ML18026A401
| ML18026A401 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/08/1990 |
| From: | Swetland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18026A402 | List: |
| References | |
| 50-387-90-20, 50-388-90-20, NUDOCS 9011210062 | |
| Download: ML18026A401 (39) | |
See also: IR 05000387/1990020
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
1)
Report
Hos.
50-387/90-20;
50-388/90-20
License
Nos.
Licensee:
Power
and Light Company
2 North Ninth Street
Allentown, Pennsylvania
18101
Facility Name:
Susquehanna
Steam Electric Station
Inspection At: Salem Township, Pennsylvania
Inspection
Conducted:
Inspectors:
September
2,
1990 - October 6,
1990
G.
S. Barber,
Senior Resident
Inspector,
J.
R. Stair,
Resident
Inspector,
C.
H. Woodard,
Senior Reactor
Engineer,
P.
D.
Kaufman, Project Engineer,
Approved 8
~
~
P.
D. Swetland,
Chic
Reactor Projects
Section
No.
2A,
F
Ins ection
Summar
Date
Areas
Ins ected:
Routine inspections
were conducted
in the following areas:
operations,
radiological controls, maintenance/surveillance
testing,
emergency
preparedness,
security,
engineering/technical
support,
safety
assessment/quality
verification,
and Licensee
Event Reports
(LER),
Significant Operating
Occurren'ce
Reports,
and Open
Item Followup.
Results:
During this inspection period, the inspectors
found that the
licensee's
activities were directed
toward nuclear
and radiation safety.
One
violation and'o deviations
were identified.
An Executive
Summary is
included
and provides
an overview of specific inspection findings.
901 121 0062 901 109
ADOCK 05000387
Q
PNU
a
TABLE OF CONTENTS
I.
EXECUTIVE SUMMARY
II .
DETAILS
1.
SUMMARY OF OPERATIONS
Page
1. 1
Inspection Activities
.
1.2
Susquehanna
Unit 1.
1.3
Susquehanna
Unit 2.
2.
OPERATIONS
1
1
1
2.1
Inspection Activities ..... ~........
1
2.2
Inspection
Findings
and Review of Events
.
.
.
.
.
2
2.2. 1
"C" Diesel Generator
Inadvertent Start
.
.
.
.
.
.
2
3.
RADIOL'OG ICAL CONTROLS
3.1
Inspecti on Activities
.
3 '
Inspections
Findings
4.
MAINTENANCE/SURVEILLANCETESTING
2
2
4.1
4.2
4.3
4.4
Maintenance
and Surveillance
Inspection Activity
Maintenance
Inspection Activities
.
Surveillance
Inspection Activity
Inspection
Findings
.
5.
5. 1
Inspection Activity .
5.2
Inspection
Findings
.
6.
SECURITY
6.1
Inspection Activity .
6.2
Inspection
Findings
.
7.
ENGINEERING/TECHNICAL SUPPORT
7. 1
Inspection Activity .
7.2
Inspection
Findings
.
7.2. 1
Diesel Generator
Damage
Due to Sandblast Grit
8.
SAFETY ASSESSMENT/QUALITY VERIFICATION
4
5
5
5
C
8.1
8.1.1
8.1.2
8.1.3
Licensee
Event Reports, Significant Operating
Occurrence
Reports,
and
Open Item Fo11owup
Licensee
Event Reports
Significant Operating Occurrence
Reports
Open
Items
7
~
>
7
8
8
9.
MANAGEMENT AND EXIT MEETINGS
9 '
Routine Resident Exit and Periodic Me'etings
9.2
Attendance
at Management
Meetings
Conducted
By
Region
Based
Inspectors
13
13
EXECUTIVE SUMMARY
Susquehanna
Inspection
Reports
50-387/90-20;
50-388/90-20
September
2,
1990
-
October 6,
1990
~0 eratioaa
(30703,
71707)
Operators effectively controlled plant evolutions
and identified plant
problems.
An inadvertent start of the "C" Diesel Generator
was appropriately
responded
to by plant operators.
Radiolo ical Controls (71707)
Individual workers
and Health Physics
personnel
implemented radiological
. protection
program requirements.
Periodic inspector observation
noted'no
inadequacies
in the licensee's
implementation of the radiological protection
program.
Maintenance/Surveillance
(61726',
62703)
Inadequate
cleanliness
control of DG intercooler cleaning resulted
in
intrusion of sandblast
in the "B" and "D" DGs air intake and combustion
chambers.
In addition,
one safety
system actuation
was attributable to
surveillance activities.
This occurred
when the "C" DG inadvertently started
during'erformance
of a 4160V
ESS
bus undervoltage
channel calibration.
a
Emer enc
Pre aredness
No emergency
preparedness
issues
emerged
during the period.
~Securit
(71707)
r
Routine observation of protected
area
access
and egress
control
showed
good
control
by the licensee.
En ineerin /Technical
Su
ort (71707,
92720,
93702,
35702)
The effects of intrusion of sandblast grit into the "B" and "D" DGs was
evaluated
and repairs
were performed to return the
status.
Your lack of procedures
to direct sandblasting
of these
intercoolers
along
with poor control of the work activity was
a significant weakness.
One
violation was identified.
Safet
Assessment/Assurance
of ualit
(90712,
92700,
92701,
92720)
A total of 75 Significant Operating
Occurrence
Reports
were reviewed during
the period,
2 of which were followed up in this report.
0
Details
SUMMARY OF OPERATIONS
Ins ection Activities
1.2
The purpose of this inspection
was to assess
licensee activities at
Susquehanna
Steam Electric Station
(SSES)
as they related to reactor
safety
and worker radiation protections
Within each inspection area,
the inspectors
documented
the specific purpose of the area
under
review,
the
scope of inspection activities and findings, along with appropriate
conclusions.
This assessment
is based
on actual
observation of licensee
activities, interviews with licensee
personnel,
measurement
of radiation
levels,
independent
calculation,
and selective
review of applicable
documents.
Abbreviations are
used throughout the text.
Attachment
1
provides
a listing of these abbreviations.
Sus
uehanna
Unit 1 Summar
1.3
Unit
1 entered
the inspection period at
99 percent full power,
commencing
coastdown at approximately one-half -percent
per day until
beginning the unit's fifth refueling outage.
Shutdown
began
on
September
11,
and the turbine generator
was taken off line at 3:46 a.m.
on September
12.
Cold shutdown
was achieved
on September
14 at 12:05
a.m.
During the period,
a full core offload was completed
and major
work on
and
ESF systems
was performed.
On October 4,
an
inadvertent start of'he "C" Emergency
Diesel Generator
occurred while
performing
a surveillance.
See Section 2.2. 1 for details.
Sus
uehanna
Unit 2 Summar
Unit 2 operated at or near full power for the entire inspection period.
Scheduled
power reductions
were conducted during the period for control
rod pattern adjustments,
surveillance testing,
and maintenance.
No ESF
actuations
or scrams
occurred during the period.
2.
OPERATIONS
2.1
Ins ection Activities
The inspectors verified that the facility was operated
safely
and in
conformance with regulatory requirements.
Power
and Light
(PP8L)
Company
management
control
was evaluated
by direct observation of
activities, tours of the facility, interviews
and discussions
with
personnel,
independent verification of safety
system status
and Limiting
Conditions for Operation,
and review of facility records.
These
inspection activities were conducted
in accordance
with NRC inspection
'rocedure
71707.
The inspectors
performed
177 hours0.00205 days <br />0.0492 hours <br />2.926587e-4 weeks <br />6.73485e-5 months <br /> of normal
and back shift inspections
including deep backshift inspections
on September
7, from 1:45 a.m. to
6:00 a.m.;
September
22, from,7:00 a.m. to 2:00 p.m.;
and,
September
28,
from 4:00 a.m. to 6:00 a.m.
2.2
Ins ection Findin
s and
Review of Events
2.2. 1
"C" Diesel Generator
Inadvertent Start
At 8:40 a.m.
on October 4,'an inadvertent start of the "C" DG
occurred.
The start occurred during performance of the
18 month
channel calibration
on 4160
VAC ESS
bus
1A203 when the
knife switch supplying control
power to the bus
was reclosed.
To
prevent the
DG from starting during the surveillance,
the
DC knife
switch is to be opened,
the fuses
labeled
"Sequence
Start" are to be
removed
and the
DC knife switch then reclosed
to restore control
power
to the bus.
Due to labeling
and permit wording problems,
incorrect fuses
labeled "Diesel. Generator Start" were pulled leaving
the
DG start logic intact.
When the
DC knife switch was then reclosed
and the undervoltage
sensed,
the
DG started
per design.
The licensee
determined
the root cause to be due to inconsistencies
between
design
drawing nomenclature
and labeling of the fuses to the
DG start logic
in conjunction with wording on the permit which was not precisely in
accordance
with the labeling.
The "C" DG was shut
down 22 minutes later
and work was temporarily
stopped to determine
why the
DG started.
The permit was then
changed
to more clearly reflect the labeling wording for the correct fuses.
The appropriate
ENS call per
was
made within the required
time period.
An interim Operational
Instruction
was issued
which
dictates that there shall
be absolute
agreement
between
Equipment
Release
Forms,
Permits,
and field labeling.
If there
are differences
between field labeling and the permit, permit tags shall not be
applied.
Other actions
being evaluated
to prevent
a recurrence
are to
develop
a switchgear inspection
plan for fuse identification, labeling
and drawings for potential
improvements
and for electrical
maintenance
to address
switching error
actions'he
inspector
discussed
the event
and the corrective actions
taken
and
being evaluated with plant personnel.
The inspector
considered
the
licensee's
acti'ons
in response
to the event appropriate.
However,
this event
was significant because it had the potential to cause
severe
personnel
injury and/or
damage
safety related
equipment.
RADIOLOGICAL CONTROLS
3.1
Ins ection Activities
PPKL's compliance with the radiological protection
program
was verified
on
a periodic basis.
These inspection activities were conducted
in
accordance
with NRC inspection
procedure
71707.
3.2
Ins ection Findin
s
Observations
of radiological controls during maintenance
acti'vities and
plant tours indicated that workers generally
obeyed postings
and
Radiation Work Permit requirements.
No inadequacies
were noted.
Y,
4.
MAINTENANCE/SURVEILLANCE
4.1
Maintenance
and Surveillance
Ins ection Activit
On
a sampling basis,
the inspector
observed
and/or reviewed selected
surveillance
and maintenance activities to ensure that specific
programmatic
elements
described
below were being met.
Details of this
review are documented
in the following sections.
4.2
Maintenance
Observations
The inspector
observed
and/or reviewed selected
maintenance activities
to determine that the work was conducted
in accordance
with approved
procedures,
regulatory guides,
Technical Specifications,
and industry
codes or standards.
The following items were considered,
as applicable,
during this review:
Limiting Conditions for Operation
were met while
components
or systems
were
removed
from service;
required administrative
approvals
were obtained prior to initiating the work; activities were
accomplished
using approved
procedures
and quality control hold points
were established
where required;
functional testing
was performed prior
to declaring the involved component(s)
operable; activities were
accomplished
by qualified personnel;
radiological controls were
implemented; fire protection controls were implemented;
and the
equipment
was verified to be properly returned to service.
These observations
and/or reviews included:
"B" DG inspection of damaged cylinder liners, pistons,
etc.
on
September
5,
1990.
VOTES
F002 Valve per
WA S00691
on
September
27,
1990.
"D" DG removal inspection
and installation of cylinder heads
per
WA
S04803
on September
28,
1990.
Removal
and capping of
1 inch
HRC 108/1 inch JRD 128 pipe section
for ESW modification per
WA C03543
on September
28,
1990.
Installation of Unit
1
ESW Loop "A" Supply and Return Lines
Building Freeze
Seal
Spools
and Valves per
WA C03581
on September
28,
1990.
Installation of new
RHRSW Loop "A" Heat Exchanger Inlet Outboard
Isolation Butterfly Valve per
WA C03430
on September
28,
1990.
4.3
Surveillance
Observations
The inspector
observed
andlor reviewed the following surveillance tests
to determine that the following criteria, if applicable to the specific
test,
were met:
the test conformed to Technical Specification
requirements;
administrative
approvals
and tagouts
were obtained before
initiating the surveillance;
testing
was accompli shed
by qualified
personnel
in accordance
with an approved
procedure;
test instrumentation
was calibrated;
Limiting Conditions for Operations
were met; test data
was accurate
and complete;
removal
and restoration
of the affected
components
was properly accomplished;
test results
met Technical
Specification
and procedural
requirements;
deficiencies
noted were
reviewed
and appropriately resolved;
and the surveillance
was completed
at the required
frequency.
These observations
and/or reviews included:
SO-024-013
"Offsite Power Source
and Onsite Class
1E Operability Test"
performed
on September
7.
SO-251-002
"Quarterly Core Spray
Flow Verification," - Unit 2,
performed
on September
21.
SI-180-303
"18 Month Calibration of Reactor
Vessel
Water
Level Channels
LIS-B21-1N031A,B,C,D," - Unit 1, performed
on September
27.
SO-151-002
"Quarterly Core Spray
Flow Verification,"
LOOP "A" Unit 1,
performed
on October 5.
4.4
1ns ection Findin
s
The inspector
reviewed the listed maintenance
and surveillance
activities.
The review noted that work was properly released
before its
commencement;
that systems
and components
were properly tested
before
being returned to service
and that surveillance
and maintenance
activities were conducted properly by qualified personnel.
Where
questionable
issues
arose,
the inspector verified that the licensee
took
the appropriate
action before system/component
operability was declared.
No unacceptable
conditions were identified.
5.
5. 1
Ins ection Activit
The inspector
reviewed licensee
event notifications
and reporting
requirements for events that could have required entry into the
emergency
plan.
5.2
Ins ection Findin
s
No events
were identified that required
emergency
plan entry.
No
inadequacies
were identified.
6.
SECURITY
6. 1
Ins ection Activit
PP5L's
implementation of the physical security program was verified on
a
periodic basis,
including the adequacy
of staffing, entry control, alarm
stations,
and physical
boundaries.
These
inspection activities were
conducted
in accordance
with NRC inspection
procedure
71707.
6.2 'ns ection Findin
s
The inspector
reviewed access
and egress
controls throughout the period.
No unacceptable
conditions were noted.
7.
ENGINEERING/TECHNICAL SUPPORT
7. 1
Ins ection Activit
The inspector periodically reviewed engineering
and techni'cal
s'upport
activities during this inspection
period.
The on-site Technical
(Tech)
section,
along with Nuclear Plant Engineering
(NPE) in Allentown,
provided engineering
resolution for problems during the inspection
period.
The Tech section generally addressed
the short term resolution
of problems while NPE scheduled
modifications
and design
changes,
as
appropriate,
to provide long lastirig problem correction.
The inspector
verified that problem resolutions
were thorough
and addressed
at
preventing
recurrences.
In addition, the inspector
reviewed short term
actions to ensure that the licensee's
actions
provided reasonable
assurance
that safe operation could be maintained.
7.2
Ins ection Findin
s
7.2. 1
Diesel Generator
Dama
e
Due to Sandblast Grit
As previously discussed
by
NRC Inspection
Report 50-387/90-15,
the "B",
and "D" EDG units'ngines
were extensively
damaged
by grit which was
introduced into the engines
by means of residual
sandblast grit from
the maintenance
cleaning of the cooling water tubes of the
intercoolers.
The licensee
removed the air intake manifolds
and the intercoolers
from the
EDG units.
The intercoolers
were purged of entrained
sandblast grit within the cooling fin assembly
by means of an agitated
hot water solvent bath over
a period of several
hours in which the
solvent
was replaced with new solvent several
times until the coolers
were considered
to,be adequately
cleaned.
The coolers
were then
0
subjected
to high velocity air purging in order to assure
that
combustion air through the coolers
would not transport
any additional
material
from the finned intercoolers.
During this cleaning
process
the licensee
removed
more than
a cup of sandblast grit from each
intercooler.
The licensee's
cleaning
procedures
appeared
to be
adequate
for the, removal of the grit from the intercoolers.
Mith the aid of the
EDG manufacturer's
field service personnel,
the
licensee
conducted detailed degradation
evaluation
inspections
of the
engine parts which may have
been
subjected
to the sandblast grit.
Engine
components
examined
include pi'stons, cylinder liners, cylinder
heads,
valve components,'rankshaft
journals,
connecting
rod bearings,
and engine driven oil pumps.
The licensee
found it necessary
to
replace
several
pistons,
piston wrist pins,
and cylinder liners on
each of the
EDG units.
Examination of selected
crankshaft journals
and connecting
rod bearings
did not reveal
evidence of abrasive grit
inclusion in the bearings
or scoring of the crankshaft journals.
Examination of oil pump lobes
revealed
no degradation.
Intake
and
exhaust
valves
and valve guides
were
undamaged.
Valve seats
were
refurbished
where necessary.
The camshaft,
cams
and bearings
revealed
no degradation.
The inspector
reviewed the licensee's
acceptance/rejection
criteria
for the pistons, wrist pins and cylinder liners
and performed
an
independent
visual inspection of these parts.
Based
upon these
inspection observations, it appeared
that the licensee's
inspection
criteria was adequate
to ensure
the detection
and replacement
of
defective
components.
Sand/grit in the cylinders which abrades
the piston
and cylinder liner
surfaces
can fall into the lubricating oil.
The licensee
performed
sampling
and analysis
to determine
the lubricating oil system
had
been
contaminated with abrasive particulate materials.
Findings were
as
follows:
Four main lube oil filter elements
The filters contained
what
"appears
to be very small metallic particles with a few glassy
particles" which were 1-2 'mils in size.
Oil sample
downstream of the oil filter - Analysis of this sample
revealed
no abrasive
contaminants.
Oil strainer
(downstream of oil filter) - The strainer
was found to
be contaminated
with what "appears to be construction debris
brass particles,
rust, glassy
spheres
and angular particles.
Two oily rags with oil wiped from the inside of oil delivery hoses
to main bearings.
Each of these
rags
had
a small quantity of fine
black and glassy particles
1-2 mils in size.
(Bearing to crank
clearances
are 7-8 mi ls.)
Turbocharger filter element.
This filter contained
"a very small
quantity of fine black and glassy particles
1-2 mils in size.
The
glassy particles
were described
as "ground up white, clear
particles."
From these
analyses
and the directly observable
good condition of the
engine bearing
surfaces
(which were not exposed
to direct
impingement'f
the sandblast grit), it appeared
that the oil filters provided
effective removal of any of the grit which did not settle to the
bottom of the crankcase.
In order to remove
any residual
sand
from
the oil system,
the licensee
flushed the oil system,
hand wiped the
crankcase,
replaced
the engine oil with fresh oil and installed
new
oil filters.
The inspector
reviewed the licensee's
evaluation of the potential root
causes.
The licensee
considered
procedural
deficiencies
and poor work
practices
to be the primary root causes
why the cleaning
sand
was
permitted to enter
and
become
lodged within the finned assembly of the
air side of the coolers.
Combustion air through the intercoolers
then
transported
the grit directly into the cylinders'ombustion
chambers
which resulted
in the internal
engine
damage,
The inspector
agreed
with the licensee's
root cause
assessment.
The failure of the licensee
to establish
and implement documented
instructions,
procedures,
and
controls for this critical sandblast
operation of class
1E equipment
is considered
a violation of 10 CFR 50 Appendix
B Criterion V.
(NV4
50-387/90-20-01
(Common))
8.
SAFETY ASSESSMENT/QUALITY VERIFICATION
8. 1
Licensee
Event Reports
(LER), Significant Operating
Occurrence
Report
(SOORs),
and
Open
Item (OI) Followup
(90712,
92700)
8. 1. 1
Licensee
Event
Re orts
The inspector
reviewed
LERs submitted to the
NRC to verify that
details of the event were clearly reported,
including the accuracy of
the description of the cause
and the adequacy of corrective action.
The inspector determined
whether further information was required
from
the licensee,
whether generic implications were involved, and whether
the event warranted onsite followup.
The following LERs were
reviewed:
Unit
1
90-018-00
Sand Intrusion Resulted
in Two Diesel Generators
Becoming
This event was,reviewed
in Inspection
Report
50-387/90-15;
50-388/90-15
and in Section 7.2. 1 of this
repor t.
SOORs are provided for problem identification and tracking, short
and
long term corrective actions,
and reportability evaluations.
The
licensee
uses
SOORs to document
and bring to closure
problems
identified that
may not warrant
an
LER.
The inspectors
reviewed the following SOORs during the period to
ascertain
whether:
additional
followup inspection effort or other
NRC
response
was warranted;
corrective action discussed
in the licensee's
report appears
appropriate;
generic
issues
are assessed;
and,
prompt
notification was
made, if required:
Unit
1
61
SOORs inclusive of 1-90-237 through 1-90-298
Unit 2
14
SOORs inclusive of 2-90-113 through 2-90-127
The following SOORs required inspector
fol,lowup:
1-90-294
documented
the inadvertent start of th'e "C" DG.
This event
is discussed
in Section
2'. 1.
1-90-242
documented
high chromium concentration
in the "8"
DG lube
oil.
This event
was reviewed in Inspection
Report
50-387/90-15;
50-388/90-15
and in Section 7.2.1 of this
report.
8.1.3
~0ee
Items
8. 1.3. 1
Closed
NC4 387/85-28-03.
388/85-23-02
Failure to Test Entire
Channel
Durin
Channel
Functional
Tests of HPCI Isolation and
Actuation Channels
During Routine Resident
Inspection
50-387/85-28;
50-388/85-23,
which
covered
the period August 26,
1985 through September
29,
1985,
one
violation concerning
HPCI monthly channel
functional tests
was
identified.
The inspector determined that the monthly channel
Functional
Tests
on the
HPCI isolation
and actuation
channels
did
not test the entire channel
as required
by the unit's TS.
Specifically, surveillance
procedures
SI-152-203,
SI-152-201,
SI-152-211,
and SI-180-205,
which implemented this requirement
on
the
HPCI steamline delta pressure
channels,
steam
supply pressure
~
channels,
turbine exhaust
diaphragm pressure
channels,
and the high
reactor
vessel
level trip channels,
respectively,
failed to test the
entire channel
since it did not test the last relay in the actuating
logic.
The corresponding
Unit 2 surveillance
procedures
also failed
to test the entire channel.
The response
by P.P.& L., dated
November
15,
1985,
requested
that
the Notice of Violation be withdrawn, since their position was that
testing in accordance
with their referenced
surveillance
procedures
represented
a valid interpretation of TS requirements,
rather than
a
noncompliance.
More specifically,
P.P.& L. disagreed
with the
use
of "channel"
as defined in IEEE Std. 603-1977 in the context of the
Channel
Functional
Test required
by TS.
The
TSs refer to an
instrumentation
channel
when requiring Channel
Checks,
Channel
Functional Tests,
and Channel
Calibrations.
P.P.& L. noted that the
IEEE standards
do not utilize the word instrumentation
in their
definition because
their
use of the channel
concept is not limited
to instrumentation.
In addition,
P.P.& L. stated that the
associated
relays
and contacts
referred to in the inspection report
are what is included in a Logic System'unctional
Test which is
performed
on an
18 month frequency.
P.P.& L. addressed
Information Notice 84-37 which discussed
mitigation of the
potentially adverse
safety
impact of using jumpers
and lifting leads
in support of surveillance testing to note the potential
adverse
impact of performing,
as defined,
Channel
Functional
Tests,
in this
case,
since
they would require lifted leads
on booted contacts
and
could lead to system isolations.
Finally, P.P.& L. addressed
in support of their position to note that
the additional
burden
on plant resources
would be significant.
The
licensee
believes that these factors provide sufficient
justification for defining the end of an instrument channel.
Their
definition specifies
the instrument
channel
endpoint for the purpose
of channel
functional testing
as being the input node(s) of the coil
of the actuated
relay(s) which enter into combinational
logic with
logic provided
by other channels.
P.P.& L. believes this definition
satisfies
the requirements
of their TS in that it tests all alarm
and/or trip functions of the channel
and at the
same
time minimizes
equipment,
personnel,
and time in test status.
Their position was
established
to prevent the degradation
of the safe operation of
SSES.
Following the
November
15,
1985 letter,
NRC Region
1 in conjunction
with NRR reviewed P.P.
& L.'s response.
This review resulted
in the
initial determination that P.P.& L.'s methods
were not acceptable
because
certain
components
in the channel
upstream of the
combinatorial
logic are excluded
from the
CFT.
A CFT must test to
the point where single action signals
are combined.
An entire
channel
includes all contacts,
relays,
indications,
and alarms which
precede
the combinatorial logic.
In addition,
P.P.& L.'
contention
that "channel"
may be defined other than
as in the industry
standards
because
the
TSs
use the modifier "instrumentation" is
unacceptable.
On March 5,
1986,
NRC Region I responded
to P.P.& L.'s November 15,
1985 letter.
This letter informed P.P.& L. that Region I in
conjunction with NRR reviewed
and found P.P.& L.'s response
to the
10
violation unacceptable.
It was noted that
CFTs for instrumentation
channels
must test all components
up to the point where single
action signals
are
combined
and that P.P.& L.'s methodology for CFTs
for HPCI and other
ECCS and Isolation actuation
systems
excludes
certain
components (e.g., relays)
in the channel
upstream of the
combinatorial logic.
A meeting
was held
on March 14,
1986 at the
Region I office in King of Prussia,
PA, to discuss
P.P.& L.'
plans
and schedule
to correct the testing deficiencies
in the
CFTs for
instrumentation
channels.
On April 22,
1986,
a letter from P.P.& L. was sent to the
NRC Region
I to supplement
information provided in the November
15,
1985 letter
and the meeting
on March 14,
1986.
Information requested
in the
March meeting
was provided in addition to commitments
by P.P.& L. to
further enhance
the effectiveness
of their channel
functional tests.
Information provided included:
( 1)
A statement
of P.P.& L.
philosophy for Conduct of Instrument
Channel
Functional Testing,
(2)
Description of the Channel
Functional
Tests which do not conform to
existing
NRC criteria, (3) Example of the potential benefits of
extending
the
scope of the monthly channel
functional tests,
and (4)
P.P.& L.'
experience with relay failures.
P.P.& L. noted that
there are
28 monthly channel
functional tests
which do not conform
to the
NRC criteria and these
represent
approximately
10 percent of
required tests.
Following the March 14,
1986 meeting
and P.P.& L.'s submittal of the
additional
information requested,
P.P.& L.'s failure to test the
entire
HPCI isolation
and actuation
channels
during functional
testing
was revisited.
NRR found from this review that the design
of the 28 instrument channels
affected did not provide the
same
degree of testability of the function of the channel
to initiate the
actuation logic as originally intended
by the= station's
TSs.
Addi-
tionally,
NRR determined that testing performed
up to the last relay
may damage plant equipment or disrupt reactor operation
and that
implementation of R.G.
1.22 recommendations
would require
an excessive
number of lifted leads,
jumpers,
or placing the actuated
equipment
in an inoperable
status.
As indicated
by the licensee,
these relays
are the
same type that get exercised
monthly in other safety
systems
and
have
a demonstrated reliability.
NRR therefore determined that
the program for instrument
channel
functional testing at Susquehanna
was adequate.
In conclusion,
the
NRC found that the referenced
instrument channels
failed to provide the intended
degree of testability.
This constitutes
a deviation from design basis
commitments
and therefore
should
have
been highlighted for staff review prior to plant licensing,
rather
than after the
1985
NRC inspection.
The additional
information
provided following the March 1986 meeting regarding
the
HPCI instru-
mentation's
design
was sufficient to allow NRC staff to determine
that
was acceptable
for these
items.
Since the
original lack of full testability was
a failure to meet industry
standards
rather than
a failure to meet
a regulatory requirement,
the
1985 Notice of Violation is withdrawn.
This item is closed.
e
11
NRC acceptance
of P.P.& L.'s methodology applies,
of course only to
those limited cases explicitly addressed
during
NRC review of this
item.
Any future additions and/or modifications to channel
logic
shall
conform to all requirements
applicable to Susquehanna.
8. 1.3.2
Closed
UNR 50-387/89-28-04
Common
0 erabi lit
Re uirements for
Control Structure Ventilation Fans
During
a routine inspection,
an
NRC inspector
noted that six Control
Structure
Heating, Ventilating and Air Conditioning
(CSHVAC) fans
(OV-103A and B, OV-115A and B, OV-117A and B) were not included in
TS.
The inspector also noted that these
fans provided direct
support to the operability function of CREOASS
and was concerned
when
no
TS could be found to address their operability.
The
licensee
agreed to review this'oncern.
Two additional
concerns
were also noted with transient
equipment control
and the proper
latching of the suction
plenum doors during
a tour of the area.
The licensee
addressed
the inspector's operability concern
(PLIS-34529)
by writing a Technical Specification Interpretation
(TSI) 1-90-001 to be used
by control
room operators that requires
plant shutdown if one division of CSHVAC is inoperable for greater
than
30 days.
If both divisions of CSHVAC are inoperable,
plant
shutdown is required in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
In addition, the licensee
is
completing their evaluation of the
CSHVAC safety functions.
After
it's completed,
the licensee
has
agreed to consider requesting
a
TS
amendment
to address
the results of thei r evaluation.
The transient
equipment control issue
was discussed
with the
licensee
and the licensee
discussed it with the work crew and agreed
to write a transient
equipment control procedure
by December
31,
1990.
Poor control of transient
equipment
and tools was also noted
in previous inspections
and unresolved
items were written to document
these
findings and follow the corrective actions.
The transient
equipment control procedure will be reviewed under unresolved
items
50-387/87-12-004
and 89-81-002.
The inspector
had noted during inspection
89-28 that only three of
nine latches
were secured
on the suction
plenum door.
The licensee
classified this as
an undesirable
work practice
and its correction
was emphasized
with maintenance
personnel.
The safety significance
of the concern
was minimized since the fan suction
plenums are
maintained at
a slightly negative
pressure
which tends to hold the
doors closed.
The inspector
reviewed the licensee's
response
and noted that the
TSI adequately
address
the operability support function of CSHVAC
along with the licensee
agreement
to consider
a
TS amendment.
The
equipment
and tools were
secured
and long term corrective
action
was provided.
The fan doors
were secured
and the licensee
noted this as
an undesirable
work practice.
Based
on the "above,
this item is closed.
I
12
Closed
UNR 50-387/85-09-01
Corrective Actions to Enhance
the
Vent Stack Monitorin
S stem
In May 1983,
the licensee identified a number of deficiencies with
the vent stack monitoring system
(SPING) operator interface
and
system design.
Thus,
the licensee
developed
a
SPING enhancement
project intended to improve the design of the vent stack monitoring
system
and its operator interaction.
The
SPING enhancement
project
was divided into five phases,
each consisting of various Design
Change
Packages
(DCP's) to install modifications to resolve the
identified deficiencies.
These
improvement modifications
can
be
accomplished
without affecting the system's
operation
and without an
outage.
Scope
and funding is complete for phases
1, 2,
and 4.
Some
of the DCP's/modifications within phase
1 and
4 have
been installed
and implemented (i.e.,
low point drain installation
on the Post
Accident Vent Stack Sampling Station
sample tubing and installation
of shut-off quick disconnects
on the sentry cart isolation valve
sample tubing).
Phase
1 includes the installation of a
new improved
control terminal insert to be supplied
by Eberline
and the redesign
of the Susquehanna
Terrain-Incorporating
Regional Effluent
Assessment
Model
(STREAM) interface
and is scheduled for
installation in December
1990.
The inspector
determined that the licensee
has developed
a thorough
an extensive
program to improve the performance of the vent stack
monitoring system.
Some of the planned
improvements
have already
been
implemented,
and the remaining
system
upgrades
are identified
and accurately
tracked
on the licensee's
Plant Problem List.
Therefore, this issue is considered
closed.
Even though this issue is closed,
the inspector considers
the
licensee's
actions untimely.
This item has
been
in process for
greater
than
seven years with little or no modification to the
power plant.
The inspector
has
noted that licensee
actions in
resolving technical
problem that require plant modification are
generally protracted.
The need to implement timely rev'iews in
resolving technical
concerns
has
been
emphasized
to the licensee
on
numerous
occasions.
Greater
management
involvement is necessary
in resolving technical
issues
in a timely fashion, especially
where
modifications are concerned.
The licensee
established
corrective actions to ensure that this
problem does not recur.
The air distribution in the radwaste
building will be contolled by installing portable hatch covers over
the north and south access
shafts
in the radwaste
carwash
area per
Engineering
Work Request
EWR-M-70187.
When the covers
are installed
in January
1991, the estimated ventilation supply will be
approximately
400 scfm and the exhaust air will be approximately
800
scfm.
This distribution of normal ventilation will maintain the
carwash
area slightly negative, relative to the rest of the radwaste
building.
e
13
Based
on this approach,
the inspector
has
reasonable
assurance
that
the covers will eliminate the transport of contamination
throughout
the radwaste building.
Therefore, this item is closed.
9.
MANAGEMENT AND EXIT MEETINGS
9. 1
Routine Resident Exit and Periodic Meetin
s
The inspector discussed
the findings of this inspection with station
management
throughout
and at the conclusion of the inspection period.
Based
on
NRC Region I review of this report
and discussions
held with
licensee
representatives, it was determined that this report does not
contain information subject to
10 CFR 2.790 restrictions.
9.2
Attendance
at
Mana ement Meetin
s Conducted
B
Re ion Based
Ins ectors
Dates
s
9/14
Subject
Emergency
Planning
~ins ection
~Re ort No.
90-18;90-18
~Re ortin
~ins ector
E.
Fox
ATTACHMENT
I'bbreviation
List
ANSI
CFR
'DX
ERT
J IO
LCO
LER
NPE
NRC
PC
PMR
SOOR
SP ING
Administrative Procedure
Automatic Depressurization
System
American Nuclear Standards
Institute
Containment
Atmosphere
Control
Code of Federal
Regulations
Control
Room Emergency Outside Air Supply System
Diesel
Generator
Direct Expansion
Emergency
Core Cooling System,
Engineering
Discrepancy
Report
Emergency
Preparedness
Electrical Protection
Assembly
.
Event Review Team
Engineered
Safety Features
Engineering
Engineering
Work Request
Fuel Oil
Final Safety Analysis Report
Integrated
Leak Rate Test
Justifications for Interim Operation
Limiting Condition for Operation
Licensee
Event Report
Loca1
Leak Rate Test
Loss of Coolant Accident
Motor Operated
Valve
Non Conformance
Report
Nuclear Department Instruction
Nuclear Plant Engineering
Nuclear Plant Operator
Nuclear Regulatory
Commission
Open
Item
Protective Clothing
Primary Containment Isolation System
Plant Modification Request
Quality Assurance
Reactor
Core Isolation Cooling
Regulatory Guide
Residual
Heat
Removal
Residual
Heat
Removal
Reactor Protection
System
Standby
Gas Treatment
System
Surveillance
Procedure,
Instrumentation
and Contro'1
Surveillance
Procedure,
Operations
Significant Operating Occurrence
Report
Sample Particulate,
and Noble Gas
TS
VOTES
WA
- Susquehanna
Steam Electric Station
Technical Specifications
- Technical
Support Center
Valve operator test
and evaluation
system
- Work Authorization
U.
S.
NUCLEAR REGULATORY COMMISSION
(Substitute)
Principal Inspector:
S.
BARBER
Reviewer:
P.
SWETLAND
INSPECTOR'S
REPORT
~ins ectors:
BARBER/STAIR
Licensee/Vendor:
Penns
lvania Power
8 Li ht Co.
2 North Ninth Street
Allentown
Pa.
18101
Docket ¹/Ins ection ¹/Se
. ¹:
50-387/90-20
50-388/90-20
Transaction
T
e:
X I - Insert
M - Modify
D Delete
R - Release
(A)
(B)
Period of Ins ection:
Ins ection Performed
B
Organization
Code
of Re ion
Region Office Staff
X
Resident
Inspector(s)
Performance
Appr.
Team
Other
Type of Activity Conducted
(One Only)
From
To
~Re ion Division Branch
09/02/90 10/06/90
I
B
C
X
Regional
Office Letter
X 02-Safety
03-Incident
04-Enf.
05-Mgmt.
Audit
07-Special
08-Vendor
09-Mat.Acct.
10-Plt.Sec.
12-Shipment/Export
13-Import
14-Inqui ry
15-Inve sti gati on
Ins ection Findin s:
Letter of Re ort Transmittal
Date
A
B
C
D
NRC Form 591 or
Report Sent to
- Clear
X
X
- Violation
- Deviation
Violation 5 Deviation
Total
No. of
Violations and
Deviations:
Enforcement
Conference
Held
Report Contains
2.790 Information
NO
(Substitute)
Ins ection
Re ort
Cont.
Docket No./Re ort No.
05000387/90-20
05000388/90-20
~Se
~
A
B
C
D
Module No.
10 CFR 2 App
C
Su
lement
No.
Severit /Deviation
1/2/3/4/5/6/D
Site
Related
5/35702
4
X
A
X
B
C
D
r
Violation or Deviation
52400 characters:
activities affectin
ualit
shall
be
rescribed
b
documented
instructions
rocedures
or drawin
s
a
ro riate to the circumstance
and shall
be
accom lished in accordance
with these instructions
.
endix
B
Criterion
V
Corrective Action
re uires that the
Contrar
to the above
commencin
on Au ust
29
1990 the licensee's
examinations
disclosed
extensive internal
dama
e of the
'B
and
D 'mer enc
diesel
enerators
units disclosed
extensive
internal
dama
ewhich was caused
b
the licensee's
failure to
rovide ade uate
rocedures.
This dama
e could
have led to the earl
traumatic failure of both of these diesel
enerators
had the
been called
u on to
o crate for accident conditions.
This is a Severit
Level
IV Violation
Su
lement I
9
MODULE INFORMATION A
NRC Form 766 (Cont.)
(Substitute)
Phase/
Direct
Module
Insp.
No.
Hrs.
Percent
~Com
1 ate
Status
Phase/
Direct
Module
Insp.
Percent
No.
Hrs.
~Com late
Status
5/30703
1
5/30702
5/61726
6
5/62703
16.5
5/90712
6
5/71707
36.5
5/92701
11
(71707)
5/35702
12
5/93702
2
5/92720
39.5
60K
C
MODULE INFORMATION B
Phase/
Module
No.
Direct
Insp.
Hrs.
Percent
~Com late
Status
Phase/
Direct
Module
Insp.
No.
Hrs.
M
Percent
~Com late
Status
5/71707
36
5/90712
4
5/62703,
3.5
5/92720
33
5/61726
3
5/92701
9
(71707)
5/92700
5/30702
12
s
60%
C