IR 05000424/1987057
ML20236M737 | |
Person / Time | |
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Site: | Vogtle ![]() |
Issue date: | 10/21/1987 |
From: | Jape F, Szczepaniec A, Matt Thomas NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20195G739 | List: |
References | |
50-424-87-57, 50-425-87-38, NUDOCS 8711130266 | |
Preceding documents: |
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Download: ML20236M737 (8) | |
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N MGoh UNITED STATES
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j ok NUCLEAR REGULATORY COMMISSION.
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o REGION il
5 t-g 101 MARIETTA STREET, N.W. SUfTE 2900 j
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ATLANTA, GEORGIA 30323
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Report Nos.: 50-424/87-57 and 50-425/87-38 i
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Licensee:
Georgia Power Company.
P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: '50-424 and 50 425-License Nos.:
NPF-68.and CPPR-109-
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Facility Name:. Vogtle 1 and 2-
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I Inspection Conducted:
September 21-25,.1987
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'I Inspectoys: k d. // ~ 2, -
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fvA.J,Szczdpaniec Date Signed.
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[eM. Thomas'
Date. Signed 1,
Approved by: hd. fA.'
/e-/7-F7 g M. Jape, CMie'f Date Signed Test Programs Section l
Division of Reactor Safety l
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SUMMARY j
Scope: This routine, unannounced inspection'was in the areas of preoperational test program for unit 2 and review of the status.of items on.the outstanding j
items list.
Results:
Two violations were identified:
Failure to Test the ' Diesel Generators in Accordance with Technical. Specification. Surveillance i
Requirements and Failure to Report.Nonvalid Diese1L Generator: Failures.
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8711130266 871105 ADOCK 0 % 4y4 PDR G
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REPORT DETAILS l
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Persons Contacted.
l Licensee Employees I
- T. Greene. ' Plant Manager.
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' *C. Belflower,'_ QA Site Manager
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C.' Whitney, General Manager - Project Support
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- H.' Handfinger, Project S/0 Manager
- M. J. Ajuluni, Operations Superintendent
-*W. C. Gabbard, Senior Regulatory Specialist
- S. Hall, Procedures Superintendent
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- R. Odom, Engineering Supervisor'
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- K. Stokes, Test Engineer.
- J. Aufdenkampe, Engineering ~ Supervisor'
- J. E. Swartzwelder, Deputy Manager. - Operations j
+#G. B. Bockhold, Plant'. General Manager - Operations
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Other licensee employees' contacted included construction craftsmen,
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engineers, technicians,' operators, and office. personnel.
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NRC Resident Inspectors
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J. Rogge, Senior Resident Inspector
- C. Burger, Resident Inspector-H. Livermore, Senior Resident Inspector, Construction
- Attended exit interview
- Contacted by telephone on September.29, 1987
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+ Contacted by telephone.on October 5, 1987 2.
Exit Interview The inspection scope and findirigs were summarized on September 25, 1987, and by telephone conversations on September 29, 1987.and October 5, 1987, with those persons. as indicated in paragraph 1 above'.. The inspectors described the' areas inspected-and discussed in detail the inspection
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findings.
No dissenting comments were received from.the licensee.
The following new items were identified during this' inspection:
Violation 424/87-57-01, Failure to test DGIA and DG1B in /qcordance.
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with the Test Interval Specified in Technical Specification Table
4.8-1 (Paragraph 6.a).
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Violation 424/87-57-02, Failure to' Report Nonvalid Diesel Generator Failures (Paragraph 6.b).
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The licensee did not identify as proprietary any of the materials provided j
to or reviewed by the inspectors during this inspedtion.
3.
Licensee Action on Previous Enforcement Ma tters '
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(0 pen) Violation 424/86-118-01, Failure to Adequately Document and Evaluate Diesel Generator Performance.
During previous followup of this item (documented in NRC Inspection Report-50-424/87-17), a
concern was raised regarding the amount of information being recorded on the forms for some of the DG start attempts.
The information en I
I the forms was not adequate to allow proper evaluation of the DG start attempts.
A second-' concern was raised regarding evaluation of DG start attemp(ts by operations personnel below the level of the shift supervisor who holds a senior. reactor operator's license).. With j
regard to the first concern, the records for DG1A and DGIB start i
attempts were reviewed.
The inspectors found the records to be,
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incomplete in that there were examples where.some start attempts were logged as acceptable starts but'there was no indication as to whether these were considered valid or nonvalid tests; _and the time interval.
between DG starting and stopping times did not agree with the times for DG engines hours (cumulativ: total)..t shutdown.
The inspectors also questioned what was meant w an the'" start ' acceptable" block on j
a the DG start attempt _ log forms was checked yes.
Operating procedure
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13145-1 and surveillance procedure 14980-1 state that appropriate information for each DG start attempt will be recorded in the shift
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supervisor's log. Review of the shift supervisor's log revealed that
the log does not provide adequate information to assist in evaluating
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questionable DG start attempts.
The inspectors concluded that there are still instances where the information is not adequate to allow proper evaluation of some DG start attempts.
With regard to the second concern, the licensee.has revised operating procedure 13145-1, Diesel Generators, and surveillance procedure 14980-1, Diesel Generator Operability Test, to require that DG start l
attemp)ts be reviewed by either the on shift operations supervisor (0 SOS, sh{
I of which holds a senior reactor operator's license.
These actions
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are adequate to resolve this concern.
- During the exit meeting, the licensee stated that the additional j
concerns will be reviewed and necessary actions taken.
This item-
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remains open and will be reviewed during a later inspection along j
with any additional corrective actions taken by the licensee.
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(Closed) Violation 424/86-132-02, Documentation.and Review of. Remote
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Shutdown Panel Test Results.
The inspectors reviewed the corrective-j actions stated in the licensee's response to the violation dated i
February 27, 1987. The corrective actions include counseling of.-Test-l Review Board members and revisions to the' licensee's instructions for l
the Writer's and Reviewer's Guide and the Review Checklist, which j
cover the review of supporting documents that may require sign-offs
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to demonstrate that t< t nq har been completed.
These corrective
actions are applicable tc t it 2 and do not apply to Unit I since the
preoperatiunal test pros."..n nas bean completed.
An. Operations i
Deficiency Report (00R) T-1-86-4680 was written'to document the test discrepancy of the unsigned steps.
The ODR:was dispositioned by signed statements from personnel involved in the test attesting that
controls had been transferred from the main control room (MCR) to the auxiliary. shutdown panel B and required actions completed j
satisfactorily during performance of _ the remote shutdown panel i
preoperational test 1-300-10 and abnonnal operating procedure 18038-1.
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Proper implementation of the corrective actions applicable to Unit 2 preoperational testing will be reviewed during inspections of-the ongoing preoperational test program for Unit 2.
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considered closed.
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4.
Unresolved Items
No items were left unresolved from this inspection following telephone l
conversations of September 29, 1987, and October 5, 1987.
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5.
Unit 2 Preoperational Test Program (70301, 70302, 70341, 70441)
During this inspection, the inspectors met with key licensee personnel
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i associated with the Unit 2 preoperational test program.
The inspectors I
discussed, the proposed preoperational test program, its current status, j
and its implementation schedule with these personnel.
A listing of J
preoperational test program procedures was. obtained, as well as the
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testing schedule for the remainder of 1987.. The inspectors also reviewed l
and observed preoperational test procedure 2-3KJ-02, Diesel Generator
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Train B Starting Air System. The inspection of the program as planned has indicated that lessons learned during the Unit 1 preoperational test j
program are being applied to Unit 2.
Within the areas inspected no violations or deviations were identified.
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Review of Georgia Power Company Special Report i
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a.
The inspectors reviewed licensee Special Report 50-424/87-001, Valid Diesel Generator Failure Mechanical Governor Malfunction, dated September 23, 1987. The failure occurred on DG1A on August 24, 1987, and the licensee submitted the report per the requirements of Vogtle
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TS 4.8.1.1.3.
While reviewing the special report and related' DG.
start attempt records, the inspectors raised several questions. The first question pertained to the licensee's statement that this was the first valid failure of DG1A in 11 valid start attempts since Unit 1 received an operating license on January 16, 1987.
The inspectors stated that, per Regulatory Guide 1.108, Revision 1, in l
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order to determine that periodic test interval for DGs 'during plant
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operation, DG start attempts and failures are to be counted from the l
time of completion.of DG reliability' demonstration test (which L is.
l performed-during the preoperational test program). The periodic. test:
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demonstration test. rather than since issuance' of the. operating license (OL).
The inspectors further stated that this. issue was the subject of a previous ~ violation (424/86-118-01) which is discussed in-paragraph 3.a above..
During review of the DG1A start attempt records, the inspectors found that the August 24, 1987 failure (start attempt no. 58)' was the second valid failure of DG1A since completion;
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of the DG reliability demonstration testing.
The first. valid failure j
occurred on December 2,1986 during start. attempt no.16. - Start attempt no. 58 was the second valid failure in 15 valid tests since completion of the reliability demonstration testing.
The special
report stated that DG1A was still on the once' per 31 days test interval.
This test frequency did not appear to.be in accordance with TS 4.8.1.1.2.a and TS Table 4.8-1 which require that each DG -
shall be demonstrated operable on a staggered test basis once per
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seven days if the number of failures in the last 20 valid tests is'
f greater than or equal to two. The. associated test frequency shall be naintained until seven consecutive failure free demands have been
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performed and the number of failures in the last 20 valid demands has
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been reduced to one.
It had been more than seven days since.DGIA had I
been tested and this did not appear to be in accordance with TS 4.0.2 l
which specifies that each TS surveillance requirement shall be performed within the specified time interval with:
(1) a maximum
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allowable extension not to exceed 25% of the surveillance interval, but (2) the combined time interval for any three consecutive surveillance intervals shall not exceed 3.25 times the: specified
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surveillance interval.
The inspectors were unable to determine if
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the TS requirements had been met in that there were a number of-DGIA start attempts which were marked as acceptable starts but had no indication as to whether the start attempts were valid or nonvalid tests. During the exit meeting on. September 25, 1987, the inspectors i
stated that the start attempts which were not. classified as neither l
valid or nonvalid needed to be evaluated and a determination made concerning their validity because this would have an impact on the TS surveillance test interval and also on whether the licensee has been in compliance with applicable TS.
The licensee stated that all the start attempts in question would be evaluated to ' determine if they were valid or nonvalid tests.
The licensee further stated that some of the start attempts were performed during engineered safety L
features actuation system (ESFAS) preoperational testing.
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licensee requested an interpretation as to whether some of successful ESFAS start attempts could be considered valid tests.
The inspectors stated during the exit that this item would be unresolved until an interpretation could be obtained from NRC-NRR on the successful ESFAS start attempts, and until the licensee -completed its evaluation of the start attempts which were not classified.
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s The inspectors discussed the quedion of? successfully ESFAS start '
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attempts - with NRC-NRR personnel on September 28. and 29,1987, who stated that the'ESFAS start attempts must. meet the criteria specified
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in Regulatory Position C.2.e of Regalatory Guide 1.108 in order to be
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considered a valid successful. test.
It was further stated that per
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TS Table 4.8-1,-DGIA should be in'a once per seven days test interval rather than once per 31 days.
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N During review of DG1B start attempt records, the inspectors. found that DG1B had had three valid failures after completion of the DG.
reliability demonstration test but prior to. issuance of the OL.
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test frequency for DG18 was increased from once per 31 days to oncec per seven days.
Licensee; personnel stated that the frequency was increased so that the number of tests required by TS Table 4.8-1 (i.e., perform seven consecutive failure free demands and the number
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of failures in the last 20 valid demands has been reduced to one)
would be performed prior to issuance of the OL and DCIB' could be returned to the once per 31 days test. interval. Diesel generator IB was retur.ned to the once per 31 days test interval after start n
attempt no. 42 was performed on February 21, 1987.
In reviewing DG1B
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start attempts, the inspectors noted that for a number of the start attempts, DG1B operated for only a short period of time.
When-questioned on the run times, licensee personnel stated that the runs
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were considered to be DG demands. A valid demand was interpreted to
be different from a valid test in that a demand was a DG start only (no loading) and, therefore, did not have to meet the valid test criteria specified in Regulatory position C.2.e of Regulatory Guide 1.108.
During telephone conversations. with NRC-NRR personnel.on September 28 and 29, 1987, the inspectors also requested an interpretation from NRR regarding " valid tests" and " valid demands" (both of which are used in Vogtle TS Table 4.8-1).
NRR personnel
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stated that the terms were synonymous, and the licensee's interpretation of valid demands as used in TS Table 4.8-1 was incorrect.
In order to have a successful. valid demand, the valid test criteria in Regulatory Position C.2.e of Regulatory Guide 1.108 must be met.
Therefore, DG1B should have remained on the once per seven days test interval instead of returning to the once per 31 days test interval.
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During a telephone conversation with licensee personnel on September 29, 1987, the inspectors informed the licensee of interpretations received from NRR.
The licensee acknowledged the information. The licensee also stated that the start attempt records for both DGs have been evaluated and the following determinations
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made:
(1) DGIA had two valid failures in 17 valid tests since i
completion of DGIA reliability demonstration testing.
DGIB had three i
valid failures in 18 valid tests'since completion of DG1B reliability
demonstration testing. Therefore, beginning September 29, 1987, both DGs would be tested on the once per seven days test interval.
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inspectors requested that copier of the updated DG start attempt j
records be sent to the NRC Region II office for review.
During review of the updated records, the inspectors made the following observations:
(1) After the valid failure to DG1A on August 24,
1987 (due to the mechanical governor malfunction), the governor was
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replaced and DG1A was successfully tested on August 26, 1987.
However, DG1A remained on the once per 31 days test interval (instead of going to the increased test frequency of once per seven days) from I
August 26, 1987 until September 24, 1987.
Therefore, DG1A was considered to be technically inoperable from September 4 through 24, 1987, (period that the surveillance test interval hadtbeen exceeded).
i The next surveillance test was performed successfully on
September 24, 1987; (2) When Unit 1 entered operational Mode 4 on
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February 20,'1987, both DGs were required to be operable.
At the l
time, DG10 had had three valid failures in nine valid tests since
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completion of the DG1B reliability demonstration testin However, j
OGIB remained on the once per 31 days test interval (g.instead of j
returning to the required once per seven days test interval) froc February 21, 1987 until September 29, 1987.
Therefore, DG1B was
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considered to be technically inoperable at various times during the j
above period, i
I As a result of failing to meet the required test intervals (based on j
the number of valid failures), both DGs were considered to be l
technically inoperable simultaneously for over 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> on August 24 q
and 25, 1987, when DG1A failed its surveillance test, and the time
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for testing DG1B (which was last tested on August 11,1987) had been j
exceeded.
Both DGs were again considered to be technically j
inoperable simultaneously for 11 days (September 4, 1987 to i
September 15,1987) when each DG had exceeded the time interval for testing.
The inspectors informed the licensee by telephone on
October 5, 1987, that failure to test the DGs in accordance with the requirements of TS surveillance requirements is a violation and would be identified as item 50-424/87-57-01, Failure to Test DG1A and DGlB in Accordance with the Test Interval Specified in Technical
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Specification Table 4.8-1.
Although the test interval was exceeded i
for both DGs, the inspectors noted that except for the DG1A failure
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on August 24, 1987, the DGs performed success fully during surveillance testing.
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During review of the DG start attempt records, the inspectors noted that there were several unsuccessful start attempts for DG1A (start nos. 43, 44, and 45 performed February 18, 1987) which were classified as nonvalid tests.
The inspectors reviewed the licensee's
evaluations of these trips (memoranda dated March 3,11, and 20,
'3 1987).
The evaluations stated that the trips were due to low turbocharger oil pressure, which is a trip that is bypassed in the i
emergency operating mode.
The evaluations further stated that one of I
the. trips was due to an improper valve alignment and the other trips
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, ' wereidue. to loose Joil fittings which J resulteGin : oil; leaks. i The', m H
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inspectors; asked licensee'personnellif. the-nonvalid failures'had been ;
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reported to the NRC. per the ' requirements; ofiTS 4.8.1.1.3.; Thisj TS1 S1
' equires'that;allTDG failures,ivalid or :nonvalid,'shallibe -~reportedJ q
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.to the Commission.in aLSpecial: Report within'301 days..; Based onsthet
Llicensee's; evaluation of the ' failures, it' appears that one orja11Lofi
'1 the ~ failures: shoul' 'h'avelbe'en reported.< t Licensee personnel cstated y
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d that the'. failures had not been reportedh ' During:theftelephone call
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- on October 5, '1987,; the. inspectors Linformed thellicensee that: failure -
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c to. report the L nonvalid" DG 3 failures is ma L violation.' and will(bel.
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identified.as' item:501424/87-57-02,; Failure to; Re' port Nonvalid: Diesel-
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Generator Failures.
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f No other. violations or deviations werenidedtified in: the areas
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(Closed) Temporary Instruction TI 2500/16,; Ins'pection to Determine if-D
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a. Potential Seismic" Interaction Exists /Between?MovableTIncore Flux f
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Mapping Systems and Seal Table ~at; Westinghouse Designed Facilities or. -
Facilities with Similar Designs..1 This concern.was transmitted;tofall?
licensees in NRC -InMrmat' ion NoticeF85-45L ' The: licensee : determined >
that this concern was ; applicable to:Vogtlef and reported the Litem:per -
the requi.rements of 10 ~ CFR Part 2 211and ;10 ' CFR: 50.55(e).: The,~
D corrective actions.st1ted-in the constructionLdeficiency report L(CDR N 1 85-83) have been completed for ' Unit 1L LThe~ CDR? wast reviewed ~ ands d
closed for Unit 1 in i4RC l Inspection. Report,50-424/86-103.1iLicensee.
personnel stated that. thel corrstive.actionsT haveD:not-yet beeni completed-for Unit 2.. Therefore, this item' is considered closed ;for
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Unit 1 and remained open1for Unit 2..
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(Closed) TI 2515/69, Inspection; of Response: to :IEfBulletin 85-01.
Licensee actions concerning this: itemi are' documentedsin NRC:
M Inspection Reports 50-424/86-117 andi424/86-132.1 Licensee. actions?
d were considered adequate. This: item is closed for. Unit 1: only.t 7.
Outstanding Item List Status Update a.
(Closed) IFI 424/86-65-03, Review Final Resolution ~'MSIV Coil Failures 1
and Subsequent Retest.
Test procedure 1-500-04, Attachment'10.7.was s
performed in March 1987 to test closure:of the.MainiSteam Isolation.
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Valves '(MSIV) at normal operating :pressurec and temperature. EThej l
inspector reviewed the procedure and the' test results, f The closure i
time test results met the acceptance criteria for each MSIV.EIt was q
also observed thatisince' completion of ~ testing: and osubsequent' plant?
startup, the original problem with the valves chas been resolved, as evidenced by continued plant operation..
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