IR 05000424/1989010

Insp Repts 50-424/89-10 & 50-425/89-12 on 890218-0317. Violations Noted.Major Areas Inspected:Plant Operations, Radiological Controls,Maint,Surveillance,Security & QA Programs & Administrative Controls Affecting Quality

ML20245H596
Person / Time
Site:	Vogtle
Issue date:	04/11/1989
From:	Aiello R, Burger C, Patterson C, Rogge J, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20245H583	List: IR 05000424/1989010 ML20245H580 ML20245H589
References
50-424-89-10, 50-425-89-12, NUDOCS 8905030442
Download: ML20245H596 (19)

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NUCLEAR REGULATORY COMMISSION REGION 18

.[" . n 4 j 101 MARIETTA STREET, t ATLANTA, GEORGI A 30323

%...../ l Report Nos.: 50-424/89-10 and 50-425/89-12 Licensee: Georgia Power Company P.O. Box 1295 Birmingham, AL 35201 Docket Nos.: 50-424 and 50-425 License Nos.: NPF-68 and NPF-79 i

Facility Name: Vogtle 1 and 2 Inspection Conducted: February 18 - March 17,1989 Inspectors: O << - % _

&lo/39 Date Signed p J. F. Rogge, Senior Resident Inspector p;

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U C. W. Burger, Senior Resident Inspector ul- h ,

Date Signed

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hR.F.Aiello,Residentinspector v /o / n Date Signed D,. (2Am 4 /,, /s ,

C. A. Patterson Project Inspector (February 21-24) Date Signed i Approved By: W //[T(4 M. V. Sinkule, Section Chief Date Sign'ed Division of Reactor Projects SUMMARY Scope: This routine, unannounced inspection entailed resident inspection in the following areas: plant operations, radiological controls, maintenance, surveillance, security, and quality programs and administrative controls affecting quality. An in-office evaluation was conducted of the licensee performance since the last SAL Results: Two violations were identifie One violation in the plant opera-tions area - failure to maintain the emergency core cooling subsystems operable (paragraph 4). One violation in the quality program area - failure to follow procedure 85301-C for establishing quality control hold points (paragraph 2.b(7)).

One weakness was noted in the quality programs area regarding the quality centrol inspection program. The weakness is characterized as

', minimal quality control program which relies only on hold points 8905030442 890419

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- where failure to specify any hold points results in a loss of

inspection coverage (paragraph 2.b(7)).

The in-office evaluation of the licensee performance since last SALP indicated that a negative trend existed in the operation area as evidenced by the recent numbers of NRC and licensee identified violations which have occurred (paragraph 5).

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. -g REPORT DETAILS Persons Contacted Licensee Employees

• G. Bockhold, Jr. , General Manager Nuclear Operations R. M. Bellamy, Plant Manager T. V. Greene, Plant Support Manager

• J. E. Swartzwelder, Nuclear Safety & Compliance Manager

• W. F. Kitchens, Manager Operations

• M. A. Griffis, Maintenance Superintendent C. C. Echert, Manager Chemistry and Health Physics

• A. L. Mosbaugh, Assistant Plant Support Manager H. M. Handfinger, Assistant Plant Support Manager

• G. A. McCarley, ISEG Supervisor G. R. Frederick, Quality Assurance Site Manager - Operations W. E. Mundy, Quality Assurance Audit Supervisor R. M. Odom, Plant Engineering Supervisor C. L. Coursey, Maintenance Superintendent Other licensee employees contacted included craftsmen, technicians, supervision, engineers, operations, maintenance, chemistry, quality control inspectors, and office personne * Attended Exit Interview Operationd Safety Verification - (71707)(93702)

The plant began this inspection period with Unit 1 in Power Operations (Mode 1) at 74?? reactor power and Unit 2 in Refueling (Mode 6).

Unit I completed repairs of the "A" main feedpump and achieved 100?s power operation on February 20. The unit was operating at this power level at the end of the inspection perio Unit 2 entered Cold Shutdown (Mode 5) on February 19. On March 4, Hot Shutdown (Mode 4) was achieved. On March 8, Hot Standby (Mode 3) was obtai ned.. On March 9, following the determination of excessive primary isolation check valve leakage the unit declared a NUE and placed the unit in Mode 4 with Mode 5 obtained on March 10. The reactor was placed into mid loop operation until March 15 to conduct repairs to the primary check valves. On March 17, Mode 4 was again achieved, Control Room Activities Control Room tours and observations were performed to verify that facility operations were being safely conducted within regulatory I requirements. These inspections consisted of one or more of the l following attributes as appropriate at the time of the inspectio .

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Proper Cantrol Room staffing

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Control Room access and operator behavior

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Adherence to approved procedures for activities in progress

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Adherence to Technical Specification Limiting Conditions for Operations

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Observance of instruments and recorder traces of safety related and important to safety systems for abnormalities

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Review of annunciators alarmed and action in progress to correct

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Control Board walkdowns

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Safety parameter display and the plant safety monitoring system operability status

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Discussions and interviews with the On-Shift Operations Supervisor, Shif t Supervisor, Reactor Operators, and the Shift Technical Advisor (when stationed) to determine the plant status, plans, and to assess operator knowledge

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Review of the operator locs, unit logs and shift turnover sheets No violations or deviations were identifie Facility Activities Facility tours and observations were performed to assess the effectiveness of the administrative controls established by direct observation of plant activities, interviews and discussions with licensee personnel, independent verification of safety systems status and LCOs, licensee meetings and facility record During these inspections the following objectives were achieved:

(1) Safety System Status (71710) - Confirmation of system operabil-ity was obtcined by verification that flowpath valve alignment, control and power supply alignments, component conditions, and support systems for the accessible portions of the ESF trains )'

were prope The inaccessible portions are confirmed as availability permit Additional indepth inspection was performed to ensure containment cleanliness as it would impact ,

the operability of the RHR and CS systems ]

(2) Plant Housekeeping Conditions - Storage of material and '

components and cleanliness conditions of various areas throughout the facility were observed to determine whether safety and/or fire hazards existe (3) Fire Protection -

Fire protection activities, staffing and equipment were observed to verify that fire brigade staffing was appropriate and that fire alarms, extinguishing equipment, actuating controls, fire fighting equipment, emergency L equipment, and fire barriers were operabl j (4) Radiation Protection - Radiation protection activities, staffing j

! and equipment were observed to verify proper progran, implemen-tatio The inspection included review of the plant program i

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effectiveness. Ra'diation work permits and personnel compliance were reviewed during _ the daily' plant tours. Radiation Control Areas were observed to verify ' proper _. identification and

' implementatio (5) ~ Secur'ity -. Security controls were observed to' verify that security barriers were intact, guard forces were on duty, and access'to the Protected Area was controlled in accordance with'.

the facility security plan. _ Personnel were observed to verify proper display of badges and .that personnel requiring escort

'were properly escorte Personnel within Vital Areas were observed to ensure proper authorization for the are Equipment operability or proper compensatory activities were verified on a periodic basi '(6) Surveillance (61726)(61700) - Surveillance tests were observed

~ to . verify that . approved . procedures were being used; qualified personnel were. conducting the tests; tests were adequate to verify equipment operability; calibrated equipment was utilized; and TS requirements were followe The inspectors observed portions of the following surveillance and reviewed completed data against acceptance criteria:

Surveillance N Title 14825-1 Rev 10 Monthly RCS valve Inservice test 14803-1 Rev 4 CCW pump discharge check valves Inservice test 14903-2 Rev 0 Containment emergency sump inspection 14235-2 Rev 1 Onsite power distribution operabil verification 14750-2 Rev 1 18 month, rod position indication operability test 14485-2 Rev 0 Monthly containment spray system flow ,

path verification 14900-2 Rev 0 Containment exit inspection 14225-2 Rev 2 Weekly borated water source concentration, volume and temperature verification during cold shutdown and refueling conditions L___ b - __ ________ _ _ _ _ _ _ _____ ___ _ _ __________ _ _ _

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14230-1 Rev 4 Weekly train "A" and "B" verification-offsite to onsite class IE AC distri-bution system circuit breaker align-ments mode'1-4 14220-1 Rev 3 Main turbine valves weekly stroke test

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14710-2 Rev 3 Remote shutdown panel transfer switch l and control circuit 18 month surveil-lance (7) Maintenance Activities (62703) -

The inspector observed maintenance activities to verify that correct equipment clearances were in effect; work requests and fire prevention work permits, as required, were issued and being followed; quality control personnel were available for inspection activities as required; retesting and return of systems to service was prompt and correct; TS requirements were being followed. Maintenance Work Order backlog was reviewe Maintenance was observed and work packages were reviewed for the following maintenance activities:

i MWO N Work Description 2890153 Rotate spectacle flanges to the open position on lines 2-1228-167-2 and 2-1228-174-2 (reactor makeup water system)

28901631 Replace escutcheon plate on the main turbine turning gear oil pump due to improper flag indication when the I switch is open 18901156 Replace the bearings and belt on the containment spray

"B" pump room cooler fan moto On March 6 while observing the performance of MWO 18901156, repair of CS pump "B" room cooler fan, the NRC inspector noted that there were no quality control observations being performed 1 during the bearing and belt replacement on this safety related j system. This was discosared when the inspector was reviewing {

the nuclear operations quality control hold point sheet. The NRC inspector further noted a complete absence of mechanical QC hold points on the hold point sheet (85301-C Figure C) which was i included as part of the work package. This concern was brought j to the attention of the mechanics working on the system at the !

time. They stated that when they got to the point where QC was to verify torquing of any 1E components, they stopped and notified them. At this point they were ready to torque in the inner bearing race set screws. A mechanical QC inspector went down to the job site and stated that all the QC hold points were q l

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electrical hold' points only, therefore, no observations were I re' quired. - The mechanical QC inspector. had an opportunity but did not recognize the lack of quality control attention neede ~

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l, l He ' could have exercised his "Ste- Work Authority'.' . until the proper. QC hold points were incorpc ated into- the work' packag The NRC inspector notified the' SS who 'in turn temporarily

. terminated the work. The QC supervisor, OSOS, two QC inspectors

and the resident inspector met in the NRC's Res.idents Office and

, attempted to' resolve the issue. A second opportunity arose'to correct this' problem before it became an issue, however, the QC.

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, supervisor was adamant and insisted that the QC paperwork was-The licensee made the decision to complete 'the work'

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correc under the existing MWO package. On the following day,. the QC E manager met with the NRC inspector. It was determined then that the QC portion of the work package was incomplete in that QC-shoulc' have been more involved with this safety related maintenance job. 'It appears that the nuclear safety concerns do not precede the job task at. hand. It was further discovered that work. planning and quality control have different views with respect to the- scope and boundaries of IE components. -This constitutes a violation of NRC requirement '

10 CFR Part 50, Appendix B, Criterion X, and the licensee's accepted QA program, Final Safety Analysis Report (FSAR) Section 17.2.10 requires that a - program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance wIth the documented instructions, procedures, and drawings for accomplishing the activity. ANSI N45.2.8, 1975 committed to in INAR chapter 1/.2.10 states that checks and inspections shall be parformed to verify the operational readiness . and completeness c f components and systems. Plent procedure, Work Planning and'

bid Point Assignment (85301-C), implements the inspection activities by providing for the establishment and control of Quality Control hold points in work activitie Procedure step 5.1.4 requires hold points for torquing and alignment items. This item is identified as violation 50-424/89-10-01

" Failure. to follow procedure 85301-C for establishing quality control hold points."

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As a result of the above violation, the inspector discussed with the Quality Assurance Site Manager the role of Quality Control as described in FSAR 17.2.10. This FSAR section des. ribes the quality control inspection progra The seventh paragraph states in part, that:

Quality control personnel have written stop-work authority, including the authority to prevent equipment or systems from being returned to service if the activity was not performed in accordance with an approved procedure, specification, or drawin If specified inspection hold points / witness points, requiring witnessing or inspecting by an inspector and beyond which work is not to proceed

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without inspector approval, are necessary, the specific ]

hold points will be indicated in the work procedure. If at '

these checkpoints the activity is found to be unsatisfac-tory, further processing of the activity -is suspended until the problem is resolve The inspector questioned the rule of QC in verifying that the work was performed in accordance with approved procedures when they appeared to be present only at the hold point The i

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inspector's position was that QC personnel should be following maintenance as it progresses, documenting inspections and/or observations and utilizing stop work authority as necessar Since QC cannot be continuously present, the'use of hold points is an additional control of the work not the only contro The licensee response was that this paragraph has never been

~ l interpreted bv the utility in this manne The inspector concluded that the disengagement of QC from the work process by the sole use of hold points is a weakness in that it dilutes the ability of QC to provide independent review and exercise their stop work authority. Additional attention to the proper application of QC holds points will be noted during future NRC inspections to determine if the conditions in the above citation represent an isolated weakness or are more generi l Review of Licensee Reports (90712)(90713)(92700) In-Office Review of Periodic and Special Reports This inspection consisted of reviewing the below listed reports to determine whether the information reported by the licensee was technically adequate and consistent with the inspector knowledge of the material contained within the repor Selected material within the report was questioned randomly to verify accuracy and to provide a reasonable assurance that other NRC personnel have an appropriate document for their activitie Monthly Operating Report - The report dated February 10, 1987 was reviewed. The inspector was informed that data in the report would be corrected in the March submittal, Licensee Event Reports and Deficiency Cards Licensee Event Reports and Deficiency Cards were reviewed for potential generic impact, to detect trends, and to determine whether corrective actions appeared appropriate. Events which were reported pursuant to 10 CFR 50.72, were reviewed as they occurred to determine  ;

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if the technical specifications and other regulatory requirements were satisfie In-office review of LERs may result in further followup to verify that the stated corrective actions have been

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completed,'or to identify violations in addition to those described in the LE Each LER is reviewed for enforcement ' action in accordance with 10 CFR Part 2, ; Appendix Review of DCs was performed to maintain a realtime -status of deficiencies, determine regulatory compliance, follow the licensee corrective actions, and assist - a's a basis for closure of the LER when reviewed. Due to tne numerous DCs processed only those DCs which result in enforcement action or further inspector followup with the licensee at the end of the inspection are listed below. The LERs and DCs denoted with an asterisk indicates that reactive. inspection occurred at the time of the event prior to receipt of the written repor (1) Deficiency Card reviews:

DC 1-89-473 " Missed Room Temperature Surveillance On FHB Room B 008." On February 16, the licensee identified that the previous evening shift had failed to perform the TS 3.~.10 required temperature surveillanc Room temperature at the time of-discovery was found within specificatio This item will be

'further reviewed when submitted as a LE *DC 1-89-527/2-89-444 "TDAFW Breakers Wrong Size." On February 23, the licensee identified that breaker 1CD1M01, ICD 1M02, ICD 1M03, and ICD 1M04 were sized as 15A thermal magnetic trip instead of 30 Design criteria 1823 specifies the 30A size breake This deficiency. pertains to the 125V DC breakers for the TDAFW pump valves 1-HV-5120,1-HV-5122,1-HV-5125, and 1-HV-512 Discovery of this issue resulted from investigation of the Unit 2 problem. This item will be further reviewed when submitted as a LE DC 1-89-531 " Inadequate Test Leads To Improper Termination Of Limiting Condition For Operation." On January 30, 1989, the Gaseous Waste Processing System's Outlet Oxygen Analyzer, IARC-2119, failed to pass TS 4.3.3.10 surveillance requirements.

l A Limiting Condition for Operation was entered which requires

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grab samples to be taken and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. A micro fuel cell in the analyzer was replaced, tested, and the LCO was terminated on February 7,1989. On February 23, a review of the work order discovered that the LC0 had been L discontinued and the equipment placed in service even though a complete surveillance test of the analyzer had not been performed to verify that the surveillance requirements were me An LCO was entered, a surveillance test satisfactorily I completed, and the LCO was terminated. This event will be further reviewed when submitted as a LE *DC 1-89-555 " Failure To Close RMWST Discharge Valves." On February 19, the licensee identified that the two RMWST discharge valves were not locked closed as required by TS 3.4.1. The operators complied with the action statement to i

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I immediately close the_ valves. . Plant personnel failed to understand the meaning of " Loops F111ed as applied in the T This item will be further reviewed when submitted as a LE DC 1-89-631 "Co'ntainment Ventilation Isolation Due To:

Containment- Area Low Range Radiation Monitor, '1RE-003, Spike."

Unit 1. was operating at full . power when a spurring high alarm was received on containment _ area low range radiation monitor 1RE-003. This caused a ' containment ventilation isolation. The radiation containment area low range radiation monitor, 1 RE-003, indicated normal radiation levels. before and after the event. This item will be further reviewed when submitted as a LE DC 1-89-748 "RHR Return Isolation Valves To RWST, Open While In Mode 3." See violation 50-424/89-12-01, paragraph 4 for

' detail DC 1-89-749 " Excessive RCS Leakage." The loop 3 cold . leg injection check valve (2-1204-U6-083) failed a surveillance leakage check - required prior to entering Mode The TS requirement is 4.4.6.2. This is a 10 inch swing check valve manufactured by Westinghouse. The three other lines success-fu11y1 passed the leakage -requirement and all valves had previously passed during hot functional testing in October-198 The check valve leakage test is conducted by isolating other lines not being tested and measuring by a flow element in a test line connected back to the RWST. The valve was disassembled and wear was found near the pivot pin which allowed the disc to drop down and not seat properly. The valve consists of a' disc with two arms which insert into a lock block. The pivot pin goes into the lock bloc The disc arms are notched our for alignment with the pivot pin. Wear was'found on both notches in the arms which allowed the . disc to drop down. The licensee l: plans to perform testing of the valve material and is consider-ing a possible Part 21 report. The other valves are also being ]j L checked. This item will be further reviewed when submitted as a LE !

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[ (2) The following LERs were reviewed and closed.

l (a) 50-424/87-64, Rev. 0 " Auxiliary Feedwater Pump Actuation l Following A Condensate Pump Work Activity." On November 5, 1987, with Unit 1 in Mode 3, an auto-start signal was initiated for the motor driven auxiliary feedwater pumps when an operator, performing a clearance of a standby '

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condensate pump inadvertently operated the wrong handswitch on the local condensate valve control panel. The discharge valve for the operating condensate pump closed which caused a trip of a noin feedwater pump on low suction pressur The labels on the local condensate control panel 1 i o _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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l: , contributed to the cause 'of this event. The labels were modified for this local panel and a review will be performed ~ of other remote -panels to identify if similar .

labeling modifications are needed. The inspector reviewed documentation which' indicated that the corrective' action j' was complete.

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(b) *50.424/87-69, Rev. 1 " Operating Above The Maximum. Power Level Specified 'In Operating License." This item was inspected in NRC Rpt. 50-424/87-63 and 50-424/88-06. T he'

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inspector reviewed implementation of the corrective action

! listed in the supplement repor (c) 50-424/87-74, Rev.'O " Technical Specification Violation When Core Exit Thermocouple Not Declared Inoperable."- On October 6, 1987, the' licensee identified that a-maintenance work order had been written on April 13, 1987, to verify that the thermocouple junction boxes were properly sealed '

to address a lack of documentation concern. The October 6, 1987 deficiency was then processed without recognition of the impact on Technical Specification requirements. The sealing was performed on October 18,1987. - On December '18, 1987, the site determined that this item was reportable during the review of the October 6,1987 deficiency. Two corrective actions are being implemented to correct these types of breakdowns. The first is a training program called " Commitment to Safety" which was~ completed. This

' training is unique ' in the fact' that corporate and site managers were making the presentation Feedback from personnel attending the sessions indicates that the training 'may have a more long term payback as personnel implement the ideals of the training. The inspector viewed a video tape of the training. The second corrective action was to expedite the review process. The' inspector reviewed documentation of training and procedure 0150-C revision In addition, MWO 2-88-09717 ensured that the condition does not exist on Unit This item has previously been identified as a violation (NRC Rpt. 50-424/87-69-01).

(d) 50-424/87-77, Rev. O " Missed Surveillance Due To Personnel Errors." Three Technical Specification surveillance events described below were not considered to be reportable at the times of their discoveries and were only recognized as such following an NRC violation. On April 3,1987, it was discovered that the surveillance for device type 43 - General Electric 400 amp current breakers had not been performed as required by TS 4.8. Subsequent testing was satisfactorily completed on April 6, 198 On May 21, 1987, it was discovered that a ,

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l surveillance of a gas decay tank had not been performed as required by TS 4.11.2.6. The taik was sampled with three hours of discovery and found to be within limits. On July 23, 1987, while preparing for a reactor startup, it was discovered that no documented evidence existed for a

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required surveillance for the previous reactor startup on July 12,1987 as required by TS 4.2.1.1. Methodology has been developed and included in Procedure 35430- Procedure 13201-1, " Gaseous Waste Processing System" and 35430-C have also been revised to improve communications between Operations and Chemistry. Licensed Operators have been counseled to ensure required surveillance are complete A requirement has been to Procedure 00057-C, that requires a check of the mode deferred binder to ensure required surveillance have not been misse (e) 50-424/87-79, Rev. O " Missed Surveillance Due To Component Failure Caused By Overtorquing." The missed Technical Specification Surveillance described below was not considered reportable at the time of discovery and was only recognized as such following an NRC violation. On May 26, 1987, a Technical Specification 4.11.2.6 sampling of a waste gas decay tank- could not be obtained because of no sample flow to the sampling hoo While performing maintenance on the Gaseous Waste Sample Outlet Header Isolation Valve, the valve was found in the closed position while the reach-rod indicated open. The valve disc was found wedged into the seat. The valve failed because there was no requirement to set the torque on the reach-rod clutch. This condition allowed the disc to be wedged into the seat when the valve was closed. Corrective action for this event was the initiation of a program, under Procedure 27541-C, " Installation Maintenance And Setup Of Reach Rod Assemblies" to set torque values for reach-rod clutches and to ensure open and closed position indications are correc . In9erable Residual Heat Removal System - (93702) Unit 2 On March 8, 1989 during initial startup, the RHR system was placed on recirculation for system cool down and depressurization. The Unit then entered Mode 3 and began the preparation for performing the required leak test on the RHR primary RCS pressure isolation check valves. The sequence of events which transpired caused a NUE to be declared for leakage in excess of TS limits, the confirmation that both trains of RHR were inoperable and subsequent plant cooldown to Mode The following is a chronology of those events:

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ChronologycfEventh

3-8-89 7:00 PM : RHR System Placed On Recirculation; In Process Of Cooling System Down 8:00 PM : Unit 2 Entered Mode 3 11:55 PM : RCS Temperature At 445 F; Pressure' AT 900 psig; RHR-System Still Cooling Down; Pressure Approximately 200 psig 3-9-89 3:30 AM : Preparing To Perform Leak Test On Primary Check Valves; RHR Needs To Be Depressurized For Test Run 3:50 AM : SS Has PE0 Open Locked ~ Closed Valves '-1205-U6-027 And 2-1205-U4-226 (RHR 8" Return Line To .WST); SS Intent Is To Open Valves For A Short Time And Reclose In Order To Relieve Pressure; PE0 Understood The Instructions To Be, Open Valves And Leave Them Open 4:00 AM : Second PE0 Independently Verifies Valves.To Be Open; Second PE0 Also' Believes Valves Are To Be Left Open;

.RHR Does Depressurize 6:30 AM : Shift Turn Over Occurs; Discussion Of Frequent VCT '

Make-up, Attributed To Leaking Seal Return Filter An Letdown RCS Filter; Previous Leakage Assessments Indicated Approximately 3-4 GPM From Filter Drain Valves (From 4:00 AM - 6:20 PM VCT Was Making Up Every 60-90 Minutes)

8:00 AM : R0 Talks To Rad Waste Supervisor Concerning Filter Leakage; And Requested To Investigate 11:50 AM : Leak Test For Primary Check Valves (2-'1204-06-083, 084, 085, & 086) Started 1:30 PM : Preliminary Leak Test Results Indicate 2-1204-U6-085 May Be Leaking In Excess Of TS Limits; Verification /

Validation Commencing; Plant Management Review Starts; Water Balance Begins 2:30 PM : NSAC Manager Discusses Preliminary Results With Residents; Retest Along With Rough RCS Water Balance In Progress 4:15 PM : Leak Test On 2-1204-U6-085 Retest Commenced; Rough RCS Water Balance Indicated Approximately 7 GPM Leakage 4:50 PM : Leak Test On 2-1204-06-085 Results Confirmed; NUE Declared (Approximately 25 GPM Leak)

5:00-6:00 PM: Discussion Of Potential Leak Paths For 7 GPM Leak; RWST Noticed To Have Been Increasing; Leakage Through 2-1205-U6-027 And 2-1205-U4-226 Considered A Possibility; Confirmation Commenced l

6:07 PM : Valves Found Open; 3.0.3 Entered; Declared Both RHR Trains Inoperable 6:20 PM : Valves Closed; 3.0.3 Exited; RHR Test Lines Opened To Prevent RHR Pressurization; Both Primary And Secondary Check Valves (2-1204-U6-086 and 2-1204-U6-149) Must Be Leaking; Cooldown To Mode 5 Will Occur 11:42 PM : Entered Mode 4

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i 3-10-89 3:31 AM : Entered Mode 5 ,

7:30 AM : NSAC Manager Briefs Residents Of Status Including-Discovery Of Open RHR Return Lines 10:00 AM : Discussion Of RHR Operability During Check Valve Repair (ie With HV-8809A or B Shut); i 5:00 PM : Decision Made To Consider Both Trains Operable Since !

Without Decay Heat The "B" Pump Can Be Brought Into l Service, With Any Single Failure In Time To Provide A '

Heat Sink 7:00 PM : Discussed Position With NRR Project Manager The inspector reviewed the appropriate procedures relating to this event and determined that: Procedure 11011, " Residual Heat Removal System Alignment,"

requires valves "RHR Test Recirculation To RWST" 1205-06-027 and 1205-U4-226 to be locked close Procedure 13011, " Residual Heat Removal System" (Standard Operating Procedure), requires RHR Test Recirculation RWST valves 1205-U6-027 and 1205-U4-226 to be locked closed with '

independent verification require P&ID Drawing 2X4DB122 " Residual Heat Removal System No. 1205" shows the Test Recirculation RWST valves to be locked close ! Procedure 14450, "RCS Pressure Isolation Valve Leak Test" does not provide guidance on how to depressurize the RHR system nor does it state that the RHR system needs to be depressurize In addition, the inspector reviewed the Unit 2 Locked Valve Manipulation Log to determine if other examples existed of possible manipulation of valves 2-1205-U6-027 and 2-1205-U4-22 It was determined that 6 entries had been made since setting the head on February 18, 1989. Examples of the reason given for manipulation were to lower RCS level, depressurize RCS, and recirculation to RWST. The Unit 1 Lockert Valve Manipulation Log was also reviewed. No manipulations of these valves for Unit 1 existed since the last refueling outag At present, the only time these valves are authorized for use (open) is for draining the refueling cavity, RHR System Declared Inoperable ,

i Both trains of the RHR system were declared inoperable when RHR Test Recirculation To RWST valves 2-1205-U6-027 and 2-1205-U4-226 were found open. With these valves in the open position, the required RHR system injection flow rates to the cold legs would not be obtained as stated in the Safety .

Analysi The inspector determined that these valves had been l l

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in the open position for a total time duration of approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> and 30 minute NUE Declared Upon confinnation that the 10 inch RCS pressure isolation check'

valve 2-1204-U6-085 was leaking--in excess of its TS leakage l limit a NUE was declared. The NUE was declared based on the i Vogtle Emergency Plan which requires that a NUE be declared when-RCS leak rates per TS 3.4.6.2 are exceede The amount of leakage from check valve 2-1204-06-085 to the RWST was determined to be approximately 25 GPM (TS limit is 5 GPM).

The amount of leakage from the secondary 6 inch check valve 2-1204-06-149 to the RWST was determined to be approximately 7 GPM (TS limit is 3 GPM). The plant was subsequently shutdown to repair the leaking valve Based on this inspection, the following conclusions are presented

regarding the opening of the RHR test recirculation to RWST valves 2-1205-06-027 and 2-1205-U4-226: The controlling procedure (14450) in use at the time the locked valves were opened did not address depressurization of the RHR system. Therefore, depressurizing the RHR system was apparently left up to the discretion of the on shift operations staf These safety related valves are required by procedure to be locked closed (except in the instance of draining the refueling cavity) and yet they were intentionally opened without justificatio Review of the Locked Valve Manipulation Log also indicates that indiscriminate use of these valves may be occurring, The opening of these valves provided an additional 8 inch diameter flow path, returning to the RWST, thereby rendering both trains of the RHR system inoperable which is in direct violation of TS 3. The RHR system was then unable to provide the required postulated flow rates to the core as necessitated by the safety analysi l The safety significance presented by this event is much less than if it had occurred following criticality and subsequent power operatio Specifically, since the core had never been critical, no decay heat existed. Therefore, there was probably little, if any, safety significance pertaining to this even However, the concern was that operations supervision directed that locked safety-related valves be manipulated without the benefit of approved procedure _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _

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This event is identified as violation- 50-425/89-12-01, " Failure To Maintain Two Independent Emergency Core Cooling Subsystems Operable As Required By TS 3.5.2."

,, 5. Licensee Quality Assurance Program Implementation (35502)

An in-office evaluation was conducted of the licensee's QA'__ program '

implementation by reviewing recent inspection reports, SALP reports, open items, licensee corrective actions for NRC inspection findings and LER Particular emphasis was placed on all new items since the last SALP period of October :, 1987 - September 30, 198 There appeared to be one negative trend within the SALP functional category of operations. Three level four violations have been identified (424/88-44, 424/88-56, and 424/88-61) and a number of licensee identified violations in this SALP area. The NRC violations concerned logkeeping for-the diesel generators, cleanup of containment,.and operability of control room chart recorders. Additionally, two _ violations from .the NRC Operational Performance Assessment Team Inspection (88-33) were denied and subsequently sustained by the NRC, Although the Unit I refueling outage overall was viewed favorably, a weakness by operations in recovery from the' outage was noted. The violation concerning cleanup of containment and failure to place the AMSAC equipment in operation as required by plant procedures at 60% power are examples of this outage recovery weaknes Additional management attention is warranted to reduce the number of future violation The review of LERs revealed several radiological monitor isolations which might have been eliminated by installing static transfer switche Apparently, momentary. power supply interruptions during test switch manipulations may be causing these isolation The LERS were '87-05, 88-03, 88-35, and 88-39. One LER stated that the switches were on-order with final installation scheduled for the next refuelin Prompt resolution of this problem may preclude repeated isolation problem '

6. Management Meetings - (30702)

This activity involves inspector participation and preparation in support of the following meeting which presented site readines l On February 24, 1989, Commissioner Kenneth C. Rogers visited the Vogtle I Site to review the Unit 2 Licensing readiness, discuss pertinent issues, and tour the Unit 2 facility. The Commissioner presented his comments to the licensee's management at the end of the visi l The following NRC Personnel were present: l i

j K. C. Rogers - Commissioner l M. L. Ernst - Acting Regional Administrator, RII J J. C. Scarborough - Technical Assistant to the Commissioner i

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J. F. Rogge - Senior Resident Inspector l C. W. Burger - Senior Resident Inspector i R. F. Aiello - Resident Inspector ' Startup Test Program Implementation / Verification - Unit 2 (72302)(72400B) !

The - inspector reviewed the present implementation of the Startup Test Progra Inspected Test Program attributes including review of administrative requirements, document control, documentation of major test events and deviations to procedures, operating practices, instrumentation calibrations, and correction of problems revealed by testin Periodic facility tours were made to observe Startup Test activities in progress. The inspector verified that procedural prerequisites and initial conditions were me Verification was performed by the inspector's review of records (valve lineup sheets, test equipment calibration status, system status checklists, or appropriate sign-offs listed in procedure were maintained current) or by direct observation (monitoring instrumentation indications, valve positions, equipment position switches or personnel actions). Discussions were held with responsible personnel, as they were available, to determine their knowledge of the Startup Test Program. Schedules for Startup Test Program completion and progress reports were routinely monitore Specific inspections conducted are listed below:

Precritical Startup Test Sequence (72509)

The precritical startup test sequence directing the test activities as contained in procedure 2-500-04 was reviewed during testin The following specific tests were partially witnesse (a) 2-5SE-02 Operational Alignment of the Nuclear Instrumentation Syste (b) 2-5SF-03 Control Rod Drive Mechanism Operational and Rod Position Indication Tes (c) 2-5SF-04 Rod Drop Time Tes No violations or deviations were identifie ! Actions on Previous Inspection Findings - (92701)(92702)  !

(Closed) Inspector Followup Item 50-424/88-43-02 " Review Licensee !

Corrective Action For Installation Of Flow Elements." Licensee maintenance procedure 25240-C, Rev. 3 " General Bolted Flange Torquing And Installation Of Flow Elements Procedure" was revised to verify that flow elements would be installed properl The inspector verified the procedure revision and reviewed MWO 1-88-06684 which corrected the direction of the orific )

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16 Exit Interviews - (30703)

The inspection scope and findings were summarized on March 20, 1989 with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection result No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection. Region based NRC exit interviews were attended during the inspection period by a resident inspector. This inspection closed one Inspector Followup Item, and five Licensee Event Report The items identified during this inspection were:

Weakness in the operations area (paragraph 5) and quality programs area (paragraph 2.b.(7)) were discusse Violation 50-424/89-10-01 " Failure to follow procedure 85301-C for establishing quality control hold points." paragraph 2.b.(7).

Violation 50-425/89-12-01, " Failure To Maintain Two Independent Emergency Core Cooling Subsystems Operable As Required By TS 3.5.2." paragraph . Acronyms And Initialism AMSAC ATWAS Mitigating System Actuating Circuitry ANSI American National Standard Institute CCW Component Cooling Water System CFR Code of Federal Regulations CS Containment Spray System DC Deficiency Cards ESF -Engineered Safety Features FHB Fuel Handling Building  ;

FSAR Final Safety Analysis Report GPM Gallons per Minute HV High Voltage  !

ISEG Independent Safety Engineering Group LCO Limiting Conditions for Operations LER Licensee Event Reports MWO Maintenance Work Order i NPF Nuclear Power Facility NRR Office of Nuclear Reactor Regulation

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NRC Nuclear Regulatory Commission

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NSAC Nuclear Safety and Compliance i

NUE Notice of Unusual Event OSOS On Shift Operation Supervisor j PE0 Plant Equipment Operator QA Quality Assurance QC Quality Control RCS Reactor Coolant System RHR Residual Heat Removal System

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RMWST Reactor Makeup Water Storage Tank RWST Refueling Water Storage Tank R0 Reactor Operator SALP Systematic Assessment of Licensee Performance SS Shift Supervisor TDAFW Turbine Driven AFW Pump TS Technical Specification VCT Volume Control Tank

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