IR 05000528/1985043
| ML17299B021 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/21/1986 |
| From: | Bosted C, Fiorelli G, Miller L, Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17299B020 | List: |
| References | |
| 50-528-85-43, 50-529-85-44, NUDOCS 8602190070 | |
| Download: ML17299B021 (36) | |
Text
Sb02190070 Sb0130 PDR ADOCK 05000528
PDR U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos:
Docket Nos:
50-528/85-43, 50-529/85-44 50-528, 50-529 License Nos: NPF-41; NPF-46 Licensee:
Arizona Nuclear Power Project P. 0.
Box 52034 Phoenix, AZ. 85072-2034 Facilit Name:
.Palo Verde Nuclear Generating Station Units
& 2 Ins ection Conduct
Nov Inspectors:
13-De mber 26, 1985 Z/-E's si erman Ins ior Date Signed j-z./- g Approved By:
Summary:
G o elli, R i t
pect C.
o ted, Resi Insp L
lier, Ch R actor Projec s Section
Date Signed
)-Z.j-Date Signed Date Signed Ins ection on November 13 throu h December 26, 1985 (Re ort Nos. 50528/
85-43 and 50-529/85-44)
Areas Ins ected:
Routine, onsite', regular and backshift inspection by the three resident inspectors (Unit 1 222 hours0.00257 days <br />0.0617 hours <br />3.670635e-4 weeks <br />8.4471e-5 months <br />; Unit 2 181.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> including 21 back shift hours).
Area's inspected included: followup of previously identified items; review of plant activities; engineered safety system walk downs; surveillance testing; maintenance; review of preoperational test results; initial fuel load witnessing; Licensee Event Report followup; Deficiency, Eyaluat'ion Report followup; licensed operator training; post trip review,, adequacy; Unit-'2 proposed Technical Specification review; periodic and special report review; and plant tours.
l During this inspection:the following,Inspection Procedures were covered:
41700, 41701, 61726, 62703,'"70329, 71301, 71302,'1707, 71710, 72524, 90711, 90713, 92700, 92701, 92705, 93702, 94300.'esults:
Of the 14 areas inspected, tw'o violations were identified in two areas.
(Failure to submit two LER's within the required 30 days paragraph 2.a; and failure to maintai'n the'ontainment power access purge valves closed to the maximum extent practicable paragraph 7.)
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DETAILS 1.
Persons Contacted:
The below listed technical and supervisory personnel were among those contacted:
Arizona Nuclear Power Pro ect (ANPP)
R. Adney, Operations Superintendent, Unit 2
- J. Allen, Operations Manager
"<J. R. Bynum, PVNGS Plant, Manager,,
'.
Cederquist, Chemical Services Hana'ger W. Fernow, Plant Services Manager R.
Gouge, Operations Supervisor, Unit
J.
G. Haynes, Vice President Nuclea'r,Operations W. E.
Xde, Corporate Quality Assur'ance Manager J. Minnicks, Instrumentati:on and 'Control Maintenance Supt.
D. Nelson, Operations Security Manager R. Nelson, Maintenance Manager G. Perkins, Radiological Services Manager J. Pollard, Operations Supervisor, Unit 2
>"L. Souza, Assistant Quality Assurance Manager
<E. E. Van Brunt, Jr.,
Executive Vice President
>'<R. Younger, Operations Superintendent, Unit 1
<O. Zeringue, Technical Support. Manager The inspectors also talked with other licensee and contractor personnel during the course of the inspection.
>Attended the Exit Meeting on December 27, 1985.
2.
Previousl Identified Items a
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(Closed) Violation (50-528/85-21-01): Failure to submit a
Licensee Event Re ort (LER) within 30 da s.
The inspector reviewed the licensee's response to the viola-tion, dated September 9, 1985, from E. Van Brunt, Jr.
(APS) to D. Kirsch (NRC).
The licensee's corrective action commitments included 1) reporting any events for which reportability appeared possible, 2) reviewing the status of Potentially Reportable Occurrences (PROs)
and draft LERs on a daily basis, and 3) hand carrying any PROs which were not reviewed in a timely manner.
The response letter also mentioned planned action to review and modify the applicable implementing procedures for identification of reportable items and to streamline the approval process for LER submittal.,
The inspector noted that the licensee's response did not address the date when full compliance would be achieved.
The inspector stated that although this appeared to be an isolated oversight the licensee should ensure that future responses to Notices of
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Violations fully addressed the provisions of 10 CFR 2.201.
The licensee representative acknowledged the inspector's comment.
The inspector reviewed a number of recently submitted LERs to determine whether the licensee's corrective actions were effective in assuring timely submittals.
Two LERs were iden-tified to have exceeded the 30 day period for submittal to the Commission following event discovery.
LERs 85-70 and 85-72, submitted on October 25 and October 16, 1985, respectively, documented conditions prohibited by Technical Specifications and were submitted in 31 days.
Failure to submit the LERs within 30 days is contrary to Technical Specification 6.6.1.a and
CFR 50.73 and is considered a repetitive violation (528/85-43"01).
The inspector also reviewed management corrective action report (CAR) MA-85-0002 initiated on August 13, 1985, which documented the identification by Quality Assurance of several late LER submittals.
The date for corrective action of this CAR, which includes revision of the implementing procedure to streamline the approval process as described above, was mod-ified from the original date of October 30 to November 27, 1985, and is currently due on January 10, 1986.
The inspector stated that the lack of timeliness in implementing corrective action for CAR MA-85-0002 was disturbing, considering it add-ressed a violation of Technical Specifications; although minor in safety significance.
The subject of improving responsive-ness to CARs has been discussed with the licensee previously, and is documented as an area requiring greater management attention in the Systematic Assessment of Licensee Performance Report, issued December 19, 1985.
For the purpose of tracking, inspection item 528/85-21-01 is considered closed and licensee corrective action will be evaluated against item 528/85-43-01.
li (Closed)
Xns ector;Followu-(50-528/85-13-04):
Fitness for Dut
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r>>>>m li The Fitness for Duty",- training program was'eviewed by the inspector for content and to"evaluate the'umber'and type of work groups that were receiving the'raining.,=The
"Fitness for Duty" training consisted of,.a pre-'reporded,video
'tape' in which the Executive Vice-President.,explained the company policy on substance abuse.
Thi video tape also explained what,the company expected of.employee's, conceining'heir',fitness, for duty.
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The inspector also reviewed 'several hundred attendan'ce sheets from all work areas of the plant, site for special training which was conducted in July and August, 1985.
A sampling review of the list of attendees included personnel from Security; Operations; Training; Engineering; Mainteqance; Chemistry; Radiation Protection; Drawing and Document Control
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and the Water Reclamation Facility.
Since September, this training has been included in the normal general employee training.
This item is closed.
3. Review of Plant Activities a ~
Unit 1 At,the start of the report period, the unit was in Mode 5 in an unscheduled maintenance outage for inspection and repair of the 13.8 KV electrical bus bar connections.
During the outage the licensee also determined that studs and anchor bolts installed in reactor coolant system line stops had not been tensioned to the specified pre-load value.
Efforts to properly retension the bolts was promptly initiated.
Further details are documented in NRC Inspection Report 50-528/85-42.
Following completion of the outage, plant heat up was commenced with criticality achieved on November 30 at 8:35 PM.
A re-perform-ance of the 80/ load rejection test was successfully conducted on December 4; however, during the recovery a malfunction in a control rod drive mechanism logic card caused control rod subgroup 12 (4 rods) to drop.
The dropped rods caused a
reactor trip on low DNBR from 56/ full power at 7:06 PM.
The reactor was restarted on December 5 at 9:07 PM, and power level was raised to 100/ FP on December 10.
On December ll, at 1:40 PM, leaking main condenser tubes depleted the condensate demineralizers, and high cation conductivity in the steam generator required that power be reduced to about 1% power.
At 3:59 PM the reactor was shutdown in accordance with plant procedures when ammonia in the reactor coolant system exceeded chemistry limits.
The originating source of high ammonia was traced to the hydrazine concentration in the Refueling Water Tank.
Following reduction of the, ammonia content to within specifica-tions through the normal ion exchange process, the reactor was started up on December 15 and power was raised to 50% FP when another condenser tube leak was discovered.
Power was held at, 50'/ while the condenser
',tube leak was~lidentified and plugged.
On December 16, at approximately, 6:ll,'PM, a'alfunction in the Balance Of Plant Engineered Safety 'Feature Actuation System (BOP ESFAS) sequencer caused:
an actuation of CREFAS, CPIAS, and FBEVAS; a loss of power load shed on the "A" train of the essential 4160 V bus S03; and'
start of the "A" Diesel Gene-rator.
'Bus S03 was deenergized; however,. the sequencer malfunction prevented the "A" Diesel Generator output breaker from closing and reenergizing the dead bus.
Operator action was required to allow the bus to be reenergized from normal power.
Shortly after the BOP ESFAS actuation the "B" Essential Chiller unit tripped on lo'w refrigerant. temperature.
With both the "A" Diesel Generator inoperable and the "B" Chiller unit inoperable a reactor shutdown was commenced at 7:50 PM.
At ll:31 PM, at approximately 2% FP, the reactor tripped on low
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n level in the number 1 Steam Generator due to the operator's inability to maintain level in manual feedwater control.
The plant was restarted on December 18 at, 12:52 AM and power level was held at 40'/, while previously plugged condenser tube leaks were reexamined.
On December 20 at 2:30 AH, the reactor tripped on high pressurizer pressure following a turbine run back.
The run back occurred upon resetting a communication data link problem between the reactor power cutback system (RPCB)
and the plant computer.
The run back signal was generated from the run back demand module in the steam bypass control system (SBCS) which was miscalibrated.
The RPCB initiated a "Loss of Feedwater Pump Cut Back", and ran main turbine power back to approximately 3/
from 40/
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Since reactor power was less than the cut back set point of 60/ no rods were inserted, and without. a heat sink the RCS temperature and pressure increased to the high pressurizer pressure set point.
Following inspection of the RPCS and calibration of the SBCS setpoint the reactor was restarted December 21 at 6:30 AH and power was maintained at greater than 95% ZP for the remainder of the inspection period.
Unit 2 The licensee's final evaluation of the plant's preoperationa1 test results was completed, and the open items required for fuel loading were closed during the inspection period.
Unit 2 was issued a low power operating license on December 9, 1985, and completed initial fuel loading on December 17, 1985.
The plant was in the process of installing the reactor vessel head at the conclusion of the inspection period.
Plant Tours The following plant areas at Units 1 and 2 were toured by the inspector during the course of the inspection:
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0 Auxiliary Building Containment, Building Control Complex Building Diesel Generator Building Radwaste Building Technical Support Center Turbine Building Yard Area and Perimeter The following areas were observed during the tours:
(1)
0 eratin Lo s"'and Records.,
Records were reviewed against Technical Specification and administrative control pro-cedure requirement I,, I p
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The inspector noted several instances where the licensee's logging of Technical Specifications or procedural required actions was poor.
Specifically:
o On October 20, 1985, four valves governed by Tech-nical Specifications were identified by the licensee to have exceeded the required surveillance interval for stroking.
The inspector verified that the valves were stroked successfully within the time constraints of the appropriate Technical Specification action statements; however, no Control Room log entry documented the fact that the valves were declared inoperable; nor were the entry and exit from the action statements logged.
o On December 3 and ll, 1985, during periods of main condenser tube leakage, the logging of entry and exit of steam generator chemistry action levels, as defined in procedure 74AC-9ZZ04, System Chemistry Specifications, lacked consistent clear and accurate entries making procedure compliance difficult to ascertain.
The licensee repres'entatiye acknowledged the inspector's comment and night orders were issued to stress the need for comprehensive'ogging of Technical Specification or procedural required actions.
,Observations of log entries near the conclusion of the inspection period showed improvement, primarily in the log'ging of,chemistry action levels.
(2)
(3)
Monitorin Instrumentation."
Process.instruments were observed for correlation between channels
"and for'con-formance with Technical Specifi'cat'io'n~ requirements."
"I observed for conformance with', 10 CPR 50.54.(k), Technical Specifications, and administrative procedures.
(4)
E ui ment lineu s.
Valve and electrical breakers were verified to be in the position or condition required by Technical Specifications and by. plant lineup procedures for the applicable plant mode.
This verification included routine control board indication reviews and conduct of partial system lineups.
Details are as provided in paragraph 4.
(5)
E ui ment Ta in
.
Selected equipment, for which tagging requests had been initiated, was observed to verify that tags were in place and the equipment in the condition specified,
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Fire Protection.
Fire fighting equipment and controls were observed for conformance with Technical Specifications and administrative procedures.
(8)
Plant Chemistr
.
Chemical analysis results were reviewed for conformance with Technical Specifications and admin-istrative control procedures.
Findings associated with implementation of chemistry action levels is documented in paragraph 9.
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~Secnrit
.
Activities observed for conformance:with'egulatory requirements, implementation of the site security plan, and administrative procedures included vehicle and personnel
'access, and Protected and vital area integrity.
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On November 27, 1985, at approximately 1:00 PM, the inspector observed an item being passed through the
"handicap" ex'it gateoins'ide,the Security headquarters building.
The item was'assed
'from, outside th'e protected area into the, protected area without a 'guard physically searching the item.
The inspector immediately brought this to the attention 'of the Security Sergeant.
An investigation by Security determined that the passer, who was,identified as an emplo'yee working in payroll, had asked the guard in the area if she could pass a paycheck within an envelope to another employee.
The payroll clerk waved the envelope at the guard.
The guard looked at the envelope, and said that it was all right to pass it to the other employee.
The guard had the employee hold the envelope up to the light and could see that the envelope contained what appeared to be a payroll check.
Security management reviewed this occurrence and immed-iately took steps to change the post orders and procedures to insure that the entry point for all material brought into the protective area is at the main access entrance and is searched in accordance with the security plan.
This is considered an isolated incident and the prompt, thorough action by Security management was considered effective.
(9)
Plant Housekee in
.
Plant conditions and material/
equipment storage were observed to determine the general state of cleanliness and housekeeping.
Housekeeping in the radiologically controlled area was evaluated with respect to controlling the spread of surface and airborne contamination.
No violations of NRC requirements or deviations were identifie I',
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4.
En ineered Safet Feature S stem Malk Down 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 functions.
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.
Unit,
Portions of the following systems were walked down on November 26, November 29 (Diesel Generators only), and December 18, 1985.
High Pressure Safety Injection Trains "A" and "B" Low Pressure Safety Injection Trains "A" and "B" Containment Spray Systems Trains "A" and "B" Auxiliary Feedwater Systems Trains "A" and "B" Diesel Generator Systems Trains "A" and "B" On November 29, 1985, the inspector observed that the "A" Diesel Generator jacket water makeup valve (DGA-V004) was in the closed, rather than the normally open position.
The makeup valve is a
small, manual valve with a non-critical function.
The Control Room alignment sheets and status print incorrectly indicated the valve was open.
Upon informing operating shift personnel of the mispositioned valve, it was promptly returned to the proper, open position.
The licensee's investigation was unable to conclusively determine how the valve became closed.
On December 2,
1985, the inspector observed that the above valve was in the proper open position; however, the alignment sheets and'status print now showed the valve as closed.
The licen'see determined that the'alve was closed during a jacket water heater replacement performed on November 30 and December.3 and the Control Room status systems were not updated following reo'pening of-the Palve.
'The. inspec'tor discussed the mispositioned.valve and 'the two~instance's of..'aintaining inaccurate valve status"iin 'the Control,'Room with licensee management.
The in'spector 'also, reviewed a "large sample of valve position verifications jerfor'm'ed without, identification of discrepancies by the license&"'s Qual'ity'As'suranch Department;.
The adequacy of the licensed's'alve posi:tion,control's pill be, reviewed as a followup item (528j85-.'43-02),.,
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Unit 2 hg, Portions of the following system were-wagked
.gown on December 19, 1985.
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Control Room Essential Filtration System.
No violations of NRC requirements or deviations were identifie V o
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5.
Surveillance Testin
- Unit 1 D
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 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 dispositioned.
b.
Portions of the following surveillances were observed by the inspector on the dates shown:
Procedure Descri tion/Dates 41ST-1SIll LPSI Pump Operational Test on November 25.
, Excore Linear Power Surveillance on November 25.
36ST-9SE03 Excore Safety Iinear Channel Calibration on December
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36ST-9SE01 Excore Safety Channel Calibration on December 16.
The following completed surveillance tests were reviewed by the inspector:
Procedure Descri tion/Dates Performed 14ST"1ZZ24 41ST-1ZZ15 41ST-1ZZ16 41ST"1ZZ18
41ST-1ZZ23 72ST-9SB02 72ST-9RX03 Fire Door Da'ily Check/October 20 to November 11.
Weekly Borated,Water Sources/December 10.
Routine Surveillance Daily/December 10.
Routine Surveillance Mode 1-4/December 10.
CEA Position Verification/December'0.
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CPC/CEAC Auto.Restart Check/December 10.
DNBR/Linear Heat Rate/AS/ for 100/ Full Power/
3)ecember 10.
No violations of NRC requirements'or deviations were identified.
1'.
Plant Maintenance - Unit 1 and
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During the inspection period, the inspector observed and re-viewed 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
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qualifications, and proper retesting.
The inspector verified reportability for these activities was correct.
The inspector witnessed portions of the following maintenance activities:
Unit
Condenser tube plugging per CWO 93389 on November 19.
Spare condensate pump maintenance work on November 19.
Baffle installation on Spray Pond "A" on November 19.
Steam leak repairs on inlet trap to gas stripper on November 27.
Troubleshooting
"A" train BOP ESFAS on December 17.
Troubleshooting
"A" Diesel Generator alarm per WO 11819 on December 18.
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Reactor vessel stud cleaning on December 19.
o Insertion of incore detectors on December 19.
Instrumentation and Control (I/C) Activities - Units 1 and
Unit
On December 13, at approximately 4:20 PM, an inadvertent safety injection and containment isolation initiation occurred at Unit 1.
Based on the inspector's preliminary review, this resulted when an I/C technician apparently did not follow the procedure in performing 36ST-9SB02 "Plant Protective System Functional Test" and had two channels in test simultaneously.
Uait 2 During the inspection period, five errors were committed at Unit 2 during the execution of I/C maintenance.
The first four occurred prior to the issuance of the Unit 2 operating license and involved:
1) the actuation of the Control Room Emergency Filtration System (CREFAS) when an I/C technician inadvertently allowed a jumper lead to contact the terminal board of the "B" train Balance of Plant Engineered Safety Features Actuation System (BOP ESFAS) causing the system to operate on Novem-ber 20, 1985; 2) the release of residual C02 from the C02 fire system line when a technician failed to close a local valve required by the procedure prior to testing a fire protection panel in the "A" Vital Switchgear Room on November 25, 1985; 3)
a technician inadvertently worked on an emergency diesel switch different from the one identified on his work order causing an alarm in the Control Room on November 25, 1985; and 4)
a technician caused the actuation of the '"B" train CREFAS when contrary to procedure, work was "initiated 'on the control unit prior to placing it in 'bypass on November.,23, 1985.
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The fifth error which occurred following the issuance of the Unit 2 license involved the actuation of the "B" train CREFAS on November 19, 1985, when an I/C technician began trouble shooting the system prior to having it placed in bypass.
The trouble shooting was started prior to the issuance of the work request authorizing the work and which contained an instruction to bypass the unit.
The root causes which resulted in the above errors committed during I/O maintenance and testing will receive further inspection, and are considered an unresolved item pending completion of'the inspector's review (529/85-44-01).
Control of the Power Access Pur e Valve 0 eration On December 3, 1985, wi;th the plant at 75'/, power, the inspector noted that the power access purge valves were open.
Subsequent discussions with Operations shift supervision and Health Physics supervision, indicated that confusion existed as to the reason for the purge.
The inspector reviewed the 'applicable release permit (//851128) which was granted for a seven day 'period starting on December 2, 1985, at 5:24 AM.
The inspector discussed the permit with plant management, who initially indicated that the purge was initiated to control containment pressure during the recent plant heat up which was completed on Novembe'r 29, 1985.
Later, it was determined, that the purge was'tarted for a,containment entry.
A containment entry was made from 6:05 PM to 10':00 PM on December 2,
1985, with no additional containment entries expected'after 10:00 PM.
Following the inspector's notification "to Operations management on December 3, that the valves were open with no apparent justifi-cation, the licensee acknowledged, the inspector's comment, concluded the purge was no longer necessary,.and closed, the powerac'cess'urge valves promptly at 12:06,PM.'
The failure to mainta'in the contain-ment power access purge, valves closed -to,the maximum extent practi-cable is contrary to Technical Specificat:ion 3.6.1.7.b and is considered a violation (528/85-43-03)
The inspector noticed that the purge'as,'reestablished at 2:00 PM on December 3, for personnel entry into the containment; however, this was an unanticipated entry not related to the previous entries.
Jhe inspector questioned the adequacy of the administrative control over the purge valves considering;,1)
the plant heat up had been concluded for several days, 2) the'ontainment building pressure at the start of the purge was 0 psig, 3) the licensee could not provide a historical basis whi'ch indicated that a pressure increase in containment would occur during plant heat up and power escalation warranting the opening of the purge valves for an extended period of time, and 4) responsible Operations personnel were not adequately familiar with the reason for the purge.
During subsequent discuss-ions with plant management, the licensee representative committed
<hat future radioactive release permits would consider the predicted length of time necessary for a release when assigning a release duration of the permit.
Additionally, the licensee committed to
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maintain the power access purge valves closed to the maximum extent practicable during future plant operations.
8.
Post Tri Review Ade uac The inspector examined the adequacy of.the licensee's evaluation process for the reactor trip which occurred on December 16 and was documented in the Post Trip Review Report (PTRR) which received management approval prior to plant restart on December 18.
Back-ground information associated with the reactor trip is documented in paragraph 3.a.
The implementing procedure, 79AC-9ZZ08,,2ost Trip Review Reporting, which specified the instruction for'completing the PTRR was considered adequate; however, the 'evaluation'f the December 16 trip was considered to lack thoroughness with regard to identifying and documenting plant anomaliesand'problem areas, including the implementation of appropxiate corrective actions.
The following examples were, discussed jn detail with plant management.
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The PTRR did not address'the fact that the secuiing of the running main feedwater pump prior to the sta'rt of an, auxiliary feedwater pump was a'ignificant,.contributor to the reactor trip on low steam generator level.-,, Further, although identified as not having been performed, in the desired order by the licensee, specific operator shift briefings/training were not performed prior to restart to minimize similar future trips.
The licensee's evaluation of the sequencer malfunction and corrective actions initiated prior to restart were considered adequate; however, plant management did not include the sequen-cer problem or actions taken to prevent recurrence in the PTRR.
Rather, a reference to an addendum report to be issued by December 31, 1985, describing the sequencer problem was in-cluded in the PTRR.
This report would also address longer term corrective action, if necessary.
The inspector stated that although the sequencer,problem was not directly tied to the reactor trip, it raised the most significant safety questions which needed to be resolved prior to restart.
Thus inclusion of more details on this issue in the PTRR report would seem to be appropriate.
Similar to the item above, the "B" Chiller was repaired and root cause analysis initiated; however, no reference to the cause of the chiller trip or its affect on overall reliability was included in the PTRR.
The PTRR did address the fact 'that the "N" Auxiliary Feedwater Pump discharge pressure gage was valved out in preparation for performance of a surveillance test; however, it did not address the apparent lack of familiarity of Control Room personnel with the status of plant equipment and instrumentatio )
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o The PTRR did not address whether Technical Specification compliance was maintained during the initial transient and subsequent reactor trip.
The inspector stressed the need for having a wel1 organized, de-tailed review accomplished for each reactor trip to ensure that all safety concerns are identified and corrected, and to use each trip as an opportunity to minimize future reactor trips and challenges of the plant protection and safeguards systems.
The licensee acknowledged the inspector's comments and committed that for all future PTRR, all anomalous and problem areas identified during compilation of available information will be documented.
The PTRR will include a description of"all the concerns and will either provide resolution in the PTRR,'r reference another document.
The inspector concluded that in order to improve the post trip review process, the above action, coupled with an increased sensiti-vity by the licensee to ensure corrective actions were sufficiently comprehensive, is necessary.
No violations of NRC requirements or deviations were identified.
Procedure Adherence During the inspection period the following instance of poor proce-dural adherence was identified and discussed with licensee management.
On December 3,
1985, at about 8:10 AM, a leaking main condenser tube plug resulted in a high silica concentration of.37 ppm in the No.
Procedure 74AC-9ZZ04, Systems Chemistry Specifi-cations, step 5.3.4.1, required that with a silica concentration greater than
.3 ppm (action level 3) shutdown. was required within four hours.
Responsible chemistry personnel identified that the specified required action level 3 was in error, and that,, in accor-dance with the PMR Secondary Mater Chemistry Guidelines prepared by the Steam Generator Owners Group, -the proper action level should be level 1, which required that the concentration be returned to within normal range within one week.
The licensee did increase steam generator blowdown and the silica concentration was,returned to acceptable levels at about 11 50 AH, prior to exceeding the four hour action level 3.
The inspector., noted that, a procedure change to 74AC-9ZZ04, step 5.3.4.1 was not initiated to correct the,erroneous action level from a level 3 to a, level 1 with greater than3 ppm k
silica.
Based on discussions with Chemistry and.'perations staff, the inspector learned that no plans to commence 'a'plant shutdown were considered, due to the knowledge, of the procedu're error" and'action to initiate a procedure change to c'orrect the error in "real time" was not pursued, apparently due in part:,to 'the fact that changes to 74AC-9ZZ04 require a Plant Review Board approval prior to implementation.
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The inspector informed licensee management.
that the potential deviation from step 5.3.4.1 appeared to indicate a lack of under-standing on the part of plant personnel concerning when a procedure change is required.
Corporate, plant and Quality Assurance management stressed to the inspector their policy of commitment to procedure compliance.
The inspector expressed concern that basic procedure adherence must be understood and appreciated at all levels of the organization for company policy to be effectively carried out.
The area of procedure adherence will continue to be evaluated as part of the routine inspection program.
No violations of NRC requirements or deviations were identified.
10.
Licensee Event Re ort (LER) Followu
- Vnit 1 a ~
(Closed)
LER 85-68: Exceeded ASME Section XI Quarterly Valve Stroking Surveillance Interval - October 20, 1985.
The licensee identified that, four valves had not been tested within the specified quarterly surveillance interval as re-quired by ASME Section XI and Technical Specifications.
The valves, which were two days overdue, were declared inoperable and were subsequently tested satisfactorily.
The inspector reviewed the test results and verified the applicable Technical Specifications action statements were satisfied.
The licensee attributed the cause of the overdue surveillance tests to ineffective. communicat'ion between the Engineering and Operations departments reg'arding whether the testing had actually been accomplished.
To prevent recurrence,,
'the lic-ensee has enhanced the ASME Section XI three week window tracking sheet by 1) adding a column indicating 'completion date, and 2) reducing the s'cheduled quarterly performance internal from 92 days to 82 days.
In addition, the licensee intends on adding software capability to track the combined (,
time interval for three consecutive.surveillance ",tests as not to exceed 3.25 times the specified,inde'rval 'as described in Technical Specification '4.0.2.b. 'inal'ly,'n order to minimize the possibility of communication difficulties, personnel responsible for verifying ASME Section XI surveillance 'tests are performed on schedule have been instructed to'ndependently check the status rather than rely on verbal reports.
This LER is closed.
b.
(Closed)
LER 85-01-02: Inadvertent Control Room Essential Ventilation Signal Actuation - January 16, 1985.
i ii The licensee's supplemental report provided information con-cerning actuation of the Control Room Essential Filtration actuation System (CREFAS).
The root, cause was related to operator error due to procedural inadequacy regarding how to
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properly reset the Balance of Plant Engineered Safety Features Actuation System (BOP ESFAS) trips.
Procedure 410P-1SA01
"BOP ESFAS Module Operation" was revised April 4, 1985, and the operators were briefed on the new procedure.
This LER is closed.
(Closed)
LER 85-08 (Ori inal and 01): Possible Unanalyzed Safety Condition - Auxiliary Feedwater System February 4, 1985.
Combustion Engineering (CE) Standard Safety Analysis Report (CESSAR) Chapter 15, Safety Analysis assumes a maximum aux-iliary feedwater flow of 1750 gpm to the steam generators following automatic actuation.
Later analysis coupled with actual measurements indicated that auxiliary feedwater flow rate could exceed 1750 gpm, which might result, in an unanalyzed safety condition.
CE conducted a new analysis which indicated that increased AFW flow does not result in decreased safety margin.
The inspector has reviewed the CE reanalysis and considers this IER closed.
(Closed)
LER 85-09: Inadvertent Reactor Trip An inadvertent reactor trip occurred on March 21, 1985, while in Mode 5, with all rods inserted, while performing surveill-ance testing in accordance with procedure 36ST-9SB02.
The cause of the trip was due to confusion on the part of the technician performing the test, and a procedure deficiency.
The procedure has been revised and the technicians instructed on the updated procedure to ensure that their actions, when performing panel manipulations, minimize the possibility of a reactor trip.
The inspector reviewed the revised procedure and noted that no additional errors of this type have occurred during the seven months following this occurrence.
This LER is closed.
(Closed)
LER 85-17: Automatic Actuation of Balance of Plant Engineered Safety Features Actuation System (BOP ESFAS)-
April 5, 1985.
Following maintenance on Control Room ventilation radiation monitor, RU-29, the electrical supply breaker for RU-29 was closed causing a momentary high output spike resulting in an automatic actuation of the BOP ESFAS.
The actuation occurred due to a lack of understanding on the part of the operator who failed to anticipate the spike when closing the supply breaker.
New procedure 410P-lSA01, effective April 4, 1985, included the necessary steps to'guide the operator resetting the xadiation monitors and BOP 'ESFAS modules.
Operations personnel were instructed on the event and on the new procedure.,
The, in-spector reviewed 410P-1SA01 and, through interviews, verified that the operators were', aware of the occurrence including how
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to correctly reset the BOP ESFAS with the procedure.
This LER zs closed.
No violations of NRC requirements or deviations were identified.
Licensed 0 erator Trainin and Retrainin
- Units
Formal training sessions required by 83TR-OZZ04 "General Employee Training Pathway" and 82TR-9ZZ03 "Requalification for Licensed Operator Retraining" were monitored by the inspector.
The inspector also verified that. operations personnel who required access into the controlled areas of the plant receive training and retraining in areas of administrative controls and procedures, radiological health and safety, industrial safety, controlled access and security procedures, and the emergency plan.
The inspector also verified that the licensee had conducted a schedule for retraining lectures and that management approved lesson plans were used in the presenta-tion of the retraining lectures.
The inspector monitored several lectures in the operator training and retraining areas.
12.
13.
No violations of NRC requirements or deviations were identified.
Licensee Review of Prep erational Test Results Unit 2 The licensee completed their review of the results of the completed preoperational tests required for fuel l'oad as listed in the FSAR and CESSAR.
The inspector"selected a,sample 'of approximately 10% of the test documents and confirmed, that the reviews and approvals had been conducted and documented.,
t No violations of NRC requirements or>devi,ations were identified.
Pro osed Technical S ecification Review'-'.,'nit 2,
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A review of Unit 2 proposed Technical Specifications was performed to insure that the items covered conditions that would, be expected in the plant.
Clarity, understandability, and enforceability were considered during the review.
The Unit 2 Technical Specifications were very similar to the ones in Unit 1.
Several minor items were noted during the review and were brought to the attention of NRR.
One other item noted was included in the final issued version of Technical Specifications.
No violations of NRC requirements or deviations were identified, 14. Initial Fuel Load Witnessin
- Unit 2 The licensee entered Mode 6 on December ll, 1985.
The initial fuel loading was witnessed by the inspector to verify that the activities were performed in conformance with Technical Specifications.
The inspector observed fuel loading activities from the Spent Fuel Machine in the Fuel Building, Refueling Machine in Containment, and the Control Room.
The activities were compared to the requirements
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of procedure 72IC-2RXOX, "Initial Fuel Load" and to the Technical Specifications.
The inspector verified that:
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On a sampling basis, the prerequisite Mode 6 and the "At all times" Technical Specifications had been completed prior to the start of fuel handling.
The Crew complement was staffed with qualified personnel in accordance with Technical Specifications.
ly The Senior Reactor Operator in charge, of fuel h'andling was in constant communication with the Control Room.
The inverse multiplication plots were being 'calculated and plotted by the Reactor Engineering Group.
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The boron concentrat'ions in the reactor coolant'system and refueling water storage 'tank were, within limits.
A Fuel Management Control Board was set up to identify the location of each fuel assembly as it was-moved from the Fuel Building to the Reactor Vessel.
The Test Director was observed to be supervising the fuel movements from the Control Room location.
o Initial fuel load procedure changes were implemented in accor-dance with administrative controls.
No violations of NRC requirements or deviations were identified.
15.
Deficienc Evaluation Re ort (DER) Followu
- Unit 2 (Closed)
DER 85-34:
Emergency Diesel Generator Override Feature Unit 2 This report discussed a problem involved with the emergency diesel generators such that when in the override mode and upon receipt of a loss of off site power signal, the diesel generator output. breaker will close, and then trip free.
This condition existed only in Unit 2 due to the installation of a design change which had not yet been incorporated in Units 1 and 3.
The problem was corrected by the addition of a two second time delay in one of the circuit relay contacts which eliminated a "relay race" between two components.
The inspector reviewed the completed work documents which authorized installation of the change as well as the test document which tested the units following the modification.
This item is closed.
No violations of NRC requirements or deviations were identifie I'
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16.
Review of Periodic and S ecial Re orts A'eriodic report submitted by the licensee pursuant to Technical Specifications 6.9.1 and 6.9.2 was reviewed by the inspector.
This review included the following considerations:
the report contained the information required to be reported by NRC require-ments; test results and/or supporting information were consistent.
with design predictions and performance specifications; and the validity of the reported information.
within the scope of the above, the following reports were reviewed by the inspector.
o Monthly Operating Reports for October and November 1985.
No violations of NRC requirements or deviations were identified.
17.
Unresolved Items Unresolved items are matters about which more information is re-quired to determine whether they are acceptable, violations or deviation.
An unresolved item is addressed in this inspection in paragraph 6.c of this report.
The inspector met with licensee management representatives period-ically during the inspection and held an exit on December 27, 1985.
The scope of the inspection and the inspector's findings, as noted in this report, were discussed and acknowledged by the licensee representative ~
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