance with the following procedures was observed.
a.
05-S-01-4 Shift Relief and Turnover. Minor comments were discussed with licensee management.
i b.
02-5-01-2 Control and Use of Operations Section directives. There is
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currently no directive coordinator fulfilling the responsibilities described in the procedure and checklists are not being followed. This
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item is designated as open item 416/82-40-02.
It is the inspectors understanding that this item will be reviewed and appropriate corrective action taken.
c.
02-S-01-5 Shif t Logs and Records. Minor comments were discussed with licensee management.
i d.
01-S-06-4 Access and Conduct in Control Room. No comments.
e.
02-S-01-3 Responsibilities and Authorities of Operations Shift Personnel. No comments.
f.
02-S-01-0 Key Control. This procedure was not being used. It is the
inspectors understanding that the procedure is being revised.
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02-S-01-12 Station Operating Orders. No comments.
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12.
Plant Tours
The inspector toured portions of the control building. auxiliary building, containment and standby service water structure. The inspector observed the a
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following activities in progress:
hot work; housekeeping; equipment preservation; fi re equipment; clearances; maintenance; instrumentation; communications and equipment controls.
i No violations or deviations were identified within the areas inspected.
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13.
Plant Operations Procedure Review j
a.
A special inspection was conducted during the period of April 19-22 to assure the plant operating, off-normal event, emergency, and alarm
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response procedures are technically adequate for plant operation.
l To accomplish this inspection the procedures were reviewed to assure i
that procedure interface is adequate to provide continuity between i
procedures and that design criteria, as-built plant conditons, and
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personnel comments were utilized during procedure development. To this
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end the procedures were compared to the following criteria:
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General Electric Design Specifications and Design Specification Data Sheets;
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As built Process and Instrumentation Diagrams (P& ID's) and electrical schematics;
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Grand Gulf Nuclear Station (GGNS) Instrument Index;
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Quantity Tracking Sy; tem Valve Log, dated March 15, 1982;
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Facility Technical Specifications (TS's);
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System Plant Data Books;
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Fluid system and control panel walkdowns; and,
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Operator and plant personnel interviews.
The review encompassed the following procedures:
(1) Integrated Operating Instructions (I0I)
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101 03-1-01-1 Cold Shutdown to Generator carrying Minimum Load, Revision 10;
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101 03-1-01-2, Power Operations, Revision 10
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10I 03-1-01-4, Scram Recovery, Revision 10, (2) System Operating Instructions (SOI)
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S0I 04-1-01-B21-1, Nuclear Boiler, Revision 10;
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SOI 04-1-01-C71-1, Reactor Protection System, Revision 10; SOI 04-1-01-B33-1, Recirculation System, Revision 10;
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SOI 04-1-01-C11-2, Rod Control and Information System, l
Revision 10;
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SOI 04-1-01-C51-1, Neutron Monitoring, Revision 10;
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SOI 04-1-01-C11-1, Control Rod Drive Hydraulic System, Revision 10;
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SOI 04-1-01-C41-1, Standby Liquid Control System, Revision 10; and,
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S0I 04-1-01-L11-1, Plant D. C. Systems, Revi sion 10.
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(3) Of f-Normal Event Procedures (0NEP)
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05-1-02-I-1, Reactor Scram, Revision 10;
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05-1-02-III-2, Loss of One or Both RPS Buses, Revision 10;
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05-1-02-III-6 Automatic Isolations, Revision 10;
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05-1-02-I-3, Single MSIV Closure, Revision 10;
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05-1-02-I-2, Turbine and Generator Trips, Revision 10;
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05-1-02-I-4, Loss of Of fsite Power, Revision 10;
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05-1-02-IV-1, Control Rod / Drive Malfunctions, Revision 10;
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05-1-02-IV-6, Loss of RPIS, Revision 10;
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05-1-02-I-5, Resin Intrusion into the Reactor Vessel,
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Revision 10, (4) Alarm Response Instructions ( ARI)
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ARI 04-1-02-1H13-P601, Panel No.1H13-P601, Revision 10.
b.
This review identified the following items:
(1) The licensee still has preliminary Technical Specifications (TS's).
The final Technical Specifications will be issued with the issuance of the Operating License (OL). As a result the TS are still subject to change which affects procedure references and operating limits. There are instances in all of the procecures where a reference or limit is not consistent with the TS. With issuance of the final TS, a procedure review will be conducted to insure consistency with the TS.
(2)
IDI 03-1-01-1 directs operators to withdraw control rods, Intermediate Range Monitors (IRM), and Source Range Monitors (SRM), however, this 101 does not direct the operators to follow the detailed procedure for these operations in the respective 501's.
This appears to be an isolated case since in all other procedures reviewed, the operator is referred to the specific SOI.
The 101's need to be reviewed to ensure there are no similar instances in other procedures.
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(3) The procedures have some miscellaneous typographical and editorial errors. The typographical errors resulted in incorrect procedure references, unclear directions, and missing initial / dating blanks.
Editorial errors resulted in steps that directed operations that
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were already completed by previous steps (and in some cases were directed to be performed in a manner that was different than previous direction) and resulted in incorrect indenting of procedural paragraphs.
l These~ types of errors can be of a minor nature and may not affect procedure adequacy.
However, when these errors can result in 4'
operator confusion, they need to be resolved.
The licensee apparently has not been proof reading procedures after typing.
The licensee will review procedures to identify and correct such errors.
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(4) Control switch designations identified in procedures to direct i
operations may not reflect actual control board nomenclature.
While this does not appear to be an extensive problem, there are
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j instances where such descrepancies could contribute to operator
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confusion (e.g., in one case a switch's identifying number applies to one valve while the same switch's identifying discription i
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applied to a different valve).
The licensee is still changing some control board / panel switch labeling to meet human factors studies and some of these changes have not been incorporated into procedures.
The licensee will
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i devise a method to assure that further changes are incorporated into procedures.
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j (5) The accuracy of the valve lineups (VLU's) and switch lineups (SLU's) in the 501's appears to be the major problem identified i
during this review. The VLU's and SLU's had errors that included:
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Valves and/or switches lef t off the list;
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Confusing instrument root valve designations; and,
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Missing pressure point (PP) root valves and pipe caps.
In addition the review found that the instrument and PP root
valves were not shown on the P & ID's.
The licensee utilizes a
" Quantity Tracking System Valve Log" produced by the architect-engineer ( AE) to identify valves and develop the VLU's.
This log was found to have numerous omissions that probably contributed to the errors in the VLU's.
The licensee will revise VLU's. SLU's and P & ID's to include root
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valves and other missing items.
These revisions will be i
accomplished by conducting system walkdowns to insure accuracy.
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(6) Review of various procedures, especially the ARL's indicate a weakness in the ability of the licensee to control the issuance, distribution, and updating of controlled documents. The licensee will develop and implement a procedure to control this documentation.
(7) Walkdown of the selected systems indicate a number of missing valve identification tags. Proper identification of system valve is especially important in a new plant and will minimize operator errors.
The licensee will institute a program to identify and replace missing valve identification tags.
(8) The ARI's appears to be adequate in format and content however there were numerous instances where the annunciator descriptions (window labeling) and functions were incorrect. The licensee must audit the annunciator labeling and functions against design documentation to insure accuracy.
(9) The licensee controls instrument valve (i.e., valves downstream of the instrument root valves) by use of the surveillance test procedures (STP's). The STP's insure proper valve verification on the return-to-normal VLU.
While this method of controlling instrument valves is effective, there may be some time between the completion of an STP and the starting of a system's operations.
Based upon numerous inadvertent instrument isolation events and incorrect lineup events that have occurred at other facilities, the inspector stated that a master instrument VLU should be developed to insure correct instrument VLU's prior to a system's operations.
The licensee will develop a master instrument VLU for each system to verify correct VLU prior to system operation.
C.
The licensee has committed to revise procedures and drawings to correct the discrepancies identified during the inspection. To accomplish the commitment, the licensee will supply a listing to the NRC of the systems required for each startup phase.
This listing will identify the applicable 10l's, 501's, ONEP's, and ARI's required for each phase.
The licensee will revise all procedures required for each phase in accordance with the findings identified in paragraphs B(1), B(2), B(3),
B(4), B(6), B(7), and B(8).
Open Item (416/82-40-03): Revise 101's, 501's, and ONEP's, and ARI's prior to use of these procedures in a startup phase.
The licensee will also develop and implement 6 document control procedure prior to fuel load.
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Open Item (416/82-40-04):
Develop and implement a document control procedure.
At the time of this exit, the licensee had not decided how to implement the master instrument VLU. This may be done on a per system basis or may be done on a single lineup that includes all safety related instrument valves.
In either case the master instrument VLU will be developed and implemented prior to utilizing specific instrumentation for system operation.
Open item (416/82-40-05): Develop and implement a master instrument valve lineup.