IR 05000416/1999008

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Insp Rept 50-416/99-08 on 990502-0612.Violations Noted.Major Areas Inspected:Licensee Operations,Maint,Engineering & Plant Support
ML20210B133
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 07/15/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20210B107 List:
References
50-416-99-08, NUDOCS 9907230065
Download: ML20210B133 (14)


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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

I Docket No.:

50-416 License No.:

NPF-29 Report No.:

50-416/99-08 Licensee:

Entergy Operations, Inc.

Facility:

Grand Gulf Nuclear Station Location:

Waterloo Road Port Gibson, Mississippi 39150 Dates:

. May 2 through June 12,1999 Inspectors:

Jennifer Dixon-Herrity, Senior Resident inspector Peter Alter, Resident inspector William McNeill, Reactor inspector Approved By:

Joseph Tapia, Chief, Project Branch A i

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ATTACHMENT: SupplementalInformation l

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j 9907230065 990715 PDR ADOCK 05000416 G

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EXECUTIVE SUMMARY Grand Gulf Nuclear Station NRC Inspection Report 50-416/99-08 This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6-week period of resident inspection.

Operations With one exception, the areas of the plant toured were maintained in good condition.

  • The inspectors identified missing or improperly secured fasteners on the access doors to three containment electrical penetration assemblies. The licensee identified similar problems on three additional assemblies. Operability of the assemblies was not affected because the equipment inside the assemblies remained environmentally

- qualified (Section O2.1).

Maintenance Eleven maintenance and testing activities observed were weii performed. A system

engineer exhioited good attention to detail in questioning a lack of indicated level in the reactor core isolation cooling turbine oil gauge prior to an overspeed test of the turbine (Section M1.5).-

The licensee failed to promptly address inadequate acceptance criteria for the oil level in

the reactor core isolation cooling turbine and correct inconsistencies in procedures addressing the oil level. This Severity Level IV violation of 10 CFR 50, Appendix B, Criterion XVI, is being treated as a noncited violation consistent with Appendix C of the NRC Enforcement Policy and is entered in the licensee's corrective action program as

' CR-GGN-1999-0675 (Section M1.5).

Operators failsd to enter Technical Specification 3.1.7.C, while ihe standby liquid control

system was inoperable with both standby liquid control system pump suction valves closed for approximately 30 minutes as required by a surveillance procedure. This Severity Level IV violation of Technical Specification 5.4.1.a. is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy and is entered in the licensee's corrective action program as CR-GGN-1999-0606 (Section M1.5).

The addition of test instructions to three different essential core cooling system

surveillance procedures without verification by system walk-through or test was identified as a poor practice.. In each case, operators stopped the pedormance of the

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procedurcis in the field after determining they could not be performed as written. The inspectors questioned the repeat errors. The licensee acknowledged the poor practice j

and determined that future revisions wore to be verified prior to approving the revision (Section M3.1).

The licensee's corrective actions in response to a pressure relief valve on the standby

liquid control system lifting 200 psi early in October 1998 were limited. The licensee i

I determined that the event occurred because the procedure to fill and vent the system i

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-2-was not added to subsequent work instructions for performing preventive maintenance on the relief valve. As a result of the limited corrected actions, the relief valve again lifted 200 psi early during a recent pump run after replacement of the pump packing (Section M3.2).

The maintenance rule periodic assessment performed for 1998 was thorough and

fulfilled the requirements of Section (a)(3) of the maintenance rule. The licensee was adequately balancing outages for maintenance to minimize system unavailability.

(Section M3.3).

The failure to provide adequate written procedures for the proper venting and filling of

the reactor core isolation cooling turbine oil system was a violation of Technical Specification 5.4.1.a. which resulted in overspeeding the turbine during testing. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. Corrective actions to address each of these failures are part of CR-GGN-1998-1442 (Section M8.1).

Plant Sucoort Observed activities involving radiological controls were well performed. The inspectors

identified an unsecured drainage hose routed into a contamination area which had the potential to allow the spread of contamination.. The licensee corrected the problem.

Health physics technicians exhibited good attention to detailin maintaining personnel dose ALARA. Daily security activities were well conducted (Sections R1.1 and S1).

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B_eport Details Summary of Plant Status The plant operated at 100 percent power from the beginning of the inspection period until May 22,1999, when the licensee lowered power to approximately 80 percent to perform control rod sequence exchange. The plant was returned to 100 percent power on May 23,1999, and operated at that level for the remainder of the inspection period.

1. Operations

Conduct of Operations 01.1 General Comments (71707)

The inspectors performed control room observations to assess operator knowledge and performance. Operations shift turnovers were thorough and well conducted. Operators

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were knowledgeable of the status of equipment and, with one exception (see i

Section M1.4), applicable Technical Specification limiting conditions for operations were appropriately entered. The operations department changed the shift hours so that the reactor operators and auxiliary operators now stood 8-hour shifts. The senior reactor

operators remained on a 12-hour shift schedule. An additional shift turnover was added to ensure that each shift was briefed on plant status. The inspectors observed that this q

change did not affect operations performance.

On May 22,1999, the inspectors observed a scheduled downpower to approximately 80 percent power. The briefing, held prior to the evolution, was thorough, and all the necessary personnel attended. The work performed included maintenance on hydraulic control units and a control rod sequence exchange. The work was well controlled and the plant was returned to 100 percent power the same day.

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O2.1 Plant Tourg a.'

Inspection Scope (71707)

The inspectors conducted tours through safety-related portions of the plant.

b.

Observations and Findinas With one exception, the areas of the plant that were toured were maintained in good condition. On May 8,1999, the inspectors noted that 7 of 10 cover fasteners on electrical penetration Box 1Z018 were loose, one fastener was missing on Box 1ZO19, and three were loose on Box 1Z020. All three were safety-related cable penetrations

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through containment. The superintendent initiated Condition Report (CR)

CR-GGN-1999-0508 and a work instruction to replace or tighten the fasteners.

Operators toured containment and found three additional boxes with missing f asteners.

The inspectors reviewed the operability review conducted by engineering personnel.

The terminal blocks inside the containment electrical penetration assemblies were environmentally qualified without the enclosure. The terminal box enclosure was only credited for shielding the terminal blocks from any Beta radiation dose.

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Conclusions With one exception, the areas of the plant which were toured were maintained in good condition. The inspectors identified missing or improperly secured fasteners on the access doors to three containment electrical penetration assemblies. The licensee identified'similar problems on three additional assemblies. Operability of the assemblies was not affected because the equipment inside the assemblies remained environmentally qualified.

11. Maintenance M1 Conduct of Maintenance

M1.1 General Maintenance Comments a.

Insoection Scope (62707)

The inspectors observed portions of maintenance activities, as specified by the following maintenance action items (MAls):

255154 Preparation for check Valve P41F169B repair

254427 Reactor Core isolation Cooling (RCIC) rupture disk replacement

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250794 RCIC turbine mechanical trip mechanism repair

255154 Check Valve P41F169B repair

251049 Replace diesel Dresser couplings Style 65 with Dresser couplings

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Style 90 254306 Division ll emergency diesel generator lube oil pressure switch

calibration 253881 SCRAM hydraulic control unit calibrations of accumulator gauges

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Observations and Findinas

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With the exception of the item discussed below, the inspectors found the work to be well performed. Craft personnel were knowledgeable, followed the written ins ^ ructions, and utilized proper tools and work practices. The licensee's planning of the work activities and the written instructions were technically proper.

The piping replacement activity involved using a thread lubricant and a gasket sealant;

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however, these materials were not specifically identified in the work package or the

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procedure. Maintenance supervision informed the inspectorr " ?t the use of these l

materials was within the skill of the craft. The inspectors rev.

1 the training given to l

craft personnel and determined that, although it did address the use of a thread

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lubricant, the training material did not clearly identify that a gasket sealant was to be used. The licensee planned to revise training materials to clearly specify that both a thread lubricant and a gasket sealant were to be used in this situation unless otherwise

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-3-M1.2 General Surveillance Comments i

a.

Inspection Scope (61726)

The inspectors observed portions of the following surveillances:

06-IC-1C51-R-0075 APRM Recirculation Flow Transmitter Calibration

04-1 -03-E51-1 RCIC Turbine Mechanical Overspeed Trip

06-OP-1 E51-0-0033 RCIC System Quarterly Pump Operability Verification

06-OP-1C41-0-0001 Standby Liquid Control Functional Test

b.

Observations and Findinas With the exception of the items discussed in Sections M1.3 and M1.4, the surveillance activities observed were well performed. Measuring and test equipment was calibrated.

The operators and technicians were knowledgeable, qualified, and demonstrated good communications and attention to detail.

M1.3 RCIC Turbine Surveillance On May 19,1999, the inspectors observed the RCIC turbine mechanical overspeed trip test. The inspectors attended the pretest briefing and found that it was thorough and included discussions of past problems and industry events involving this type of test.

While touring the pump room before the test, the inspectors noted that a hose that had been used by the night shift to provide temporary cooling during the uncoupled run was supported by safety-related conduit for the trip throttle valve actuator. The conduit contained cables for the trip throttle valve which was not operable at the time. This matter is discussed further in Section R1.1.

A system engineer observing the test noted that there was no oil in the turbine lube oil sight glass. The engineer contacted the control room, and maintenance personnel were directed to add oil. The oillevel was raised to the appropriate level. The engineer initiated CR-GGN-1999-0546 to document that Procedure 04-1-03-E51-1 and other

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- procedures provided no direction to check the lube oil level.

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This matter had been previously identified in CR-GGN-1998-0729, written in June 1998.

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In NRC Inspection Report 50-416/98-08, the inspectors had noted that the RCIC system

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engineer was not aware of what the proper level should be and was investigating industry guidance to define the proper level. The inspectors had also noted that applicable procedures were not consistent in providing guidance to operations personnel to ensure that the level was checked. During that inspection, the operations superintendent stated that the procedures would be revised.

In NRC Inspection Report 50-41G/98-13, the inspectors noted that one of the corrective actions taken in June 1998 was to direct the operators ensure that the level was maintained within an inch of the line on the gauge glass. This guidance had been provided verbally, placed on an information tag on the pump, but was not documented in i

the CR. The licensee subsequently determined that the line was below the minimum oit

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-4-level required. After determining that the mark on the gauge glass was incorrect, the system engineer initiated CR-GGN-1998-1441. This CR documented that the level mark was too low. The corrective action for this CR included providing training to operations personnel, hanging an information tag in the field, and adding the proper level marks to the gauge glass. The CR did not address ensuring that the procedures reflected the change in acceptance criteria.

Although the procedure inconsistency was identified in June 1998, it was not corrected until after May 19,1999, when the system engineer identified that there was no oilin the gauge glass.10 CFR 50, Appendix B, Criterion XVI, requires that measures be established to assure that conditions adverse to quality, such as deficiencies and nonconformances are promptly identified and corrected. The failure to promptly identify potentially inadequate acceptance criteria within the corrective action program and to promptly correct inconsistent procedures to ensure that a piece of risk-significant equipment was properly maintained were conditions adverse to quality. It took approximately 6 months to address the concerns dealing with the lack of level acceptance criteria and 11 months to address the identified inconsistencies in the procedures. This failure was a violation of 10 CFR 50, Appendix B, Criterion XVI. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy (50-416/9908-01). This violation is captured in the licensee's corrective action program as CR-GG-1999-0675. The licensee planned to change the procedures to eliminate the discrepancies and ensure that the oillevel was correctly maintained.

M1.4 Standbv Liauid Control (SLC) Quarterly Functional Test a.

Inspection Scope (61726)

i On June 7,1999, the inspectors observed the performance of the SLC System B i

quarterly functional test. The inspectors reviewed Procedures 06-OP-1C41-OOOO1,

" Standby Liquid Control Functional Test," Revision 103,02-S-01-5, " Shift Logs and Records," Revision 104, and 01-S-06-44," Operability Assessment," Revision 102.

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Observations and Findinos Operations department personnel declared SLC Systems A and B inoperable and j

entered Technical Specification 3.1.7.C, as required, when the SLC pump's common

suction was aligned to the system test tank. The motor-operated SLC storage tank I

suction Valves 1C41-F001 A and B are interlocked closed when the manually-operated test tank outlet Valve 1C41-F031 is open. The shift supervisor cleared the Technical Specification limiting condition of operation when the Pump B functional test was complete, and Valve 1C41-F031 was closed. Approximately 10 minutes later, the inspectors noted that SLC Systems A and B were again made inoperable when operators closed manually-operated pump suction Valves 1C41-F002A and B for 30 minutes to allow stroke time testing of SLC System B storage tank outlet

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Valve 1C41-F001B. The surveillance tracking logbook entry for Procedure 06-OP-1C41-OOOO1 only tracked the time that Valve 1C41-F031 was open.

When asked by the inspectors, the shift supervisor explained that operators normally

-5-only tracked the time Valve 1C41-F031 was open. The shift supervisor agreed that the SLC system was inoperable when Valves 1C41-F002A and B were closed and that the time those valves were closed should be tracked as well.

In the note following step 5.2.2, Procedure 06-OP-1C41-OOOO1 states "During portions of this test, SLC System will be Inoperable (i.e., whenever [ Valve) 1C41-F031 is Open or Both [ Valves) 1C41-F002A and 1C41-F002B are Closed)." Procedure 01-S-06-44, Attachment VI, Section A.7 states that "if during preventative maintenance or Technical Specification surveillances equipment is removed from service and rendered incapable of performing its specified function (s), it shall be declared inoperable. The [ limiting condition for operation) action statement shall be entered unless the Technical Specification explicitly directs otherwise." Technical Specification 5.4.1.a. states that procedures recommended in Appendix A of Regulatory Guide 1.33," Quality Assurance Program Requirements (Operations)," Revision 2, shall be implemented. SLC system surveillance procedures and administrative procedures for log entries and record retention are covered by Appendix A. The failure of operators to enter Technical Specification 3.1.7.C, while the standby liquid control system was inoperable with both standby liquid control system pump suction valves closed for approximately 30 minutes as required by a surveillance procedure, was a violation of Technical Specification 5.4.1.a. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy (50-416/9908-02). This violation is captured in the licensee's corrective action program as CR-GGN-1999-0606.

The licensee plans to improve the directions in Procedures 06-OP-1C41-0-0001 and 02-S-01-5.

M1.5 Conclusions on Conduct of Maintenance Eleven maintenance and testing activities observed were well performed. A system engineer exhibited good attention to detail in questioning a lack of indicated level in the reactor core isolation cooling turbine oil gauge prior to the overspeed test of the turbine.

The failure of the licensee to promptly address the inadequacy of the acceptance criteria for the oil level in the RCIC turbine and correct inconsistencies in procedures addressing the oillevel promptly was a violation of 10 CFR 50, Appendix B, Criterion XVI. The failure of operators to enter Technical Specification 3.1.7.C, while the standby liquid control system was inoperable with both standby liquid control system pump suction valves closed for approximately 30 minutes as required by a surveillance procedure, was a violation of Technical Specification 5.4.1.a. These Severity Level IV violations are being treated as noncited violations, consistent with Appendix C of the NRC Enforcement Policy.

M3 Maintenance Procedures and Documentation M3.1 Surveillance Quality a.

inspection Scope (61726)

The inspectors reviewed problems associated with surveillance procedure quality.

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Observations and Findinas On April?0,'1999, the inspectors reviewed the quarterly functional test of the high pressure are spray pump. - After the pump run had been started, operators backed out

' of the sury illance procedure when they found that the gauge which the procedure

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directed be installed was not the correct range for the application.- The shift

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superintendent initiated CR-GGN-1999-0478 to document the procedure problem. The

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inspectors noted that halting the test to revise the procadure was appropriate, but i

recalled that the test of the low pressure core spray pump had been stopped for similar reasons 'on April 19,1999, and that a similar problem with the surveillance of the

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residual heat removal system had occurred before that. In each case, the procedure being used had been recently revised and operators had questions that prevented the

" procedures from being successfully used as written.

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During the discussion of the procedure problem in the condition review group meeting on April 30, the inspectors questioned why there had been repeat problems with revised surveillances and why the procedures had not been walked down prior to use. The

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licensee researched the question and readdressed it during the meeting on May 3,1999. The surveillance procedure problems all dealt with a recent decision to.

l change the testing of the system jockey pumps. Engineering personnel provided input on how the pumps were to be tested, and operations personnel revised the surveillance procedures using this input. Each problem encountered was different in the cat,e of low pressure core spray pump, the system drawing did not include an instrument root L valve and the procedure did not include directions to manipulate the valve. Without this direction, the procedure could not be implemented. For the residual heat removal

. system, the acceptance criteria provided was not the_ appropriate criteria for the installed pumps and, as a result, the pumps could not' pass the surveillance.

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Procedure 01-S-07-2, " Test and Retest Control," Revision 102, step 6.6.2 stated that, when feasible, procedures / instructions should be validated by walk-throughs, trials on

. the plant simulator, or other means before the test was actually performed. In this case, no walk-through or verification process was used. Operations personnel planned to -

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validate major revisions to test instructions in surveillance procedures prior to f_

' implementation in the future.

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Conclusions iThe addition of test instructions to three differ 6'11 essential core cooling system

surveillance procedures without verification by system walk-through or test was

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identified as a poor practice. in each case, operators stopped the performance of the

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procedures in the field after determining that they could not be performed as written.

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The licensee acknowledged the poor practice and stated that future revisions were to be q

verified prior to approving the revision.

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-7-M3.2 Inadeauate Fill and Vent of the SLC System Followina Maintenance

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Insoection Scope (61726)

On June 6,1999, during performance of postmaintenance testing of SLC Pump A, the pump discharge relief valve lifted. The inspectors reviewed the licensee's immediate response to the event and corrective actions to restore SLC System A to operable status. The inspectors reviewed MAI 24221," Replace SLC Pump A Packing," dated June 2,1999, Instruction 07-1-34-C41-C001-1, " Standby Liquid Control Pump Disassembly, inspection and Reassembly," Revision 5, instruction 04-1-01-C41-1,

" Standby Liquid Control System," Revision 104, P&lD M-1082, " Standby Liquid Control System," Revision 24, CR-GGN-1998-1106, and CR-GGN-1999-0597 and 0599.

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Observations and Findinas The licensee determined that the cause of the unexpected lift of the SLC Pump A discharge relief Valve 1C41-F029A was air in the pump discharge piping. Neither MAI 24221 nor Procedure 07-1-34-C41-C001-1 provided for refill and vent of the system following pump reassembly. In addition, the inspectors found no provisions for filling and venting the SLC system in Instruction 04-1-01-C41-1. The licensee initiated CR-GGN-1999-0597 to address the concern.

The inspectors noted that a similar event had occurred on October 20,1998, as documented in CR-GGN-1998-1106. At that time, relief Valve 1-C41-F029A had been reinstalled after preventive maintenance. During the functiona! test of the system, the

valve lifted 200 psi early. The licensee determined the cause to be air entrapped in the standpipe upstream of the relief valve "due to no way to fill and vent system due to design of piping inside the pump boundary." The corrective action for this event was to provide special instructions in the work order to verify that the system was completely filled prior to reinstalling the pressure relief valve. CR-GGN-1998-1106 was closed on January 7,1999.

The pressure which caused the relief valve to open during the two events was a result of the throttling of test tank isolation Valve 1C41-F0221. This valve was throttled to verify that the relief valve did not open when the pressure in the system reached 1300 psig.

Once the air was vented out of the system, the relief valve opened at the design setpoint of 1500 psig. The licensee has identified no other examples where the relief valve opened early at 1300 psig. The failure to adequately fill and vent the SLC system was of low safety significance because the system was vented during the postmaintenance test. The licensee has not had other problems in the past due to the absence of a fill and vent procedure for this system.

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Conclusions The licensee's cc.'rective actions in response to a pressure relief valve on the standby liquid control system lif ting 200 psi early in October 1998 were limited. The licensee determined that the event occurred because the procedure to fill and vent the system was not added to subsequent work instructions for performing preventive maintenance

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8-on the relief valve. As a result of the limited corrected actions, the relief valve again lifted 200 psi early during a recent pump run after replacement of the pump packing.

M3.3 Maintenance Rule Periodic Assessment a.

Inspection Scope (62707)

The inspectors reviewed the "GGNS Maintenance Rule Periodic Assessment for 1998,"

dated May 27,1999.

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Observations and Findinas The periodic assessment conducted for 1998 detailed the systems removed from and added to Section (a)(1) status within the maintenance rule and how those systems were meeting the goals that had been set. In addition, the assessment reviewed all systems monitored under the maintenance rule, providing detail as needed. The inspectors observed that there had been no repeat problems and that the outages for maintenance were balanced so as to minimize system unavailability where possible. The systems that did not meet these goals were being monitored under Section (a)(1). The goals set were adequate and reflected industry experience. The reviews completed specifically addressed risk for each of the systems being tracked under Section (a)(1).

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Conclusions The maintenance rule periodic assessment performed for 1998 was thorough and fulfilled the requirements of Section (a)(3) of the maintenance rule. The licensee was adequately balancing maintenance outages to minimize system unavailability.

hWl8 Miscellaneous Maintenance issues M8.1 (Closed) Unresolved item 50-416/9815-01: RCIC system turbine overspeed and failure to trip. On December 3,1998, during postmodification testing for Work Order (WO) 19960334, the RCIC turbine experienced an overspeed condition and failed to trip automatically. The operators were also unable to trip the turbine remotely. The turbine was secured by closing the turbine trip throttle valve from the main control room. The RCIC system was declared inoperable in accordance with Technical Specification 3.5.2.

Following extensive maintenance to the RCIC trip throttle valve and troubleshooting of the turbine oil system, RCIC was declared operable on December 12,1998. A significant event response team was established to investigate the event and make corrective action recommendations. In conducting this review, the inspectors reviewed the following documents:

CR-GGN-19981442, "RCIC turbine overspeed on 12/03/98."

  • Significant Event Response Team (SERT) Report, "RCIC Turbine Overspeed

During Attempted sol Run Following a System Maintenance Outage," dated February 3,1999.

WO 19960334, " Install RCIC Turbine Oil Sample Valves Per ER 96/0334-00-1,"

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-9 dated November 19,1998.

Instruction 07-S-14-92," Inspection and Lubrication of Terry Turbine Throttle Trip

Valve," Revision 1; Instruction 07-1-34-E51-C002-1, *RCIC Turbine Bearing inspection and

Replacement," Revision 8.

Vendor Manual 460000182, RCIC Pump Drive for Terry Steam Turbine.

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Special Instruction (WO 217073) for postmaintenance retest of RCIC turbine,

dated December 6,1998.

Equipment Performance Instruction 04-1-03-E51-1,"RCIC Turbine Mechanical

Overspeed Trip," Revision 4.

M8.1.; RCIC Turbine Trio Failure The licensee's SERT determined that the most probable cause for the failure of -

RCIC turbine to trip automatically was relaxation of the trip throttle valve closing spring.

During discussions with the vendor, the licensee learned that the valve design had been modified to incorporate a stronger spring as a result of three different events at other sites where the trip throttle valve stuck while operating at minimum steam flow conditions. The manufacturer determined that the modification was an improvement rather than a needed design change because the valves would work properly in an overspeed condition. As a result, the need for the modification was not well

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communicated. In investigating the problem, the licensee found that the manufacturer l

of the valve had not taken into account any friction that would be encountered when the valve went closed nor that the springs would relax with time and, as a consequence, no maintenance was suggested. The licensee modified the valve to use the stronger

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spring and plans to revise the preventative maintenance procedures for the trip throttle

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valve to maintain the spring.

M8.1.2 RCIC Turbine Oversoeed -

The licensee's SERT report identified that the rnost probable cause for the RCIC turbine overspeed was improper fill and vent of the turbine oil system as part of work performed under WO 19960334. This resulted in air binding of the control oil portion of the turbine control valve servo mechanism. The licensee identified several contributing causes for this failure, which included:

Instruction 07-1-34-E51-C002-1 did not specify the correct quantity of oil to

completely refill the turbine oil system nor did it contain comprehensive i

instructions to adequately drain, fill, and vent the RCIC oil system.

WO 19960334 did not include the necessary sections of

Instruction 07-34-E51-C002-1 for properly refilling the turbine oil system following modification to the syste.

-10-The work instructions were not revised in accordance with Procedure 01-S-07-1,

" Control of Work on Plant Equipment and Facilities," Revision 34, step 6.5.3, after the system engineer determined that the RCIC turbine should be hand rolled while the oil system was being drained. This direction was given verbally and was not properly evaluated for its impact on the refilling process.

The fill and vent instructions in the vendor manual were not for the turbine oil

system installed and modified at Grand Gulf.

Technical Specification 5.4.1.a. states that procedures recommended in Appendix A of Regulatory Guide 1.33," Quality Assurance Program Requirements (Operations),"

Revision 2, shall be established and implemented. Maintenance that can affect the performance of safety-related equipment is covered by Appendix A. The failure to provide adequate written procedures for the proper venting and filling of the reactor core isolation cooling turbine oil system was a violation of Technical Specification 5.4.1.a.

which resulted in overspeeding the turbine during testing. This Severity LevelIV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy (50-416/9908-03). Corrective actions to address each of these failures are part of CR-GGN-1998-1442.

lit. Enaineerina E8 Miscellaneous Engineering issues E8.1 Year 2000 S?aram Review (Tl 2515/141)

The inspectors conducted an abbreviated review of Y2K activities and documentation using Temporary Instruction 2515/141, " Review of Year 2000 (Y2K) Readiness of Computer Systems at Nuclear Power Plants," dated April 13,1999. The inspectors addressed the areas of Y2K management planning, documentation, implementation planning, initial assessment, detailed assessment, remediation activities, Y2K testing and validation, notification activities, and contingency planning. The inspectors used NEl/NUSMG 97-07, " Nuclear Utility Year 2000 Readiness," dated October 1997, and NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning," dated August 1998, as references for this review. The results of this review will be combined with the results of reviews performed at other nuclear plants in a summary report to be issued by July 31,1999.

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IV. Plant SuppoA

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R1 Radiological Protection and Chemistry Controls R1.1 General Comments a.

Inspection Scope (71750)

During tours of the radiologically controlled area, the inspectors observed radiological postings and worker adherence to radiation protection procedures.

b.

Observations and Findinas Personnel followed radiation protection procedures, locked high radiation area doors were locked, and radiation and contamination areas were properly posted. The inspectors observed radiation work practices and performance during the planned RCIC system outage. With one exception, workers exhibited good work practices and the health physics technicians were diligent about pointing out low-dose waiting aret t and maintaining ALARA. The inspectors observed that a drain hose going from the RCIC turbine to a contaminated area drain was attached to a safety-related conduit, which was used to supoort the hose, and then to the drain. The hose was not secured at the point it entered the contaminated area. The inspectors discussed the concern with the radiation protection supervisor in the area and with the shift superintendent.

The radiation protection supervisor had the hose secured until operations personnel could properly reroute it.

c.

Conclusions i

Observed activities involving radiological controls were well performed.- The inspectors j

identified an unsecured drainage hose routed into a contamination area which had the potential to allow the spread of contamination. The licensee corrected the problem.

Health physics technicians exhibited good attention to detail in the area of maintaining personneldose ALARA.

i S1 Conduct of Security and Safeguards Activities (71750)

On a daily basis, the inspectors observed security personnel practices and the condition of security equipment. Protected and vital area barriers were in good condition. The isolation zones were free of obstructions, and the protected area illumination levels were l

good. The inspectors concluded that the daily security activities were well conducte l

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-12-V. Manaaement Meetinas X1_

Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on June 17,1999. The licensee acknowledged the findings

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presented.

The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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d ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee C. Bottemiller, Superintendent, Plant Licensing B. Carroll, Superintendent, Operations B. Edwards, Manager, Planning and Scheduling W. Eaton, Vice President C. Lambert, Director, Design Engineering J. Roberts, Director, Quality Programs W. Shelly, Manager, Training C. Stafford, Manager, Plant Operations NRC P. Sekerak, NRR Project Manager INSPECTION PROCEDURES USED 61726 Surveillance Observations 62707 Maintenance Observation 71707 Plant Operations 71750 Plant Support Activities 92902 Followup - Maintenance Tl 2515/141 Year 2000 Program Review ITEMS OPENED. CLOSED. AND DISCUSSED i

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50-416/9908-01 NCV Failure to Promptly Correct Inadequate Criteria and Procedures (Section M1.3)

50-416/9908-02 NCV Failure to Enter LCO Action (Section M1.4)

50-416/9908-03 NCV Inadequate Procedure for Fill and Vent of RCIC Turbine Oil Systern (Section M8.1)

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Closed 50-416/9815-01 URI RCIC System Turbine Overspeed and Failure to Trip (M8.1)

50-416/9908-01 NCV Failure to Enter LCO Action (Section M1.5)

50-416/9908-02 NCV Inadequate Procedure for Fill and Vent of RCIC Turbine Oil System (Section M8.1)

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