IR 05000498/1990008

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Insp Repts 50-498/90-08 & 50-499/90-08 on 900201-28. Violations Noted.Major Areas Inspected:Plant Status,Onsite Followup of Events,Operational Safety Verification,Esf Sys Walkdown & Monthly Maint & Surveillance Observations
ML20012C794
Person / Time
Site: South Texas  
Issue date: 03/16/1990
From: Skow M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20012C792 List:
References
50-498-90-08, 50-498-90-8, 50-499-90-08, 50-499-90-8, NUDOCS 9003230226
Download: ML20012C794 (13)


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APPENDIX B

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U.S. NUCLEAR REGULATORY COMMISSION l

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REGION IV

NRC Inspection Report:

50-498/90-08 Operating License:

NPF-76 50-499/90-08 NPF-80

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L Dockets:

50-498

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50-499

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Licensee: Houston Lighting & Power Company (HL&P)

P.O. Box 1700 p

Houston, Texas 77251 Facility Name:

South Texas Project (STP), Units 1 and 2

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Inspection At:

STP, Matagorda County, Texas Inspection Conducted:

February 1-28, 1990

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I Inspectors:

J. I. Tapia, Senior Resident Inspector, Project Section D Division of Reactor Projects R. J. Evans, Resident Inspector, Project Section D Division of Reactor Projects

Approved:

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.5/N/10 M. E. Skow, Acting Chief, Project Section D Date Division of Reactor Projects

DaInspectionSummary

$o Inspection Conducted February 1-28, 1990 (Report 50-498/90-08: 50-499/90-08)

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Mo Areas Inspected:

Routine, unannounced inspection which included plant status, 80-onsite followup of events at operating power reactors, operational safety SO verification, engineered safety feature system walkdown (Unit 2 component ox cooling water system), monthly maintenance observations, and monthly No surveillance observations.

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N Results: Within the areas inspected, two violations were identified. The

$c-first violation (cited) involved the failure to fully implement surveillance g@g requirements established by Technical Specification (TS) 4.7.3.a (paragraph 5).

The second violation (noncited) involved the failure to follow a safety-related procedure (paragraph 7). A walkdown of the Unit 1 and Unit 2 supplementary containment purge systems was performed and all components were noted to be in

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positions required to support plant operation (paragraph 4).

An engineered

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safety feature (ESF) walkdown was performed on the Unit 2 Component Cooling l

Water (CCW) system, and all CCW components were found in position to support plant operation. Additionally, housekeeping was being maintained in the areas

inspected and the system piping and instrument diagrams (P& ids) were noted to

be higher than normal quality (paragraph 5). Three maintenance tasks were

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observed with no violations identified (paragraph 6).

Four surveillance tasks

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were observed with one noncited violation being identified (paragraph 7).

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DETAILS 1.

Persons Contacted

  • G. E. Vaughn, Vice President, Nuclear Operations
  • W. H. Kinsey, Plant Manager
  • A. C. McIntyre, Manager, Support Engineering
  • D. J. Clifford, Manager, Support Construction
  • W. J. Jump, Maintenance Manager
  • D. J. Denver, Nuclear Engineering Manager
  • M. R. Wisenburg, General Manager, Assessment
  • T. J. Jordan, General Manager, Nuclear Assurance
  • A. W. Harrison, Supervisor, Licensing Engineering
  • J. R. Lovell, Technical Services Manager
  • D. A. Leazar, Plant Engineering Manager
  • J. W. Loesch, Plant Operations Manager In addition to the above, the inspectors also held discussions with various licensee, architect engineer (AE), maintenance, and other contractor personnel during this inspection.

' Denotes those individuals attending the exit interview conducted on March 2, 1990.

2.

Plant Status Unit 1 operated at essentially 100 percent reactor thermal power throughout this inspection period. There were no unplanned plant evolutions during this inspection period.

Unit 2 began this inspection period'at 100 percent reactor thermal power.

On February 2, 1990, the unit tripped when a reactor trip breaker unexpectedly opened. Af ter a post-trip investigation, the unit was again brought to 100 percent power on February 7, 1990.

Unit 2 remained at 100 percent reactor thermal power level through the end of the inspection period.

3.

Onsite Followup of Events at Operating power Reactors (93702)

On February 2, 1990, at 2:59 a.m, Unit 2 tripped from 100 percent power when the Train S reactor trip breaker spuriously opened. As a result of the breaker opening without receiving a reactor trip signal from the Solid State Protection System, a turbine trip was initiated from Lo-Lo turbine

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electro-hydraulic control header pressure. The turbine trip initiated a j

reactor trip since power was above the P-9 setpoint. A feedwater isolation occurred on low average reactor coolant system (RCS) temperature and an auxiliary feedwater system actuation occurred on low steam generator level as expected. The main steam isolation valves were closed to limit RCS cooldown and the plant was then stabilized in Mode 3 (Hot

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Standby).

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Subsequent troubleshooting was performed to determine the cause of the event. The Train S reactor trip breaker was subjected to thermographic inspection. The Westi v ause Universal Logic Cards and their power supplies in the solid state protection system were also inspected.

Inspections for loose connections and for conformance with schematic diagrams were also conducted.

No inspection results were identified which would have resulted in the spurious opening of the trip breaker.

Additional troubleshooting was implemented to attempt to identify external conditions which could have initiated the spurious opening of the reactor trip breaker. These inspections included subjecting the Universal Logic Cards to heat, cold, and vibration and to ambient radio frequencies.

No problem was noted with the equipment during these tests.

Although no specific condition was identified as being the cause of the

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spurious opening of the reactor trip breaker, the licensee replaced the 15 Train S Universal Logic Cards associated with the reactor trip function.

This action was taken because three cards showed higher than average AC ripple voltage when the cards were subjected to cooling. The significance i

of this higher than average noise level has not been determined.

Each of the removed logic cards has been sent to Westinghouse for further investigation. The results of the investigation were not available at the close of this inspection period.

Secondary plant systems functioned properly during the trip with the exception of the following items:

Steam Dump Valve PV7494 failed open, Main Steam Train A Above Seat Drain Valve FV7900A lost position indication, main turbine auxiliary lube oil pump failed to start automatically, and Charging Flow Control Valve FCV-205 failed open and would not close using the controller. The reactor operators correctly

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responded to each of these malfunctions.

Steam Dump Valve PV-7494 was appropriately isolated which prevented a possible excessive cooldown of the primary system.

Reactor plant operators were dispatched locally to effect the required actions when needed.

None of the secondary system nalfunctions caused the reactor operators additional difficulties which prevented them from maintaining the plant in a safe and normalized condition.

The licensee subsequently generated a temporary modification to install instrumentation to monitor the reactor trip breaker.

The parameters to be monitored include the undervoltage trip device and the shunt trip coil.

This instrumentation should help the licensee to identify any future spurious signals which may cause a reactor trip breaker trip to occur.

4.

Operational Safety Verification (71707)

The purpose of this inspection was to ensure that the facility was being operated safely and in conformance with license and regulatory requirements.

This inspection also included verifying that selected activities of the licensee's radiological protection program were being implemented in conformance with requirements and procedures, and that the licensee was in compliance with its approved physical security plan.

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-5-The inspectors visited the control rooms on a routine basis and verified that control room staffing, operator decorum, shift turnover, adherence to TS limiting conditions of operation (LCOs), and overall control room decorum were in accordance with requirements.

The inspectors conducted tours in various locations of the plant to observe work operations, and to ensure that the facility was being operated safely and in conformance with license and regulatory requirements.

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The supplementary containment purge systems (HC) were inspected for both units to verify the operability and status of each system.

The inspection included comparison of as-found control switch, power supply breaker, and valve positions to those required by the operating procedures.

A comparison of the operating procedures to design documents, including P& ids, was also performed. The HC system procedures reviewed and walked down included:

IPOP02-HC-0003, Supplementary Containment Purge, Revision 6

2 POP 02-HC-0003, Supplementary Containment Purge, Revision 1 Items noted during a technical review of the procedures included (unless specifically noted, the items observed applied to both procedures):

The reference section for each of the above procedures (Section 2.0)

did not' identify an applicable P&ID and TS section.

P&ID SV149V00018 #1 (for Unit 1) and #2 (for Unit 2), Reactor Centainment Building Normal Purge Subsystem, showed valves on the P&ID that were listed in the procedure valve lineup. TS 3.6.1.4, " Primary Containment Internal Pressure," requires that the primary containment internal pressure be maintained between -0.1 to +0.3 psig in Modes 1, 2, 3, and 4.

  • Valves that are required to be locked in position (open, closed, or throttled) are identified as such on the system P& ids using status symbols such as LO (locked open), LC (locked closed), and LIP (locked in place). However, System Valves HC-0015 through HC-0022 were required to be LO or LC, but the associated P&ID did not identify the valves as locked valves.
  • The power supply for the nonsafety-related Flow Modulation Damper FV-9594, was missing from the Unit 2 procedure power supply checklist. The power supply was found to be in the correct position to support plant operation.

Items observed during the walkdown of the system using the operating procedure and P& ids included:

The valve locations (elevation levels) listed in both valve lineups were incorrect for Test Connection Valves HC-013 and HC-014. The indicated location of the power supply for the Unit 1 Flow Modulation Damper FV-9594 was incorrect (wrong building).

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Nonsafety-related Instrument 1-PDISH-9725 appeared to be improperly

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set. The required setpoint was 2.5 plus or minus 0.08 inches water column (w.c.).

The Instrument 1-PDISH-9725 was found set at 4.0 inches w.c., a value above the allowable setpoint tolerance.

The Unit 2 Instrument 2-PDISH-9725 was found correctly set at 2.5 inches w.c.

1-PDISH-9725 monitored the supplementary purge supply unit

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differential pressure, and would actuate a computer alarm on high differential pressure.

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Penetration Test Connection Valve 1-HC-014 was required to be LC.

The valve was found to be improperly locked because the wire cable

used to secure the valve was not tight. This condition was reported to the on-duty shift supervisor who initiated corrective actions.

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All valves, power supplies, and switch positions were noted to be in positions required to support plant operation.

Items noted by the inspector did not appear to directly impact safe operation of the plant.

All observations were referred to the licensee for inclusion in the licensee's long-term program for procedure upgrade.

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No violations or deviations were identified in this area of the inspection.

5.

Engineered Safety Feature (ESF) System Walkdown - Unit 2 (71710)

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A walkdown of the CCW system for Unit 2 was performed to independently verify the status of this ESF system. The inspection consisted of an operating procedure review, comparison of the operating procedure to plant drawings and TS, and a walkdown of the system to verify whetner the system was properly aligned to support plant operation.

Specific items inspected in the plant included verifying valve, switch, and breaker positions, housekeeping, and support availability systems.

The inspector reviewed Operating Procedure 2 POP 02-CC-0001, " Component Cooling Water System," Revision 4 (effective date of January 25,1990).

The procedure lineups (valve, switch, and electrical power supply positions) were compared to system P&lDs.

Observations made during the procedure review included:

The prerequisite section of the procedure, 3.0, listed the support systems required for system operation.

Section 3.0 should have included the support system, Instrument Air System.

  • Step 5.9 provided instructions to vent nonsafety-related system components. This was to be accomplished using Vent Checklist 2p0P02-CC-0001-5.

Fifteen vent valves were noted to be missing from the vent checklist.

  • Valves that were required to be locked in position were to be identified as such on the system P& ids.

Valve 2-CC-0152 was a LO l

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~7-valve that was not shown on the P&ID as LO.

Valve 2-CC-0227 was a l

LIP valve that was not shown as LIP on the P&ID.

  • Valve 2-CC-0719 was incorrectly listed as Valve 2-0C-0791 in Checklist 2 POP 02-CC-0001-1. Valves 2-CC-846, 2-0C-850, 2-0C-854, and 2-CC-858 were listed as test cunnection valves on the P&ID but were listed as drain valves in the checklist.

Valve 2-CC-0445 was a LC valve that was only required to be closed, not locked, in the i

checklist.

  • Instrument Vent Checklist 2 POP 02-CC-0001-8 was missing nonsafety-related Pressure Switches 2-CC-PSL-4644, 2-CC-PSL-4644A, and 2-CC-PSL-4644B.

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Observations made during a plant walkdown of the system and the operating procedure included:

Vent Valve 2-CC-844 was shown on P&ID 5R209F05020 #2, CCW System, Revision 10.

Valve 2-CC-B44 was not listed in the Valve Lineup Checklist 2 POP 02-CC-0001-1 and was not located in the field.

There were no approved change requests outstanding against the P&ID. The Valve 2-CC-844 should have been deleted from the P&ID if not installed.

  • Incorrect or inccmplete locations were listed for the following valves in the Valve Checklist 2 POP 02-CC-0001-1: 2-CC-0421, 2-CC-0873, and 2-CC-829.

Incorrect or incomplete locations were listed in Electrical Lineup 2 POP 02-CC-0001-6 for Components 2-CC-MOV-0314, 2-CC-MOV-0059, 2-CC-MOV-0147, and 2-CC-MOV-208.

In Checklist 2 POP 02-CC-0001-6 the device number was incorrect for Components 2-CC-MOV-0208, 2-CC-MOV-0129, and 2-CC-MOV-0291.

Per Checklist 2 POP 02-CC-0001, the required position of Valve 2-CC-0834 Radiation Monitor RT-8037 supply valve, was full open, but the valve was found in a throttled position. The Drain Valve 2-CC-0618 hand wheel was found on the floor near the valve (no maintenance work request tag was attached).

  • The wrong positions for the CCW to reactor containment fan coolers (RCFC) 21C and 220 cooling coil inlet and outlet valves were listed in Electrical Checklist 2P0P02-CC-0001-6. The required breaker positions were locked off, per the locked valve program, but the checklist (-6) listed the power supply positions to 2-CC-MOV-0200, 2-CC-MOV-0203, 2-CC-MOV-0204, and 2-CC-MOV-0207 as ON.

The power supplies were found locked off in the plant.

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Valve Checklist 2 POP 02-CC-0001-1 listed the position of Valves 2-CC-0872 as normally open and 2-CC-0871 as LIP. The locked valve program required Valve 2-CC-0872 to be LIP and 2-CC-0871 to be l

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full (but not locked) open.

Checklist 2 POP 02-CC-0001-1 should have been revised to agree with the positions required by the locked valve program.

TS surveillance requirement 4.7.3.a states, "At least 3 CCW loops shall be demonstrated operable at least once per 31 days by verifying that each valve outside containment (manual, power operated, or automatic) servicing safety related equipment that is not locked, sealed, or otherwise secured in position is in its correct position." This surveillance requirement was verified in Unit 2 by implementing Procedure 2 PSP 03-CC-0011. "CCW Valve Checklist," Revision 1.

This procedure included only the remotely operated valves (motor and air operated) supplying ESF loads. These loads consisted of the residual heat removal (RHR) heat exchangers and RCFC cooling coils. All manually operated valves (valves in the line of flow)

to the ESF loads were required to be LO. These manual valves were not included in Valve Checklist 2 PSP 03-CC-0011-2.

The NRC inspector noted

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that other manual valves were also not included in Valve

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Checklist 2 PSP 03-CC-0011-2, such as the in-line valves to and from other safety related but non-ESF components.

Safety-related components that were not included in the valve surveillance checklist or locked velve program included the centrifugal charging pump lubricating oil coolers and room air handling units, positive displacement pump room air handling unit, and spent fuel pool heat exchangers. These safety-related

= components are not ESF loads but should have been included in the surveillance program.

TS 6.8.1 states that written procedures shall be established, implemented, and maintained covering the applicable procedures reccmmended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A, Section 8.6, states " Specific procedures for surveillance tests, inspections, and calibrations should be written (implementing procedures are required for each surveillance test, inspection, or calibration listed in the TS."

.The failure to include valves servicing all Safety-related CCW equipment in Procedures 2 PSP 03-CC-0011 (Unit 2) and IPS903-CC-0011, Revision 3 (Unit 1), is an apparent violation of TS 6.8.1 (498/9008-01;499/9008-01). TS 4.7.3.a was not being fully implemented because Procedure 2 PSP 03-CC-0011 did not include all Unit 2 valves servicing safety-related equipment (a total of 27 valves were identified missing from Procedure Checklist 2 PSP 03-CC-0011-2).

When informed of the inadequate procedure, the licensee took corrective actions that included:

(1) writing field change requests to add the missing valves to both Procedures IPSP03-CC-0011 (Unit 1) and 2 PSP 03-CC-0011 (Unit 2), (2) verifying the missing valves were in the correct positions, (3) writing a station problem report to investigate the problem, and (4) informing the NRC operations center of the problem.

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In conclusion, all valves, switches, and power supplies were found in position to support plant operation. Additionally, housekeeping was being maintained in the areas inspected in Unit 2 during the system walkdown.

Despite the few P&ID errors observed, the CCW P& ids were noted to be

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better than the average system P& ids that were reviewed during previous I

plant system walkdowns. The small number of errors observed compared to the size of the system indicated that the P& ids were of higher than normal quality. All observations were reported to the licensee for inclusion into the licensee's long-term procedure enhancement program, t

One apparent violation and no deviations were identified in this area of the inspection.

6.

Monthly Maintenance Observations (62703)

Selected maintenance activities were observed to verify whether the activities were being conducted in accordance with approved procedures.

The activities observed included:

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Preventive Maintenance (PM) EM-1-NK-88002930 Inspection and Test of Freeze Protection Control Panel 9E281 ERR 0024

PM IC-2-HE-89001192, Calibration of Control Room Cleanup Unit 21A outlet differential pressure transmitter

PM IC-1-AM-89003473, Inspection of the Qualified Display Processing System (QDPS)

The inspector verified that the activities were conducted in accordance with approved work instructions and procedures, test equipment was within the current calibration cycles, and housekeeping was being maintained in

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an acceptable manner. All observations made were referred to the licensee for appropriate action.

PM EM-1-NK-88002930 was performed by electrical department technicians on Freeze Protection Control Panel 9E281 ERR 0024. The technicians also performed Procedure OPMP05-NK-0002, Heat Tracing / Freeze Protection Panel Tests, Revision 0, on the control panel.

Observations made during the

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performance of PM EM-1-NX-88002930 and Procedure OPMP05-NK-0002 included:

The panel had a thermostat that controlled the space heater in the control panel. The vendor drawing for the panel specified that the thermostat should have been set at 50'F, but the thermostat was found set at 80'F.

The PM should have included instructions to verify that the thermostat was set at the vendor recommended setpoint of 50'F.

  • The label on the manual handswitch located on the control panel was previously reported to be on the wrong side of the switch.

During the panel inspection, the label was noted to be repositioned on the correct side of the switch.

  • Temperature Switch NINK-TSLL-8520 was installed in the field to monitor ambient air temperature. On low-low temperature (35'F)

concurrent with an open main contactor, the switch was designed to actuate a local alarm indicating contactor voltage failure (loss of

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-10-power to freeze protection circuits). The temperature switch was

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installed in the field, but the alarm circuit was never fully installed by the licensee. Although no maintenance was scheduled to be performed on the thermostat, a controlled instrument analog scaling data sheet was being maintained by the licensee. This incomplete circuit had no effect on system operation.

  • Step 6.4.1 of Procedure OPMP05-NK-0002 instructed technicians to verify that all circuits were energized at the panel. At this point in the procedure, only the main power leads into the panel were energized.

Step 6.4.5 instructed the technicians to manually energize all individual heater circuits.

Step 6.4.1 was signed off when Step 6.4.5 was completed.

Step 6.4.1 should have provided more specific instructions or, what circuits to check.

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Step 6.4.3 instructed technicians to verify that the local alarm for heater failure circuit operated properly and not to replace bulbs for circuits not used. The replacement of bulbs for circuits not used was not applicable to Step 6.4.3 but applied to Step 6.4.4, which tested the individual circuit lights.

  • FCR 90-0238 was written to revise Step 6.4.5 of OPMP05-NK-0002. The inspector noted FCR 90-0238 was not included in the working copy the technicians were about to take into the plant and use. The FCR was issued between the time the electrical shop was given the work package and the time the procedure was to be implemented. After the missing FCR 90-0238 was identified, an updated copy of the procedure was obtained and used.

This subject area (ensuring that all working / controlled copies of the procedure are identified and updated when procedure changes occur) was previously identified by the licensee and was the subject of a recent station problem report.

PM IC-2-HE-89001192 was performed by instrument and control (I&C)

personnel to verify the calibration accuracy of the Unit 2 control room Cleanup Unit 21A Outlet Flow Transmitter A2HE-FT-9597.

The actual calibr.stion was performed using Procedure OPMP08-ZI-0002, " Pressure Transmitter or Differential Pressure Transmitter Calibration," Revision 2.

Observations made during the review and performance of the PM included:

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Step numbering inconsistencies in Procedure OPMP08-ZI-0002.

Substeps of Section 4.2 used letters (such as 4.2.a. 4.2.b, etc.) while substeps of Section 7.1 used numbers (such as 7.1.1,7.1.2,etc.).

The numbering of steps should have been consistent.

  • The as-found data was recorded twice by the technicians. The recorded data was noted to be out of tolerance (low) the first time.

The test rig was reinstalled and the data was again obtained.

The second time the data was measured, the values were out of tolerance (high).

Variations in building air pressure (e.g., doors opening and

closing) were noted to affect the data being measured. The measured values varied up to 0.2 milliamps while the allowed tolerance was L

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i 0.24 milliamps. The technicians were noted to be recording the average value measured. The procedure instructions permitted removal of the transmitter from its permanent field location for testing and adjustment. Despite the problems encountered, the technicians decided not to remove the instrument and tested / adjusted the

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instrument in its permanent location. The as-left data was noted to be within acceptance criteria limits.

PM IC-1-AM-89003473 was performed by I&C technicians to inspect as-found conditions of the Unit 1 QDPS displays, processors, and status lamps. No specific concerns were identified by the NRC inspector.

No violations or deviations were identified in this area of the inspection.

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7.

Monthly Surveillance Observations (61726)

Selected surveillance activities were observed to ascertain whether the surveillance of safety significant systems and components were being conducted in accordance with TS and other requirements. The following surveillance tests were observed and the documents reviewed:

IPSP06-RC-0005, "Undervoltage Reactor Coolant Pump Trip Actuating

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Device Operational Test (TA00T)," Revision 4 IPSP06-RC-0006, "Underfrequency Reactor Coolant Pump TADOT,"

Revision 6

2 PSP 03-EW-0003, " Essential Cooling Water Screen Wash Booster Pump 2A Inservice Test," Revision 1 2 PSP 05-SI-0931, " Refueling Water Storage Tank Level Set 2

Calibration," Revision 1

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Specific items inspected included verifying that as-lef t data was within acceptance criteria limits, the acceptance criteria as listed in the procedures agreed with values listed in design documents or instrument l-setpoint indexes, and the test equipment used was within its current calibration cycles.

Following observation by the inspector of the j

surveillance activities, the procedures were reviewed for technical

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accuracy and for conformance to TS requirements.

l Procedures IPSP06-RC-0005 and IPSP06-RC-0006 were performed by electrical department technicians to meet TS-required surveillance on the Unit 1 reactor coolant pump (RCP) undervoltage and underfrequency relays.

No concerns were identified with these two procedures.

i Procedure 2 PSP 03-EW-0003 was performed by Unit 2 operations personnel to l

verify operability of the Essential Cooling Water Screen Wash Booster Pump 2A. Observatir;ns noted during the performance of 2 PSP 03-EW-0003 I

included:

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Steps 5.3 and 5.3.1 were listed twice in the procedure, the first time on the bottom of page 2, the second time on top of page 3,

Step 5.9 instructed the test performers to open root valves to temporary gauges and place the gauges in service, however, the actions required by Step 5.9 were performed when the gauges were

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installed in Step 5.3,

Step 5.3.2 provided instructions that a temporary test gauge "shall" be installed at an elevation equal to the centerline of the pump suction line (about 4 feet above the floor), however, the gauge was

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observed to be installed about I foot below the centerline of the suction line (about 3 feet above the floor), and

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During the test performance, Instrument N2EW-PDI-6944 (Essential Cooling Water Pump A seal water strainer differential pressure was t

noted to be reading below 0 psig.

The meter reading appeared erroneous (a positive value should have been observed) and was reported to the unit supervisor for resolution.

None of these observations had a significant effect on test performance or data recorded.

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Procedure 2 PSP 05-SI-0931 was performed I&C technicians to verify the accuracies of the alarms, trip setpoints, and remote displays of Instrument Loop D2SI-L-0931, Unit 2 Refueling Water Storage Tank Level.

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Observations noted during review of Procedure 2 PSP 05-SI-0931 included:

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Numbering inconsistancies in Section 4.0 where substeps of 4.1 used letters while substops of 4.2 used numbers.

  • Typos in Steps 7.4.3 and 7.19.8 where Motor Control Center E2A2 was listed as EIA2,

A step should have been a r ed prior to step 7.15.3 (monitor and record a trip value) to r ange the test point needed to monitor the data to be recorded in h ep 7.15.3.

The meter was noted to be on the wrong test point (Test point 2 versus Test Point 1) during the l.

performance of 7.15.3, and

Level Recorder N2-SI-LR-0931 had meter units of gallons, but Instrument Loop D2SI-L-0931, Section 12, stated Level Recorder LR-0931 output read in units of percent.

l Procedure 2 PSP 05-SI-0931 was performed by two different crews.

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of 2 PSP 05-SI-0931 instructed the test performer to record the as-found l

position of a Toggle Switch SW6 on the data sheet (-1), page 16.

Step 7.4.7 was checked off as being performed but the switch position was

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not recorded on page 16 by the first crew. A shift turnover was l

performed, and the test was continued.

Step 7.19.3 instructed the second crew to return the toggle switch to the as-found position recorded on the l

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-13-data sheet (-1), page 16. The second crew did not clearly know what the as-found position was because the position was not previously recorded.

The failure to record the as-found toggle switch position is a failure to follow a safety-related, approved procedure. The failure to follow procedures is an apparent violation of TS 6.8.1 (50-499/9008-02). This apparent violation of TS is not being cited because it meets the criteria established in Section V.A of the general statement of policy and procedure for NRC enforcement actions. The Toggle Switch SW6 was found in the correct position to support procedure performance and the switch was

~e left in the correct position to support plant operation. Corrective actions taken by the licensee included reminding the technicians the importance of procedure adherence and attention to detail.

One violation (noncited) and no deviations were identified in this area of the inspection.

8.

Exit Interview The inspectors met with licensee representatives (denoted in paragraph 1)

on March 2, 1990. The inspectors summarized the scope and findings of the inspection. The licensee did not identify as proprietary any of the information provided to, or reviewed by, the inspectors.

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