IR 05000528/1985026

Insp Repts 50-528/85-26 & 50-529/85-27 on 850801-0908. Violations Noted:Failure to Properly Verify Closure of Unit 1 Doors & Tech Spec Overtime Limits Exceeded W/O Approval by Plant Manager or Designee

ML20138B900
Person / Time
Site:	Palo Verde
Issue date:	09/25/1985
From:	Bosted C, Fiorelli G, Miller L, Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20138B882	List: IR 05000528/1985026 IR 05000801/2009008 ML20138B876
References
50-528-85-26, 50-529-85-27, NUDOCS 8510220075
Download: ML20138B900 (16)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

1 Report Nos: 50-528/85-26, 50-529/85-27

Docket Nos: 50-528, 50-529' License Nos: NPF-41; CPPR-142

, Licensee: . Arizona Nuclear Power Project P. O. Box 52034 Phoenix, AZ. 85072-2034

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Facility Name: Palo Verde Nuclear Generating Station Units 1 & 2 I InspectionConduct/4: Au {- Se tember 8, 1985 Inspectors: _ b 2 '[-

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Summary:

Inspection on August I through September 8, 1985 (Report Nos. 50-528/85-26 and 50-529/85-27)

Areas Inspected:' Routine, onsite, regular and backshif t inspection by the a

three resident inspectors (Unit-1 - 209 hours0.00242 days <br />0.0581 hours <br />3.455688e-4 weeks <br />7.95245e-5 months <br />, including 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> backshift; Unit 2 - 196 hours0.00227 days <br />0.0544 hours <br />3.240741e-4 weeks <br />7.4578e-5 months <br />, including 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> backshift). Areas inspected included:

review of plant ' activities; surveillance testing; plant. maintenance; preoperational testing activities; engineered safety features configurations; periodic and special report review; conformance of as-built systems to Technical Specification: potential tampering'with plant equipment; diesel

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, generator speed control modifications; Unit ~2 fuel receipt; staff overtime;

Technical Specification action statement compliance; Deficiency Evaluation Report followup; and plant tour During this inspection the following Inspection Procedures were covered:

30703, 60501, 61700, 61726,~62700, 62703, 70314, 70315, 70316, 70324, 70436, '

70400, 70431, 70537, 70540, 70549, 70450, 71302, 71707, 71710, 90711, 90713,

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92701, 92705, 9470 Results: Of the 14 areas-inspected, two violations were identified in two areas.- Failure to take adequate corrective action, resulting in a repetitive Technical Specification violation paragraph 2.c.6; and exceeding Technical 8510220075 851004 PDR ADOCK 05000528 Q PDR

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l Specification overtime' limits without approval by the Plant Manager or his i designee paragraph .

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DETAILS

. Persons Contacted:

The below listed technical and supervisory personnel were among those contacted:

arizona Nuclear Power Project (ANPP)

R. Adney, Operations Superintendent, Unit 2

• J. Allen, Operations-Manager,

• J. R. Bynum, PVNGS Plant Manager

• W. Fe rnow, Plant Services Manager,

.R. 60uge, Operations Supervisor, Unit 1

• J. G. thynes, Vice President Nuclear Operations F. Hicks, . Training Manager'

• W. E. Ide, , Corporate Quality Assurance Manager

• D. B. Karner, Assistant Vice President, Nuclear Production J. Kr.ox , Integrated Safeguards Test-Director

• R. Meyer, Fire Protection Supervisor

• J. Minnicks, Instrumentation and Control Maintenance Sup . D. Nelson, Operations Security Manager i *R. Nelson, Maintenance Manager .

J. Pollard, Operations Supervisor, Unit 2

• C. Russo, Quality Audits Manager I T. Shriver, Quality Systems and Engineering Manager L. Souza, Assistant Quality Assurance Manager

• E. E. Van Brunt , Jr. , Executive Vice President R. Younger, Operations Superintendent, Unit 1

• 0. Zeringue, Technical Support Manager The inspectors also talked with other licensee and contractor personnel during the course of the inspectio * Attended the Exit Meeting on September 5,198 . Review of Plant Activities Unit 1 During the reporting period, Unit I was in a maintenance outage until August 26, 1985. During the outage, several leaking main condenser tubes were plugged and modifications made to the Post Accident Sampling System. On August 26, 1985, the reactor was taken

critical and power level was raired to 10% full power (FP). Power level was raised to 35% FP on August 29, and raised to 50% FP on i September On September'2, power Icvel was reduced to 11% FP due to high conductivity in both steam generators resulting from initial lineup of the heater drain system downstream of the condensate polishers. Prior to this time, heater drain system flow was routed to the main condenser. Following cleanup of the steam generators '

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through increased blowdown, on September 3, power level was raised to 50% FP and then reduced to 35% FP when the "A" Main Condenser conductivity indicated another' leaking tube. One train of condenser

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cooling water was removed from operation, condensate conductivity improved, and reactor power was raised to 53% FP, concurrent with identification and plugging of the leaking - tube. On September 5, a technician removed a temperature detector from the "B" Diesel

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Generator lube oil system, erroneously believing it to be housed in

. a thermowell, causing approximately 500 gallons of lube oil to be pumped onto the diesel generator floor before the lube oil pump could be secured. The "B" diesel lube oil system was refilled, the spilled lube oil was cleaned up, and the diesel was successfully operated prior to being considered operable, Unit 2 The Hot Functional Test was concluded during the inspection period, following 61 days of plant testing. The reactor vessel head was removed and the core internals were removed for inspectio ~

Integrated Safeguards Testing designed to confirm plant performance during emergency conditions was started on August 22, 1985, and continued through the conclusion of the inspection perio Plant Tours The following plant areas at Units 1 and 2 were toured by the inspector during the course of the inspection:

o Auxiliary Building o Containment Building o Control Complex Building-o Diesel Generator Building o Radwaste Building o- Technical Support Center o Turbine Building o Yard Area and Perimeter

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The following areas were observed during the tours: Operating Logs and Record Records were reviewed against Technical Specification and administrative control procedure

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requirement . Monitoring Instrumentatio Process instruments were observed for correlation between channels and for conformance with Technical Specification requirement . Shift Manning. Control room and shift manning were observed for conformance with 10 CFR 50.54.(k), Technical Specifications, and administrative procedure . Equipment Lineup Valve and electrical breakers were verified to be in the position.or condition required by Technical Specifications and by plant lineup procedares for the s applicable plant mode. -This verification included routine control board Indication reviews and conduct of partial system lineups. l Details as 'provided in paragraph t

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. Equipment Tagging. Selected equipment, for which tagging requests had been initiated, was observed to verify that tags were in~ place and the equipment in the condition specifie . Fire Protection. Fire fighting equipment and controls were observed for conformance with Technical Specifications and administrative procedure During a Unit 1 Control Room inspection of fire protection logs on August 29, the inspector noted that four fire doors had been identified by members of the licensee's staff to have been

. advertently excluded' from a revision of surveillance procedure 14ST-1ZZ24 " Unlocked Fire Door Position Verification". This procedure implemented Technical Specification surveillance requirement 3.7.12 which requires that each unlocked fire door without electrical supervision located in a fire rated assembly penetration be verified closed at least once per twenty-four_ hours. During the period April 17 through August 11, three unlocked fire doors (J-111, A-336 and'J-126) which are governed by Technica1' Specification 3.7.12, were not verified to be closed, and a fourth door (A-203) was verified on a seven day cycle (locked door frequency) rather than once per twenty-four hours as require These doors are a subset.of sixteen fire doors previously identified by the licensee on April 12, 1985, and documented in Licensee Event Report 50-528/85-24, as not having been included in 14ST-1ZZ24, which resulted in exceeding the required surveillance interval. The procedure was revised immediately

, by a procedure change notice (PCN) to include the above door On April 17, revision 2 to 14ST-1ZZ24 was issued which should have_ included'the PCN. However, due to an apparent administrative error, the PCN was -not fully incorporated into the revised procedure, resulting in the repetitive violation of Technical Specification 3.7.12. On August 11, following

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identification by the licensee of its exclusion, revision 2 to

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14ST-1ZZ24 was PCN'd to include fire door A-203. Similarly, on August 24, previously identified fire door J-111 was again PCN'd to the procedure and on August 29, 1985, previously identified fire doors A-336 and J-126 were also again PCN'd to the surveillance procedur Following the April 12, 1985, discovery by the licensee of exceeding the Technical Specificat ion required frequency for performance of fire door surveillacce, the failure to implement effective corrective action to prevent a repetitive occurrence of the above Technical Specification violation is contrary to 10 CFR 50 Appendix B, Criteria XVI at d Technical Specification - 3.7.12; and represents a Severity Level IV Violation (50-528/85-20-01),

f The inspector noted that the statement regarding corrective action in Licensee Event Report 85-24, dated May 13, that, "The'

procedures have been permanently revised to correct the noted

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deficiencies..." was not fully accurate, in that the PCN i

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generated on April 12, to 14ST-1ZZ24 was not totally

.; . incorporated into revision 2 to the procedure. The inspector informed the licensee that additional care and verification should be taken on submittals to the NRC which detail

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corrective action . Plant Chemistry. Chemical analysis results were reviewed for

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conformance with Technical Specifications and administrative control procedure . Security. Activities observed for conformance with regulatory requirements, implementation of the site security plan, and administrative procedures included vehicle and personnel access, and protected and vital area integrit . Plant Housekeeping. Plant conditions and material / equipment storage were observed to determine the general state of cleanliness, housekeeping and adherence to fire protection requirement f

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' While no instances of equipment abuse were noted, the inspector observed that Unit 2 housekeeping conditions deteriorated following the completion of the Hot Functional Test. This was mainly due to the resumption of. construction work coupled with an apparent let down in the routine surveillance of plant conditions by the licensee' staff. An intense program to correct the condition was observed to be underway at the conclusion of the inspection perio . Engineered Safety Feature' System Walk Down - Unit'l Selected engineered safety feature systems were walked down by the inspector to confirm that the systems were aligned in accordance with plant procedures. During the walkdown of the systems, items such as hangers, supports, electrical cabinets, and cables were inspected to determine that they were operable, and in a condition to perform their required functio'ns. D The inspector also verified that the system valves were in the required position and' locked as appropriate. The local and remote position indication and controls were also confirmed to be in the required position and operable. Portions of the following systems were walked down on August 7 ar.a 8, 198 High Pressure Sa'ety Injection Trains "A" and "B" -

Low Pressure Spiety Injection Trains "A" and "B" Containment Sr ray Systems Trains ."A" and "B" Auxiliary Fet.dwater Systems "A" and "B" No violations or deviations were identifie . Surveillance Testing - Unit 1 Surveillance tests required to be performed by the Technical Specifications (TS) were reviewed on a sampling basis to verify that: -1) the surveillance tests were correctly included on the

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facility schedule; 2) a technically adequate procedure existed for performance.'of the surveillance tests; 3) the surveillance tests had been performed at the frequency specified in the TS; and 4) test results satisfied acceptance criteria or were properly dispositione The following completed surveillance tests were reviewed: *

Procedure Description / Dates 40AC-0ZZ06 Essential Spray Pond Locked Valve Positions Verification, performed August 16, 198 AC-0ZZ06 Essential Cooling Water Loops Locked Valve Position Verification, performed August 16, 198 ST-9RZ11 COLSS Azimuthal Tilt Alarm and COLSS Margin Alarm Check, performed July 1,198 ST-9PK01 125 Volt Battery Bank Operability Demonstration, performed - Channels A & C performed June 5, 12, 19, 26; and July 3, 10, 17, 24, 31, 198 Channels B & D, performed June 7, 14, 21, 28; and July 5, 12, 19, 198 ST-9ZZ01 Fire Suppression System Water Supply Volume l Check, performed June 6, 13, 20, 27; and July 4, 11, 18, 25, 198 ST-1FP02 Fire Suppression System Electric Motor Driven i Pump Operability Demonstration, performed June 25, and July 26, 198 *

41ST-1ZZ18 Safety Injection Tank Borated Water Volume and j Nitrogen Cover Gas Pressure Check, performed July 1 through 15, 198 ST-ISIO8 Safety Injection Tank Isolation Valve Power Removal, performed June 25 and July 22, 198 l 41ST-ISIO2 Safety Injection Tank Nitrogen Vent Valves Power l Removal, performed June 20 and July 21, 198 ST-1ZZ16 - Shutdown Margin Verification, performed June 14, 15, 16 and July 1, 2, 12, 13, 14, 17, 18, and 23 '

through 31,~198 ,

73ST-9SIO3 Leak Rate of RCS Isolation Pressure Valves, .

performed April 28 and May 13, 198 !

74ST-1CH01 Refueling Water Storage Tank Boron Surveillance t performed on June 3, 10, 17, 24, and, July 1, 8, 15,  !

22,'29, and August 5, 12, 19, and 26, 198 ,

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74ST-IDF01 ~ Diesel Generator "A" Fuel Oil Storage Tank performed June 1, and July 17, 198 ST-1DF02 Die:ci Generator "B" Fuel Oil Storage Tank performed July 2, and August 2,198 ST-ISI01 Safety Injection Tank' Boron Surveillance Mode 1, 2 performed on June 2, July 18, and August 19, 198 ST-ISIO2 Iodine Removal Surveillance performed April 4, 198 ST-ISIO3 Emergency Core Cooling System Trisodium Phosphate Surveillance performed on April 9,198 ST-12ZO2 Chemical Waste Neutralizing Tank Surveillance

. performed on May 19, 198 ST-1ZZO3 ' Liquid Holdup Tank Surveillance performed on June 4, 11, 18, 25, and July 2, 9, 16, 23, 30, and August 6, 13, 20 and 27, 1985 75ST-92208 Effluent Monitor Monthly Surveillance performed on June 26, and July 15, 198 ST-92ZO3 Radioactive Gaseous Effluent Surveillance performed on June 3, 10, 17, 24, and July 1, 8, 15, 23, 30, and August 4, 198 ST-1AF02 Auxiliary Feedwater Pump AFA-P01 Operability Test performed on July 10, and 15, 198 ST-ISS03 Backup Post Accident Sampling System Surveillance, performed August 16 through 18, 198 ST-1AF03 Auxiliary Feedwater Pump AFB-P01 Operability performed on July 19, and August 2, 198 During review of the leak tests of the Reactor Coolant System

' Pressure Isolation Valves performed in accordancc with 73ST-9SIO3, the inspector identified two calculational errors. Neither error had significant effect on the calculated leak rates, and did not affect valve operability. The inspector noted that each calculation had the signature of the performer and the signature of an individual performing a second check of the calculation. These errors, which indicate the need for ensuring adequate review of test data in the future, are further discussed in paragraph The inspector noted that, although not required, the monthly procedure (41ST-1AF02) for testing the steam driven Auxiliary Feedwater (AFW) pump did not verify the turbine's ability to be

, driven from both the "A" and "B" trains of steam supply. The i specified valve to be opened, SGA-UV-134, supplied steam (train "A")

to the AFW pump's turbine; yet, the procedural step to verify

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closure of the steam supply valve stated to close valve SGA-UV-134 or SGA-UV-138 (train "B") . This is considered confusing because the-procedure did not require the

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"B" steam supply valve, SGA-UV-138, to be opened. The licensee acknowledged the inspector's comment and revised the procedure so that each train is tested alternately on a biweekly basi The inspector reviewed the completed 79ST-1SS03 procedure and verified that, following design modifications to the post accident sampling system (primarily containment air sampling function), the system was capable of taking samples, and achieving the accuracy through analyses, as stated in ANPP letter to the NRC (33238) dated August 19, 1985. The licensee intends to take additional samples during stable power plant operation to verify the accuracy of isotopic sampling and analysi No violations or deviations were identifie . Plant Maintenance - Units 1 and 2 During the inspection period, the . inspector observed and reviewed documentation associated with maintenance and problem investigation activities to verify compliance with regulatory requirements, compliance with administrative and maintenance procedures, required QA/QC involvement, proper use of safety tags, proper equipment alignment and use of jumpers, personnel qualifications, and proper retesting. The inspector verified reportability for these activities was correc The inspector witnessed portions of the following maintenance activities:

o Troubleshooting on plant protective system channel "A" - Unit 1, performed August 8,198 o Calibration of linear power channel "D" ' Unit 1, performed August 8, 198 The inspector reviewed documentation associated with the following maintenance activities:

o Calibration of the charcoal filter differential temperature instrumentation loop associated with the "B" Essential Air Filtration Unit (AFU) for the Auxiliary and Fuel Building, performed July 29, 198 (Work Order 95060)

o Replacement of the high pressure safety injection valve UV-626

- Unit 2, performed June 27, 198 o Preventative maintenance of the two fuel pool cooling pumps -

Unit 2, performed August 12, 198 Preventative maintenance of the two fuel pool cleanup pumps -

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o Preventative maintenance of the two spray pond pumps - Unit 2, performed August 12, 198 The inspector reviewed Work Request 109082 which was generated as a result of a-meter indication and alarm condition on the Control Room B02 panel. The alarm indicated high differential temperature across

the "B" Essential Exhaust AFU charcoal filter. Local temperature indication was verified by the Operations Department to be norma Work Order (WO) 95060 was generated to calibrate the remote temperature instrument loop. The inspector reviewed the completed WO which left the loop properly calibrated, but (as documented in the comment section of the WO) did not correct the problem. No further work document was generated to follow up on the initial W The ' inspector stated that the supervisory reviews of WO 95060

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should have generated an additional WO to troubleshoot the instrument loop when the routine calibration did not identify or correct the problem. The inspector further added that the calibration was, performed on a routine preventive maintenance WO, rather than a corrective maintenance troubleshooting WO which appeared more appropriate. The inspector concluded that the use of-a routine preventative maintenance WO may have added to prematurely

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closing the work related documentation without adequately troubleshooting'and repairing the differential temperature loo The-licensee acknowledged the. inspector's comments, and stated that in the future'a corrective maintenance WO will usually be issued initially' to envelope the. repair work; although a preventative maintenance WO may'be appropriate as a sub-tier document during the troubleshooting phas In addition,' based on' review of WO 95060 and verification with plant personnel, the inspector noted that the work group supervisor did not identify during his review that as-found data for a differential

temperature switch (TDSH-74) was not recorded in the same units

, (volts-dc) as the acceptance criteria (ohms), making acceptability difficult'to ascertain. The inspector did note that the second level of supervisory review did identify the discrepancy, made the unit conversion, and verified the results were acceptabl Nevertheless, the premature closing of.the work activities on the instrument loop, and the missed unit inconsistency between the data and acceptance criteria by the work group supervisor, when coupled with the calculation errors documented in paragraph.4, indicated the need for continuing emphasis by the licensee regarding attention to detail and the importance of the review function in assuring quality work. The area of independent and supervisory review of work ,

, activities will be reviewed in greater detail during a future NRC inspection (50-528/85-26-02). '

) The inspector noted that the retest for proper operation of the limit switch on valve UV-626 had been completed using instructions i from a letter written by Combustion Engineering. The conduct of

', this type of test is considered of sufficient importance that it should be covered by a formal test procedure. This: item will remain (

unresolved pending the review of additional retest packages to

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determine whether there are other instances where important tests are performed ,without the instructions from formal test procedure (50-528/85-27-01)

No violations or deviations were identifie . Review of Preoperations Testing Activities - Unit 2 Major Test Activities During the inspection period, the precore Hot Functional test was '

concluded following 61 days of plant testing at normal operating temperature and pressure conditions. The test program included a

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series of 36 system tests developed to confirm design performanc ,

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With the' exception of a greater than expected heat loss to

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containment and several minor deviations, preliminary evaluations

' indicate that while some equipment required modification and/or repair, plant systems performed as required by design. Engineering evaluations, corrective action and retesting are planned for the exception i Preoperational Test Witnessing *

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The inspector witnessed portions of the following tests:

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93PK-2SA01 Integrated Test of Engineered Safety Features i 92HF-2AV01 Loose Parts Monitor Test ,

91CM-2SIO2 Shutdown Cooling System Test 93SU-2SA01 Preparation For Integrated Test Equipment Safety Features '

The inspector verified that approved procedures were used,, test !

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personnel were knowledgeable of the test requirements, and data was .

! properly collected. Procedure changes and test exceptions were i identif.ied and significant events were recorded in the test lo l'

Other' test related activities such as 'the use of calibrated M&TE and j completion of test prerequisites were also verified to have been i accomplished in accordance with administrative control procedure , Preoperational Test Results Review l

The results of the following preoperational tests were reviewed by ,

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the inspecto I 91HF-2RC05 Reactor Coolant System Leak Rate Measurement f

'90HF-2ZZ01 Hot. Functional Test Controlling Document 91PE-2SG01 Main Steam Isolation Valve Test "

91PE-2SG03 Atmospheric Dump Valve Test

93PE-2PK02 Class IE 125 V DC Power System '

93PE-2PK02 125 V DC Power System The inspector verified that activities such as test exceptfo '

i resolution, test data acquisition, test report issuance,' test r

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modifications and acceptance criteria verification had been j accomplished in accordance with procedure l E

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No. violations.or deviations were identifie I Technical' Specification Verification'- Conformance to As-Built f Systems --. Unit 2

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A review was conducted.to. verify that the as-built systems of the f facility were consistent in terms of equipment components and design ,

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features with selected Limiting Conditions for Operation (LCO) of the j Appendix A Technical Specifications (Proof and Review copy). The review i

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..was accomplished on a sampling basis through a combination of (a)  !

examining official. plant drawings, (b) system walkdowns to verify

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q equip;acat and component installation, (c) discussions with licensee i

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personnel and (d): review of technical documents'. The numerical l i

designations correspond with Technical Specification LCO !

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{ 3.1. Boration Systems Flo'w Paths - Shutdown  !

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, 3.1. Boration Systems Flow Paths - Operating  !

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3.1. Charging Pumps - Shutdown  ;

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3.1. Charging Pumps - Operating i t

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3.1. Borated Water Source.s - Operating 3'. Refueling Machine' f

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0 3.' Crane Travel - Spent Fuel Storage Pool Building '

i i 3.9.12 Fuel Building Essential Ventilation System l

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{ 3.6. Iodine Removal System l 3.6. Containment Spray System l .

No violations or deviations were identifie t

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- Unit Staff Overtime'- Unit 1 l

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Based on observations and discussions with plant personnel, the inspector j i noted that overtime worked by unit staff who performed safety related i

functions in excess of the over time guidelines specified in Technical i

Specifications 6.2.2.2.b, was being approved by supervision below the j l Plant Manager's first line supervisors. The inspector stated that the  ;

! practice of allowing lower level management to approve exceeding'the  :

overtime guidelines was not consistent with APS internal memorandum PVNGS-JRB-M84-361, dated September 5, 1984, which designated the Plant ~!

l Manager and his first line supervisors that. authority. The inspector

further. stated that. inspections of the licensee's intended method of .,

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approving overtiuc work beyond the guidelines was previously inspected and documented in NRC Inspection Reports 50-528/85-36 and 50-528/85-4 The above APS memorandum was used in the latter report as a part of the basis for confirming that this TM1 Lessons Learned item (NUREG 0737, I.A.I.3.1. and Generic Letter 82-12) was adequately addressed by the licensee. The inspector expressed concern to licensee management that a portion of the basis for this prior NRC inspection finding was superseded in revisions to the governing administrative control procedure, 10 AC-0ZZ07, Overtime Limitations. The licensee representative stated that upon subsequent issuance of the Unit 1 Technical Specifications, it was '

interpreted that the wording of Technical Specification 6.2.2.2.c which states in part that over time in excess of the guidelines "...shall be authorized by the PVNGS Plant Manager or his designee who is at supervisory level (emphasis added) or above, or higher levels of management....", allowed the superintendent level to authorize overtime as well. This practice resulted in authorization of 14 supervisors as the Plant Manager's "Jesignee". The inspector informed the licensee that, at most, only the first line supervisors below the Plant Manager (4 individuals) were considered appropriate to serve as the " designee" for overtime approval. The licensee representative acknowledged the inspector's comments and stated that an internal memorandum will be reissued and 10 AC-0ZZ07 revised, as appropriate, to define the Plan Manager's " designee" for overtime approval. The inspector will follow up on the licensee's actions (50-528/85-26-03).

The inspector also reviewed the.use of overtime on a sampling basis for the months of July and August ,1985, and noted that overtime for the Operations, Instrumentation and Control, and Chemistry Department was normally maintained within the guidelines of Technical Specification o.2.2.2.b. During a review of overtime worked by the Operations .

Engineering Department the in'spector observed that a substantially' higher amount of overtime was worked, and approval for overtime was not considered by the licensee to be constrained by Technical Specification 6.2.2.2. The inspector informed the licensee that this Technical Specification applied to all unit staff who performed safety related functions, including Operations Engineering personnel. Based on a review l of overtime records and discussion.with engineering personnel, the i

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-inspector identified that a member of the engineering staff worked 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />s-during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period beginning at 6:00 PM on August 19, 1985, without the overtime' being approved by the PVNGS Plant Manager or his designee. Technical-Specification 6.2.2.2.b limits overtime to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period without.the above approval. The engineer was directly involved in taking measurements and calculating percent of valve travel during the performance of surveillance testing to satisfy Technical Specification requirement 4.5.2.g which involves verifying the correct position of electrical and mechanical stops associated with ,

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specific emergency core cooling throttle valves. This is contrary to Technical Specification'6.2.2.2.c and is' considered a violation (50-528/85-26-04).

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r  ! Review-of APS Inv'estigat mns into Possible Tampering Incidents l

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To date several incidents have occurred involving possible unauthorized operations of plant equipment. In addition to the incident which occurred on July.8, 1985 and was reported in NRC Inspection Report 50-529/85-22,- the .following additional incidents occurred.

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On July.26, 1985, control room operators were alerted to the unauthorized i operation ~of a " remote / local" switch associated with the' operation of the 4 "D" battery supply breaker. This switbh'is located outside the control room in the D battery charger / inverter roo On July 31, 1985, while checking the operation of the ammonia injection pumping equipment as a possible cause for a change in condensate chemistry, a technician discovered that the ammonia tank supply valves were found, close )

On August 5,1985, five power breaker switches on control element drive mechanism panels"were found in the " closed" instead of "open" positio '

.On August 8, 1985, 21'similar switches were found in the " closed" instead of "open" position In each of the incidents, no equipment-damage or personnel safety-problems occurre '

The licensee conducted investigations into each of the incidents. To date no positive identifications have been made with respect ~to persons deliberately. tampering with equipment. In the cases involving the closed ammonia tank valves and the remote / local switch operation, the licensee concluded the acts didino'O involve tamperin .

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/ On August-15, 1985, at approximately 9:50 AM, the Control' Room received an alarm indicating that a control switch associated with the 125V DC "D" Battery Charger Disconnect Switch'had been ' repositioned from the " remote" position to the " local / remote"'pohition.' An auxiliary operator and control room operator responded to-the~ equipment room and found the switch mis positioned with no personnel in the roomi Licensee

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investigation' concluded'that no work associated with the switch had been authorized;'however, the physical location of the switch made it-susceptible to being accidentally bumped. Security supervision reviewed

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computer access recordss and-interviewed personnel which were identified to have been in.the' vicinity during the g'eneral time period. -No,

-conclusive determination was made-as to the cause of the' switch being

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mis positioned,'although;it was determined that some unrelated

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mo'dificatiou planriing work was in progress in the equipment. roo ?

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The inspector monitored the' licensee's~ efforts throughout the investigation. The inspector informed licensee management that in view of the recent Remoti Shutdown Panel-incidentJ(documented in NRC Inspection Report x 50-529/85-22),SaslweY1 as several other ongoing

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[ investigations of a similar nature at Units 2 and 3 (documented above) l licensee efforts to determine the cause of the mis-positioned switch were l not considered timely. Specifically, site management'was not notified of

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l the event until the afternoon of August 16, 1985. Additionally, personnel interviews were not conducted for an. additional 3 - 4 day i perio ;

, Licensee management concurred with the-inspector that notification of

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site management should have been quicker, but stated that completion of  :

the investigation was prioritized with other significant work. The 7 inspector reiterated that future notifications of possible tampering events were expected to be provided to site management in a more timely fashion, and sensitivity to these occurrences should result in a full

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investigation into the circumstances of the situation being carried out expeditiously. Licensee investigations into any future possible

tampering events will be monitored by the inspectors as part of the normal inspection program.

j 1 Review of Technical Specification 3.3.9 (Effluent Monitoring) Records i

The inspector reviewed Health Physics records on a sampling basis to ensure grab samples and flow rate estimates were performed in accordance ,

, with~ Technical Specifications 3.3.3.9, in place of radioactive gaseous  :

effluent monitors o'n the plant vent (RU-143), condenser evacuation '

(RU-141),.and fuel building vent (RU-145), during the week of August 11, *

1985, when the in line monitors were inoperative. Several required actions apparently' exceeded the action statement repetitive frequency (twelve hours between grab samples and four hours between flow estimates)

by a short duration. These errors were a very small percentage of the  ;

total required number of samples. The inspector stressed to licensee '

management that Technical Specification action statement frequencies are l required to be satisfied without reliance.on the 25% extension granted to routine surveillance intervals'in Technical Specification 4.0.2.

' Compliance with action statements including intervals between repetitive actions will be further reviewed as part of the routine inspection

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program.

l 1 Emergency Diesel Generator Governor Speed Control - Units 1 and 2 During the-preoperational testing of the Units 1 and 2 diesel generators,

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, -several overspeed trips occurred as a result of sluggish mechanical governor control response. ~The increase in governor hydraulic fluid viscosity due to cool spray pond water, which is used as governor

, hydraulic fluid heat exchanger' coolant, is believed by:the licensee to

, have been a primary factor in the sluggish response. If the governor ,

response is adjusted when the hydraulic fluid is warm, for example during r the summer season when spray pond water is warm, and the engine is

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subsequently started from a cold' condition at a time when the spray pond l

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water >is cold, the governor speed control response will be sluggish l because of' increased oil viscosity. This'can contribute to an engine l

overspeed trip. The mechanical governor is backed up by an electronic .: '

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governor so that the problem of speed control should not occur unless the

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i electronic ~ governor is also inoperable. The potential problem should

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only occur during the cold winter months, when the spray pond water is the coldes Following an enginec...g review, the following modifications were performed to the Unit 2 Diesel Generators. The source of cooling water to the governor hydraulic fluid heat exchanger was changed from spray pond water to the jacket cooling water. This water temperature is maintained between 120 - 135 degrees F. The governor vendor has also implemented changes to the ports and buffer springs within the governor to improve engine speed contro Initial testing of these modifications indicated a substantial improvement in control. Additional testing of the diesel generators is planned during integrated safeguards testin The corresponding cooling water modification at Unit 1 is scheduled for completion in the next several weeks. Because of the significant testing required for the governor modification, this change is scheduled during the first refueling outage. The inspector concluded that the governor modification was not required at this time since operability of the diesel generator units which currently meet technical specification requirements will be further improved with the cooling water modification. The inspector will follow the Unit I diesel generator design changes as they occur. (85-26-05)

No violations or deviations were identifie . Deficiency Evaluation Report (DER) Followup (Closed) DER 85-01: Auxiliary Feedwater Pump Drive Turbine - Unit I and Unit 2 This report discussed a problem involving an undersized taper pin on the coupling end.of the Auxiliary Feedwater Turbine that would not resist the shear loads existing during normal operation and seismic event conditions. The turbine vendor reevaluated the design and concluded the taper pin installation would be acceptable provided the preloads of 3 sets of bolts used in the turbine assembly were increased. The inspector reviewed the engineering and installation documents for Unit 2 and confirmed that proper preloading of the bolts had been completed and verified by Bechtel QC, This work has been completed in Unit 1 and will be completed during the normal construction work at Unit This item is close (Closed) DER 85-14: Low Lube Oil Trip of Emergency Generators -

Unit I and Unit 2 This report discussed a design deficiency that allowed the tripping of an Emergency Diesel Generator from a one-out-of-two low oil pressure condition instead of a one-out-of-two-taken-twice actuation logic. The licensee'.s resolution included the implementation of a design change which corrected the circuitry to require a one-out-of- two-taken-twice low oil pressure condition to trip an emergency diesel generator. The inspector noted the design change at Unit 2 had been signed off as completed and the installation verified by Bechtel QC. The inspector also confirmed that the diesel tests of-the new configuration had been

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satisfactorily completed to confirm proper implementation of the design j change. This work has been completed.in Unit 1 and will be completed i 3-during the normal construction work at Unit This item is close [

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1 Fuel Receipt - Unit 2 l l .  !

To date, approximately 50% of the 241 fuel elements scheduled to be f

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shipped to the site for Unit 2 core loading have been received. The inspector observed ~ several operations involving the unloading, inspection and storage of the fuel elements. The unloading crew appeared well

, trained and executed the unloading steps with good control and in  ;

l accordance with applicable procedure !

t f The inspector verified that radiation surveys were performed on the  !

j truck, fuel handling and storage of equipment as well as the fuel.

i Security controls were in place and were considered effectiv t i With.the exception of one fuel element that was noted.during an unloading l inspection by QC to have a broken grid strap spring no other fuel related  ;

anomalies have occurred. The effect of a broken spring on bundle use is }

} being evaluated by CE. The inspector. confirmed that fuel unloading and }

j storage activities were conducted in accordance with'the license i

provision i No violations or deviations were identifie l i

14. Review of Periodic and Special Reports

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The monthly operating reports for June and July, 1985, were reviewe ;

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The reports contained the information required to be reported by NRC {

requirements,_and the reports appeared vali *

l i t No violations or deviations were identified, t E

r 15. Unresolved Items

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. An unresolved item is a matter about which more information is required [

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in order to. ascertain whether'it is an acceptable item, an open item, a f deviation,.or a violatio f I

1 Exit Meeting _  !

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The inspector met with licensee management representatives periodically during the inspection and held an. exit on September 5, 1985. The scope l

,' of the inspection and the inspector's' findings, as noted in this report, r

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were discussed and acknowledged by the' licensee representative !

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