IR 05000416/1986037

Insp Rept 50-416/86-37 on 861018-1114.Violation Noted: Failure to Follow or Provide Adequate Procedures Appropriate to Current Refueling Outage

ML20215F568
Person / Time
Site:	Grand Gulf
Issue date:	12/10/1986
From:	Butcher R, Dance H, Will Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215F548	List: IR 05000416/1986037 ML20215F546 ML20215F557
References
50-416-86-37, NUDOCS 8612230455
Download: ML20215F568 (16)

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UNITE'3 STATES

[Sn REroq'o NUCLEAR REGULATORY COMMISSION

[ ~, REGION 11 g j 101 MARIETTA STREET, * 2 ATLANTA, GEORGI A 30323

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Report-No.: 50-416/86-37 Licensee: Mississippi Power and Light Company Jackson, MS 39205 Docket No.: 50-416 License No.: NPF-29 Facility Name: Grand Gulf Nuclear Station Inspection Conducted: October 18 - November 14, 1986 Inspec ors:

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Butcher, Senior g sident Inspector

/2 ev 14 Date Signed

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" W. F. Smith, Residen p itor ALQn - nl~fa Date Signed Approved,by:_ L c., M H. C. Dance, Siection Chief is /o b Date Signed Division of Reactor Projects f

SUMMARY Scope: This routine inspection was conducted by tne resident inspectors at the site in the areas of Licensee Action on Previous Enforcement Matters, Operational Safety Verification, Maintenance Observation, Surveillance Observa-tion, Reportable Occurrences, Operating Reactor Events, Inspector Followup and Unresolved Items, Design, Design Changes and Facility Modifications, Refueling Activities, and Cold Weather Preparation Results: One violation was identified with five examples where the licensee failed to follow procedures or failed to provide adequate procedures (paragraph 9).

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k REPORT DETAILS Licensee Employees Contacted J. E. Cross, GGNS Site Director

• C. R. Hutchinson, GGNS General Manager R. F. Rogers, Manager, Unit 1 Projects

• A. S. McCurdy, Manager, Plant Operations

• F. W. Titus, Director, Nuclear Plant Engineering J. D. Bailey, Compliance Coordinator

• J. Wright, Manager, Plant Support

• L. F. Daughtery, Compliance Superintendent D. G. Cupstid, Start-up Supervisor R. H. McAnulty, Electrical Superintendent R. V. Moonaw, Manager, Plant Maintenance W. P. Harris, Compliance Coordinator J. L. Robertson, Licensing Superintendent L. G. Temple, I&C Superintendent J. H. Mueller, Mechanical Superintendent

• L. B. Moulder, Operations Superintendent J. V. Parrish, Chemistry / Radiation Control Superintendent M. Wagner, Training Instructor

• W. F. Maskburn, Civil Engineer, Nuclear Plant Engineering

• D. W. Stonestreet, Manager, Plant Modifications & Construction Contractor Personnel Contacted G. E. Pierce, General Electric Resident Manager Other licensee employees contacted included technicians, operators, security force members, and office personne * Attended exit interview Exit Interview The inspection scope and findings were summarized on November 14, 1986, with those persons indicated in paragraph I abov The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio The licensee had no comment on the following inspection findings:

416/86-37-01, Violation - Failure to provide adequate control of work activities resulting in several significant incidents (paragraph 9).

416/86-37-02, Unresolved Item - Evaluation of environmental acceptability of improperly installed Raychem heat shrink seals (paragraph 10).

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416/86-37-03, Inspector Followup Item (IFI) - Routine followup on a General Electric Service Information Letter regarding the possible installation of negative voltage sensing relays in the Intermediate Range Monitors (paragraph 10).

416/86-37-04, IFI - Tracking of FSAR changes resulting from design changes (paragraph 11).

416/86-37-05, IFI - Tracking of containment pressure instrument test to completion (paragraph 12).

3. Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 416/83-25-02. The License Commitment Tracking System (LCTS) implemented by Action Item 4.1.4 of the licensee's operations enhancement program was to meet a management objective to install a single, comprehensive system capable of tracking all commitments made to the NR The system failed to alert management of the commitments made in two letters to the NRC (AECM 83/0013 and AECM 83/0092), and thus they were not completed as described in the letter Failure to meet these commitments was identified by Deviation 416/83-25-01, which has since been corrected and closed by NRC Inspection Report 416/84-16. The resident inspectors reviewed the current LCTS and confirmed that a sampling of commitments selected at random are being tracked. Thus it appears that the licensee's tracking system for commitments made to the NRC is active and complete. There is a notification system in place to ensure commitments are not missed. Section 5.6.1.a.(3) of Nuclear Licensing and Safety Administrative Procedure 2.7, Revision 1, License Commitment Tracking System (LCTS), requires a monthly report which notifies actionees of commitments that are approaching the due-date. The licensee's representative produced the last report (dated October 3, 1986) which identified commitments due between October 3, 1986 and November 15, 198 These notices appear to be an effective tool to ensure commitments are met on schedul Site compliance personnel have developed an easily accessible, redundant database dedicated to NRC inspection report findings to aid in tracking the correction of inspection report issue In addition, the inspectors noted a personal dedication on the part of site compliance personnel to not allow another commitment go beyond the due-date without the appropriate management actions. Nuclear Licensing and Safety personnel at MP&L Corporate Headquarters have also developed an administrative procedure and database that is dedicated to the control of Licensee Event Reports (LERs) and special reports. These receive a corporate level of management attention; however, specific actions are still incorporated into the LCTS database for tracking. The inspectors are satisfied that the licensee has adequate controls in place to assure the timely completion of commitments to the NRC; therefore, this item is close *

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3 Unresolved Items *

One new unresolved item identified during this inspection is discussed in paragraph 10, Operational Safety Verification (71707)

The inspectors kept themselves informed on a daily basis of the overall plant status and any significant safety matters related to plant operation Daily discussions were held with plant management and various members of the plant operating staf The inspectors made frequent visits to the cortrol room such that it was visited at least daily when an in-aector was on site. Observations included instrument readings, setpoints and recordings, status of operating systems, tags and clearances on equipment controls and switches, annunciator alarms, adherence to limiting conditions for operation, temporary alterations in effect, daily journals and data sheet entries, control room manning, and access controls. This inspection activity included numerous informal discussions with operators and their supervisor Weekly, when the. inspectors were onsite, selected Engineered Safety Feature (ESF) systems were confirmed operable. The confirmation is made by verifying the following: accessible valve flow path alignment, power supply breaker and fuse status, major component leakage, lubrication, cooling and general condition, and instrumentatio General plant tours were conducted on at least a biweekly basis. Portions of the control building, turbine building, auxiliary building and outside areas were visited. Observations included safety related tagout verifi-cations, shift turnover, sampling program, housekeeping and general plant conditions, fire protection equipment, control of activities in progress, radiation protection controls, physical security, problem identification systems, and containment isolatio No violations or deviations were identified. Maintenance Observation (62703)

During the report period, the inspectors observed portions of the maintenance activities listed below. The observations included a review of the work documents for adequacy, adherence to procedure, proper tagouts, adherence to technical specifications, radiological controls, observation of all or part of the actual work and/or retesting in progress, specified retest requirements, and adherence to the appropriate quality control *An unresolved Item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviatio ..

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MWO hC4996, Disassembly and reassembly of Standby Diesel Generator 12 for Design Review / Quality Revalidation (DR/QR) inspection MW0s E67276, and M67591, Rework and replacement of RHR valve E12-F03 MWO INC842, 47-Month replacement of NAMCO Limit Switches on containment cooling valve M41-F01 MWO E67455, Rework Raychem seals in penetration 1Z00 MWO M58857, Repair of Control Rod Hydraulic System valve C11-F06 On October 22, 1986, when the inspectors arrived at the jobsite in the containment, valve C11-F067 was found with the bonnet removed, the valve body open to the atmosphere, and water leaking out on the floo The valve was unattended, and thus the system was not protected from foreign materia The MWO contained a cleanliness checklist which required foreign material control, as required by Plant Administrative Procedure (AP) 01-S-07-13, Revision 6, Cleaning Processes. Licensee contract personnel explained that a black plastic trash bag was supposed to have been taped over the valve to protect the opening and collect leakage, and that the weight of collected water probably pulled the bag down. Use of only this black plastic material for covering the system opening is prohibited by Paragraph 6.3.3 of the above procedure which requires a stiff disc, larger than the pipe inside diameter, to protect the plastic material from puncture or from being drawn into the system. Although valve C11-F067 is not safety-related, it is in the path of water that is routed during normal operation through the control rod drive mechanism to the reactor vessel, via the solenoid operated stabilizing valve IE Information Notice No. 86-89 was issued on October 16, 1986, addressing an uncontrolled rod withdrawal because of a single failure at Grand Gul In that report, the licensee concluded that temporary particulate accumulation on solenoid operated directional control valve 422 caused an incomplete closure of the valve, thereby allowing drive water pressure to leak past the valve and force the control rod drive piston downward af ter a withdraw command was terminate The NRC inspectors expressed concern that failure to implement adequate cleanliness controls such as described above could lead to similar future losses of control on safety related equipmen No violations or deviations were identified. Surveillance Observation (61726)

The inspectors observed the performance of portions of the surveillances listed below. The observation included a review of the procedure for technical adequacy, conformance to technical specifications, verification of test instrument calibration, observation of all or part of the actual surveillances, removal from service and return to service of the system or components affected, and review of the data for acceptability based upon the acceptance criteri . _ _ . *

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06-0P-1P81-R-0001, Rev. 23, High Pressure Core Spray Diesel Generator 18 Month Functional Tes IC-1821-R-0002, Rev. 24, Reactor Vessel Water Level Low /High

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Channel C Calibratio ME-1M10-R-0003, Rev. 24, Drywell Bypass Leakage Rat , Rev. 0, ADS Air System Drop Tes ;

No violations or deviations were identifie . Reportable Occurrences (90712 & 92700)

The below listed event reports were reviewed to determine if the information provided met the NRC reporting requirements. The determination included

adequacy of event description and corrective action taken or planned, i existence of potential generic problems and the relative safety significance 1 of each event. Additional inplant reviews and discussions with plant

. personnel as appropriate were conducted for the reports indicated by an

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asterisk. The event reports were reviewed using the guidance of the general policy and procedure for NRC enforcement action The following License Event Reports (LERs) are close LER N Event Date Event

• 86-016 April 17, 1986 Procedural error caused missed isolation time measurement

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i during surveillance.

i i *86-018 May 13, 1986 Technical Specification required i sample for Main Condenser offgas hydrogen was not taken.

I *86-024 July 6, 1986 Surveillance on drywell outer

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air lock door seal performed

late due to personnel erro (Closed) 10 CFR Part 21, P2184-06, (NEC 85/06) Fuel control levers on

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emergency Diesel Generators (DG) 11 and 12 may not be pinned in place. The licensee implemented MW0s M55861 and M55862 to install roll pins in the fuel

- control levers. The inspectors subsequently verified the pins were in place f by visual inspection and reviewed the completed documentation. This item is I closed.

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(Closed) 10 CFR Part 21, P2185-05, (NEC 85/21) Failure of a crankshaf t !

l lubricating oil plug on a Transamerica Delaval diesel generato The licensee issued MW0s M53171 and M53172 to inspect the crankshafts of DGs 11 i j and 12 to verify that the thinner 22 gauge plugs subject to failure do not i

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exist at GGNS, and that the heavier,16 gauge plugs are installed. The inspectors physically inspected a sampling of visible plugs and verified

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that the heavier plugs were installed, and reviewed completed documentation d

with satisfactory result This item is close No violations or deviations were identified.

j Operating Reactor Events (93702)

The inspectors reviewed activities associated with the below listed reactor

events. The review included determination of cause, safety significance, l performance of personnel and systems, and corrective action. The inspectors examined instrument recordings, computer printouts, operations journal entries, scram reports and had discussions with operations, maintenance and engineering support personnel as appropriate.

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Throughout this first refueling outage there were incidents, all of which were documented by licensee Incident Reports (irs), where the impact of

system and/or component clearances for authorized work was not realized or i understood enough to prevent unexpected results. The probability of such ,

2 incidents had been increased due to the large number of design changes, maintenance and repairs scheduled for this outage. While the safety significance of these incidents was mitigated by the fact that the plant had been shutdown since September 6, 1986, the inspectors expressed concern that failure to prevent such repeated incidents could be a precursor to more i serious events, particularly after start up and return to powe The following licensee identified events were reviewed using the guidance of the i

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general policy and procedure for NRC enforcement actions and no violations will be issued:

i On October 16, 1986 during performance of work authorized by DCP 83/5021,

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the Division 1 and 4 trip system was placed in an inoperable status, which  !

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required entering a 12-hour Licensee Condition of Operation (LCO) action '

j statement; however, this was not done and it was not discovered until

! several days later by the licensee.

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On October 21, 1986, a Technical Specification (TS) LCO report was

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discovered to be expired by eleven days. On September 9,1986 an LCO was written to document Standby Gas Treatment System (SGTS) Train A noble gas monitor inoperable. TS 3.3.7.12 action statement allowed effluent release 4 via this path for up to 30 days if 4-hour grab samples were taken. The  ;

l effluent releases continued intermittently beyond the 30 day limit to 41 -

days (about 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of release time af ter 30 days) before being identified j and corrected by the licensee.

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{ TS 4.4.4.c.2 requires, when the continuous recording conductivity monitor

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is inoperable, obtaining an in-line conductivity measurement at least once I per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the existing plant condition Contrary to this, on  ;

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l October 27, 1986 it was discovered that Reactor Water Clean-up (RWCU)

' influent conductivity samples were taken from a tagged, isolated sample line j i for three days until the fourth day when the line finally drained out. Upon <

l questioning the operators, the chemist found that no representative sample  !

j had been drawn for three days, i _-_____ __ - _ _ - _ - _ _

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On October 27, 1986 the licensee determined that two surveillances were not completed prior to the " late date" of October 26, 1986. One of the surveillances (06-0P-1R20-W-0001) was an AC and DC weekly lineup required by TS 4.8.1.2 to be current in support of core alterations. Core alterations were suspended until the surveillance was accomplished. The other

, surveillance, a weekly verification of -locked fire rated doors, was also

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completed promptly.

. The following licensee identified events were reviewed using the guidance of the general policy and procedure for NRC enforcement actions and due to the previous similar violations issued (86-32), a violation in this area will be I assessed against failure to follow procedures or failure to establish adequate procedures:

3 On October 15, 1986, a clearance for a Division 2 electrical outage did not recognize system conditions existing at the time or specify the necessary

tagout sequence to preclude an inadvertent Engineered Safety Feature (ESF)

i actuation. When the tagout was implemented, an inadvertent initiation of j the Standby Gas Treatment System and Control Room Standby Fresh Air System

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? On October 17, 1986, inadequate work instructions in support of Maintenance

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Work Order (MWO) p57626 resulted in an inadvertent ESF actuation. When l 1 power was restored to Bus 16AB af ter work ccmoletion, an inadvertent

Divisten 2 isolation signal was generated, closing shutdown cooling

isolation valve E12-F00 On October 18, 1986, prerequisite plant conditions were not established as

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, required by step 4.4 of surveillance procedure 06-ME-1821-R-0008, MSRV  ;

Operability Test, which required air to the Main Steam Relief Valve (MSRV)  ;

solenoids to be depressurized. This resulted in MSRV 021-F041C being inadvertently stroked dry during the solenoid operability test (Click Test) prescribed in step 5.10 of the procedur ;

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On November 6,1986, inadequate work instructions accompanying MWO E64279 l

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resulted in an inadvertent ESF actuation. While replacing an Agastat relay,  ;

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drywe',1 purge compressor A inadvertently starte j

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Technical Specification (TS) 6.8.1 requires that the applicable procedures

! recommended in Appendix A of Regulatory Guide (RG) 1.33 be estabitshed, l

implemented and maintaine Appendix A of RG 1.33 states that the >

performance of maintenance should be covered by written procedures i

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Contrary to TS 6.8.1, the licensee as described above failed to follow procedures or failed to provide adequate procedure This is violation 416/86-37-01.

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NRC Inspection Report 416/86-32 cited violation 416/86-32-04 where in two i i instances the licensee failed to provide adequate, documented procedures as i required by TS 6.8.1. In both cases, an inadvertent actuation of an ESF :

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inadvertently actuated, due to failure to follow procedures, or inadequate

{ procedures which failed to prevent the actuation ,

Licensee management recognized the apparent adverse trend of the number of incidents occurring during the outage at approximately the same time the inspectors were becoming concerned, and began to take actions to control

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the amount of work processed through the control room. The inspectors J

discussed these concerns with management, and management indicated that i efforts were already underway to explore additional and more effective actions to keep these incidents under control. As the outage progressed, i the number of incidents decreased sharply, an apparent result of reduced :

control room activity as mandated by management, and as operators became !

more discriminating as to what activities would be permitted to occur concurrently. Licensee management is presently developing additional means

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to eliminate these types of incident ;

i The large amount of maintenance, design modifications, surveillance and l

, retests complicated the required efforts to maintain adequate control over

, plant conditio While it is understood that licensee management took l

decisive action and is presently developing additional means to eliminate l the above types of incidents, corrective actions shall be documented and implemented in response to this violatio l The resident inspectors Fave been monitoring licensee activities related to ;

i the correction of Standby Service Water (SSW) system deficiencies which were previously identified in NRC Inspection Reports 416/86-26, and 416/86-3 Briefly, on August 27, 1986, while the plant was in hot shutdown (operating j condition 3), the licensee identified errors made in the calculation of SSW l flow to ESF switchgear room coolers which resulted in less than the design j requirements. This led to the discovery of piping and cooler fouling in i those areas jointly served by Plant Service Water. While conducting piping design reviews for improved flow, it was discovered that a seismic qualift-cation deficiency existed on four ESF equipment room cooler inlet and outlet

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l nozzles. Through detailed engineering design reviews, system cleaning, i cooler cleaning, and previously scheduled SSW System improvements, the .

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end of this reporting period:  ;

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! SSW Train A i l l J The Reactor Core Isolation Cooling (RCIC) pump room cooler appears to have ;

j undersized piping for the length installed, thus insuf ficient flow exist t

, The licensee is replacing the 3/4 inch pipe size with 1-1/2 inc i

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The control room air conditioning unit condensers, af ter a design review, l l have mar inally adequate flw. The licensee is cleaning the piping (by use

I of Hydro azing) to improve the margi l l

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The ESF Equipment room cooler located at level 119 feet West has had some piping replaced; however, flow is marginally acceptable and the licensee is evaluating alternative corrective actio SSW Train B At present, only the ESF Equipment room cooler located at level 139 feet East has marginally acceptable flow. The licensee is completing a design review to verify that further actions need not be take The licensee has committed to keep the NRC staff informed of interim and final resolutions related to all SSW problem This is already being tracked under Unresolved Item 416/86-32-0 NRC Inspection Report 416/86-36 dated November 13, 1986, contains additional inspection results related to SSW System problems on flow, piping corrosion, and maintenanc . Inspector Followup and Unresolved Items (92701)

(Closed) IE Information Notice (IEN) 86-53. On July 7, 1986, MP&L received IEN 86-53, dated June 26, 1986. The IEN was published to alert licensees to a potentially generic safety problem involving improper installation of heat shrinkable tubing supplied by Raychem over electrical splices and termination At several plants, potential failures and in some cases actual damage existed due to improper installation, or application under circumstances that were outside of the configuration presumed by the Raychem design. Just prior to arrival of the IEN, the Architect / Engineer, Bechtel Corporation, notified MP&L on June 20, 1986, that this problem may apply to GGNS Unit 1, because for example, GGNS design and installation documents specified a 1-inch minimum seal length while Raychem required a 2-inch seal length. At the time, the plant was at power, so Nuclear Plant Engineering (NPE) conducted a field walkdown to verify proper installation on a limited sample basis, i.e., outside containment on nuclear environment interface seals only. The results were that all had a 2-inch overlap, and thus for the time being, NPE concluded there was no cause for concern. Subsequently, during this refueling outage, NPE conducted their routine 10 CFR 50.49 walkdown inside the containment, and found applications where the Raychem seals were improperly installed. In most cases thera was insufficient seal length (less than 2 inches on each end) and in others full seal length adhesion was not achieved, or cable conductor splice diameters exceeded the use range of the particular Raychem seal applied. On October 15, 1986, Material Nonconformance Report (MNCR) 0954-86 was initiated to identify the deficiencies. A 100". inspection was conducted, and as a result, of the 315 total splice locations, some were in compliance with Raychem requirements, some were adequate based on documented Wylie Laboratory reports on similar configurations, and 58 were not in compliance with Raychem requirements nor were there any documented test reports that would support the adequacy of the installations. The licensee is attempting to obtain supporting test reports for the remaining 58 configurations; however, they have taken the

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! conservative approach and have replaced all 58 seals prior to startup to preclude the possibility of any of these 58 seals impacting startup for lack of supporting test reports. TFe inspectors witnessed a sampling of this work. This action closed IEN 86-53; however, the licensee has not completed evaluating the environmental acceptability of the previous installation This shall be unresolved iter 416/86-37-0 (Closed) IE Information Natice 84-22, (licensee potentially reportable deficiency 84-09) Deficiency in Comsip, Inc., standard bed catalys Comsip, Inc., issued a 10 CFR 21 report indicating that catalyst supplied prior to April 1983 used in the Comsip Model K-111 containment gas monitoring system, was subject to degradation due to fission fragment iodine which may be present in the containment atmosphere during a loss of coolant accident involving core damage. This in turn would desensitize the monitor causing it to progressively provide less than actual hydrogen concentration indications. In a Potentially Reportable Deficiency (PRD) report to the NRC dated August 26, 1983, the licensee identified the problem in response to the 10 CFR 21 report, and committed to complete replacement of the catalyst beds on GGNS Unit 1 on or before December 31, 1983. The NRC inspectors reviewed documentation and had discussions with licensee maintenance personnel and found that the catalyst beds had been replaced several times with beds supplied after April 1983. This issue is close (0 pen) Resident follawup action on General Electric (GE) Service Information Letter (SIL) 445 entitled, Intermediate Range Monitor (IRM) Fuse Failure, dated July 26, 1986. The SIL reported that during an outage at an operating GE/8WR, all positive and negative IRM 3/4 Amp fuses (F1 and F2) connected to the 24 vde bus B were blown because of a power surge resulting from a switching transient on the 480V power supply. Af ter the positive 3/4 Amp fuses (F1) were replaced, all inoperative IRM channels appeared to be operating normally. However, because of continued loss of the negative power supply, for which there was no indication on control room panels, the IRM channels were inoperable and unable to process flux signals. If this condition had remained undetected, the IRM-initiated alarms and scram may not have occurred if needed during restart of the plan The blown negative-side fuses were detected later during subsequent IRM surveillance testing prior to restarting the plant. The purposes of the SIL were, for GGNS, to recommend the reevaluation of procedures pertaining to replacement of blown fuses and restoration of inoperative safety related channels; and modification, if desired, of SRM/IRM system designs to add negative voltage sensing relays to each channe The inspectors discussed the SIL with the licensee to determine if either of the actions recommended by GE were implemented. The licensee considered the GGNS procedures to be adequate, because weekly and pre-startup surveillances will perform the necessary operational test. Having been made aware of the '

S!L, maintenance instrumentation and control engineering specifies an operational retest after corrective maintenance which will preclude the above incident from occurring at GGN ,

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At the present time, the licensee is evaluating whether or not negative

, voltage sensing relays should be added to each channel. The IRMs at GGNS would go downscale if the negative voltage was lost, and a rod block andunciator would alarm. .It appears that this would be sufficient notifi-

' cation of _ this: problem if it should occur in the middle of a startup; '

- however, the licensee has not reached a decision as of the end of this reporting period. Resolution of this issue shall be tracked as Inspector Followup Item 416/86-37-0 (Closed) Inspector Followup Itea 416/86-32-10, additional followup of closeo6t. on De:ign Change Package (DCP) 82/0543, License Condition (LC)

2.C.(25)(a). 'The inspectors reviewed the completed DCP records and verified that all documentation required for signoff in support of satisfactory completion of this DCP was in order. This DCP was implemented to satisfy LC 2.C.(25)(a), which states that prior to startup following the first refueling outage, a heavy duty turbocharger gear drive assembly shall be installed on all EMD diesel generators. The Division 3, High Pressure Core Spray diesel generator is the only EMD unit at GGNS. This LC is considered I satisfied by the resident inspectors, based on witnessing, in part, the installation work, retesting and the review of final documentaticn. This item is close (0 pan) Inspector Followup Item 416/86-28-01, DCP 81/5018, Installation of Triaxial Accelerometer When inspecting the installation of the additional Strong Motion Accelerometer (SMA) being installed to satisfy LC 2.C.(7) the inspector questioned the orientation of the SMA. The SMA, p/n SC85-XE-N012

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and Kinemetrics model FBA-3, is shown in DCP 81/5018 on drawing J-0129G which references Specification 9645-J-701.0, Instrument Installation Requirements. Paragraph 6.8.3 of this specification requires triaxial instruments, which are not mounted directly on equipment, to be oriented

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so that one horizontal axis is parallel to the major horizontal axis assumed in the plant design. This alignment shall be within one degree to ensure correct interpretation of the data. The licensee personnel installing the SMA had ne' directions on how to align the SMA horizontal axis parallel to a

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plant horizontal axi Licensee technicians that calibrate the SMAs use Surveillance Procedure 06-IC-SC85-0-1003, Forced Balance Strong Motion Accelerometer Calibration, for guidance. Paragraph 5.42 of the surveillance procedure states to install the SMA in the field and to complete the hardware restoration section of Data Sheet I Paragraph 5.43 states to record the orientation of the SMA plug relative to building North on Data Sheet II. This record of orientation is for a relatively crude representa-tion of the orientation of the SMA. With no directions or provisions for orienting the SMA horizontal axis with a plant horizontal axis, the technicians reinstall the SMA such that the plant electrical lead will mate with the SMA plug. The orientation is not held to within one degree as required by Specification 9645-J-70 l

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The licensee has issued a change notice to DCP 81/5018 to clarify the installation for axis orientation of SC85-XE-N012. There are five other SMAs previously installed as required by TS 3.3.7.2, which have the same orientation problem following calibration as SC85-XE-N012. Technical Specification 6.8.1 requires written procedures be established, implemented and maintained covering the surveillance activities of safety related equipment. Specification 9645-J-701.0 requires triaxial instruments to be oriented so that one horizontal axis is parallel to a major horizontal axis assumed in the plant design and that this alignment shall be within one degre Contra ry to this requirement the Surveillance Procedure 06-IC-SC85-0-1003 is inadequate in that reinstallation instructions are not adequate to insure SMA alignment within one degree. This will be the fifth example of Violation 416/86-37-0 (Closed) Inspector Followup Item 416/86-32-07, additional followup of DCP 85/3100. The inspectors reviewed the Design Change Implementation Package (DCIP) for completeness. The post modification testing was accomplished and was adequate to demonstrate operability. Training and procedure changes were addressed as not required for this change. No control room drawings were affected by this chang The Plant Safety Review Committee had reviewed and approved the DCIP. The number of eight hour emergency lighting units was also addressed during a fire protection inspection conducted by Region II inspectors and is carried as IFI 416/85-16-04 which is still ope (Closed) Inspector Followup Item 416/86-32-11, additional followup on DCP 84/4080-1, modifications to SSW Basin A pipe supports as a result of soil structure interaction analysis. The inspectors reviewed the closed DCIP for completenes There were no requirements for changes to operating, surveillance or maintenance procedure (0 pen) Inspector Followup Item 416/86-32-13, additional followup on DCP 84/3029. The inspectors continued to monitor portions of the instaliation work and retesting of diesel generator (DG) 12 (Division 2) generator ground overcurrent relays. On October 13,1986, DG 12 work was completed and the unit was successfully operate This item remains open pending witnessing of further test and review of DCP closecut documentation and procedure changes.

l (0 pen) Inspector Followup Item 416/86-32-14, additional followup of DCP 84/5007, modifications to the scram discharge volume vents, drains, and level instrumentation. The inspectors continued to monitor work and testing

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related to this DCP. This item remains open pending review of DCP closeout documentation, procedure changes and drawing change . Design, Design Changes and Facility Modifications (37700 & 37701)

The inspectors have been conducting document reviews and hardware l inspections to ascertain that design changes and facility modifications

! associated with Technical Specification (TS) License Conditions were in l

conformance with the requirements of the facility license, TS, and 10 CFR l

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50.5 Reviews conducted during the previous reporting period are documented in NRC Inspection Report 416/86-32, and are being tracked as-Inspector followup Item Those reviews that were continued and/or completed during this reporting period are documented in paragraph 9 abov The following additional DCPs were reviewed during this reporting perio DCP 84/4062, LC 2.C.(15) (partial): Installation of protective silicone rubber tubing on the leadwires of the Scram Discharge Volume Isolation Pilot Solenoid Valves. The inspectors have reviewed the implementing documentation and portions of the work and retesting. The completed DCIP was reviewed for completeness. There were no requirements for changes to operating, surveillance or maintenance procedures, nor was there any need identified for an FSAR change. This DCP is complete and as such partially satisfies LC 2.C.(15) pending completion of DCP 81/5007 which is being tracked under IFI 416/86-32-1 DCP 85/3040, .LC 2.C.(37) (a) and (b): This design change added a second level undervoltage (sustained, degraded voltage) protection and automatic test mode override to the HPCS diesel generator switchgear and control panel. The inspectors witnessed portions of the work and the retesting, and reviewed the completed, signed off DCIP. There were TS changes, electrical schematic drawing changes, operating and surveillance procedure changes, and FSAR changes involved. All were specifically checked by the inspectors for change implementation with satisfactory results. The FSAR change, however, was limited to an advance change request, thus the adequacy of the actual FSAR revision shall be tracked for future inspection by IFI 416/86-37-05 described belo Thus LCs 2.C.(37)(a) and (b) are considered satisfie The inspectors noted that most of the DCPs reviewed involved changes to the FSA Since FSAR updates occur on an annual basis, it was impractical to

"ete.rmine if the update from each DCP reviewed was adequate. Therefore, FSAR updates will be reviewed separately after they are issued, and shall be tracked under one Inspector Followup Item (416/86-37-04).

Operator Training:

The inspectors conducted an evaluation of the effectiveness of licensed operator training through attendance of Emergency Procedure (EP) and Safety Parameter Display System (SPDS) training. The objectives of this inspection i was to attend training lectures, witness simulator operation, and verify l that the technical content of information presented was adequate.

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The inspectors reviewed System Operating Instruction 04-1-01-C93-1, Revision 0, Safety Parameter Display System and attended at least half of the lecture sessions given on the new flow-charted EPs and noted that an j adequately detailed work session was conducted on each EP with appropriate l discussions on the bases of significant steps in each E Each class had constructive comments and found minor discrepancies in the charts such that by the end of the plant training series of several groups, well groomed EPs will probably be issued for plant operator us The inspectors observed several hours of simulator training conducted using the new EPs and noted a l

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high degree of efficiency displayed through their use, once the operators became accustomed to the format. Many of the operators commented that the new EPs were a significant improvement over the previous procedure No violations or deviations were identifie . Refueling Activities (60710)

'The first refueling outage commenced with a reactor shutdown on September 6, 1986. - The inspectors routinely monitored refueling activities in progres The primary objectives of this inspection were to ascertain whether pre-refueling activities specified in the TS have been completed and whether refueling activities are being controlled and conducted as required by TS and approved procedures. The following comments were noted:

During this inspection period all core alterations were completed, the reactor internals have been reinstalled, and the reactor vessel head was installed with all vessel head closure bolts fully tensioned. The plant is in operational condition 4 (Shutdown at less than 200F). The inspectors witnessed the start of the initial, post refueling pressurization of the reactor to normal operating pressure of 1025 psig in accordance - with Integrated Operating Instruction 03-1-01-6, Revision 8, Reactor Vessel In-Service Leak Test. However, it became necessary to secure the test temporarily due to a leak in the reactor head piping mechanical joint. The test was successfully completed after repairs were mad On November 10, 1986, the inspectors witnessed an integrated containment pressure instrument test, the instruction for which was attached to MWO I67774, which was approved on November 9, 1986. The objective of this test was to verify the proper connection and tracking of containment pressure instruments and veri fy the tubing supplying these instruments was not blocked. The test was performed pursuant to LC 2.C.(33)(b), which requires prior to restart following the first refueling outage, for MP&L to complete the additional testing and training related to TMI Action Plan I .G.1 as described in Section 2.3 of the MP&L submittal dated April 3,1986. The MP&L submittal had two tests remaining as the refueling outage approache The first was operation of the Reactor Core Isolation Cooling (RCIC) system with a sustained loss of AC power to the system. This was successfully

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completed on September 5,1986, and is documented in NRC Inspection Report 416/86-26, in paragraph 11. The second test was to be the above integrated containment pressure instrument test. During the drywell bypass leakage rate test witnessed by the inspectors (paragraph 6), all of the drywell pressure instruments were satisfactorily response tested in accordance with MW OI67774. The remaining containment pressure instrument test shall be tracked to completion by Inspector Followup Item 416/86-37-0 No violations or deviations were identified.

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13. Cold Weather Preparations (71714)

The inspectors reviewed Equipment Performance Instruction 04-1-03-A30-1, Revision 0, Cold Weather Protection, for accomplishmen The instruction had been performed and deviations were identified and comments entered as to reasons for deviations. All deviations from required lineups were due to

. red tags covered by active clearance No violations or deviations were identified.

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