ML19343C634

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IE Insp Repts 50-338/80-41 & 50-339/80-38 on 801201-810110. Noncompliance Noted:Failure to Trip Inoperable Instrument within Time Frame Required by Tech Specs
ML19343C634
Person / Time
Site: North Anna  
Issue date: 03/06/1981
From: Kellogg P, Tattersall A, Webster E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19343C631 List:
References
50-338-80-41, 50-339-80-38, NUDOCS 8103240803
Download: ML19343C634 (11)


See also: IR 05000338/1980041

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

REGION 11

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101 MARIETTA ST

N.W.. SulTE 3100

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ATLANTA, GEORGIA 30303

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Report Nos. 50-338/80-4. and 50-339/80-38

Licensee: Virginia Electric and Power Company

P.O. Box 26666

Richmond, VA 23261

Facility Name: North Anna Units 1 and 2

Occket Nos. 50-338 and 50-339

License Nos. NPF-4 and NPF-7

Inspection at North Anna Site near Mineral, Virginia and Corporate Office,

Richmond,. Vi rgini a

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Inspectors:

E. H. Webste,r, Senior Resident Inspector

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A. P . Ta* e

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ent Irispector

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Approved by:

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P. J[ kev oVM

Chief, RONS Branen

Date Signed

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SUMMARY.

Inspection on December 1-January 10, 1981

Unit 1 Areas Inspected

This routine inspection by che resident inspectors involved 99 inspector-hours

onsite in the areas of plant transients, .10CFR21 reports, Task Action Plan

requirements, followup of previous concerns, licensee event reports, and

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refueling operations.

Unit 1 Findings

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Of the six areas inspected, no violations or deviations were identified in five

areas. One violation was identified in one area (Failure to trip an inoperable

instrument within the timeframe required by the Technical Specification Action

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Statement

paragraph 7.)

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Unit.2 Areas Inspected

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This routine inspection by the resident inspectors involved 113 inspector-hours

onsite in the areas of plant transients, 10CFR21 reports, Task Action Plan

requirements, followuo of previous concerns and licensee event recorts.

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Unit 2 Findings

Of the five areas inspected, no violations or deviations were identified in four

areas. One violation was identified in one area (Failure to use procedures in

activities affecting quality

paragraph 6).

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DETAILS

1.

Persons Contacted

Licensee Employees

  • W. R. Cartwright, Station Manager
  • E. W. Harrell, Assistant Station Manager

D. L. Benson, Superintendent - Technical Services

"J. R. Harper, Superintendent - Maintenance

S. L. Harvey, Superintendent - Operations

J. M. Mosticone, Operations Coordinator

R. A. Bergquest, Instrument Supervisor

J. P. Smith, Engineering Supervisor

F. Terminella, Engineering Supervisor

  • A. K. White, Engineer

P. Perrine, Computer Technician

M. A. Harrison, QC Engineer

C. T. Snow, Corporate Reactor Physics Engineer

Other licensee employees contacted included three technicians, four

operators, two security force members and several office personnel.

Other crganizations

P. Griffin, Lead Advisory Engineer, Stone & Webster Engineering Corp.

  • Attended one or more exit interviews

2.

Exit Interview '

The inspection scope and findings were s'ummarized on December 12, 1980, and

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January 16, 1981, with those persons indicated in Paragraph 1 above. The two

violations discussed in paragraphs 6 and 7 were discussed with and

acknowledged by plant management on December 12, 1980.

3.

Licensee Action on Previous Inspection Findings

a..- (0 pen) Infraction (338/80-29-01) Failure to place an inoperable

instrument channel in " trip" within the prescribed timeframe of the

Technical Specification " Limiting Condition for Operation".

During

followup of the licensee's corrective action, another instance of this

type was identified by the-licensee.

See Paragraph 7 for a complete

description of 'this issue.

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(0 pen) 'Infr'ac' tion. (339/8d '28-04)~ Failiare to implement valve lineup

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procedures for instruments important to safety.

The licensee did

develop valve lineup procedures to verify transmitter isolation valve

positions and included conduct of this procedure in the plant ~startup

checklist procedure as described in his letter of September 12, 1980.

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h3 wever, during the Unit 2 startup of November 24-30, this procedure

was not followed. This issue is described in detail in paragraph 6.

4.

Unresolved Items

Unresolved items were not identified during this inspection.

5.

Post Three Mile Island Task Action Plant Requirements

During this reporting period, the licensee requested relief from Unit 2

Operating License NPF-7 conditions in letter serial no. 930 dated

December 15, 1980. These conditions required task completions earlier than

allowed in NUREG 0737, " Clarification of TMI Action Plan Requirements". In

response, Amendment 2 to license NPF-7 dated December 29, 1980, changed the

required completion dates for all TMI tasks discussed in the license to

coincide with NUREG 0737 scheduling.

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The licensee also forwarded a response to NUREG 0737, serial no. 985 dated

December 15, 1980, which establishes new commitment dates for completion of

task items for both Unit 1 and 2, to coincide with the schedule of

NUREG 0737. This report also requests completion date extensions for six

specific items, three of which were required by January 1,1981:

- Item I.C.6 program implementation - to be completed June 1,1981

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- Item II.B.1 procedure submittal - to be completed January 1,1982

- Item II.K.3.2 report submittal - to be completed March 1,1981

The inspector verified completion of the following items due by January 1,

1981.

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Shift Technical Advisor (STA) Training Program

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NUREG 0737 item number I.A.1.1. requires the licensee to implement an

STA training program and to have on duty STA's trained by Janaury 1,

1981. Unit .2 operating license NPF-7 condition 2.C(21)(a), further

defines the minimum requirements this training program thould meet. The

licensee further committed in their -letter, serial number 277 of

.. March 26, 1980, to a minimum STA background qi.alification of 18 months

nuclear plant experience. The inspector reviewed the background of the

six STA's who will rotate shift duties. All bJt one have engineering

degrees, and.that one has an SR0 license on be.th units. All six STA's

have greater than 18 mont.ns nuclear plant expe. ience.

.The training.progra completed December 17,1980, . involved .664 hours0.00769 days <br />0.184 hours <br />0.0011 weeks <br />2.52652e-4 months <br /> of

classroom ~ instruction in~ engineering sciences given by professors from

Virginia Polytechnic Institute; folicwed by 156 classroom hours on

North Anna systems, given by t:.e licensee training staff, and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />

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of accident / transient analysis given by the licensee's fuel resources

division. Five days of simulater training was given at tne end of this

program and a final examination.was acministered on December 15. This

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program meets the requirements of license condition 2.C.(21)(a) for

initial implementation of the STA program.

The follow-on STA training program and requalification program was

reported to the NRC in letter serial no. 1022 dated December 31, 1980.

The program described appears to be adequate, and will be reviewed in

future inspections to verify adequacy.

Followup items (338/80-38-01 and 339/80-36-01) were identified to

follow task item I. A.1.1.

In this area, the staticning and initial

training of STA's has been verified. These items remain open pending

eview of the long-term program.

b.

Performance Verification

NUREG 0737 item I.C.6 requires licensee survei' lance and maintenance

activity administrative controls be uograded :.o the requirements of

Draft 3 ANS 3.2 proposed revision to ANSI N18.7-1972 section 5.2.6. The

licensee's December 15, 1980 submittal commits to completion of this

item by June 1, 1981, and indicates that interim administrative

controls would be established by January 1,1981, to meet the intent of

this requirement.

The licensee ' established Standing Order 68 prior to January 1,1981,

which directs operations supervisors to insure redundant checks of all

safety-related equipment be performed to assure operability prior to

returning it to service after maintenance or surveillance activities.

Tne adequacy of this program as well as verification of the1 final

program, when implemented, will be completed in future inspections

under the 'already designated items (338/80-38-03 and 339/80-36-03).

6.

Protec1! ion Syst'em Transmitter' Lineups (OPEN)

Infraction 339/80-28-04_ identified an item of noncompliance where procedures

concerning the alignment of the Engineered . Safeguards (ESF) and Reactor

Protection (RPS) instrument transmitter valves had not been developed. VEPC0

letter no. 738 dated September 12, 1980, stated that 2-OP-1A "Pn Startup

Checkoff List" would be reviewed to include a requirement that the ESF and

.RPS transmitter valve lineups be completed. IMP-P-MISC-11 was developed to

implement this requirement by: (1) checking transmitters against redundant

channels when the monitored variable is on scale; or (2) verifying valve

positions for transmitters that are not on scale; or (3) verifying that the

transmitter was operating satisfactorily during previous operation and no -

maintenance had been . conducted which would affect ^the transmitter. The

VEPCO. response .further -indicated that the facility would - be in full

compliance by September 15,1980. During 'this inspection', the inspector

noted while reviewing the completed procedures covering the startup of Unit

2 during the period November 24 thru November 30, 1980, that this require-

ment had not been completed. Failure to verify the service condition of the

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ESF. and RPS instrument transmitters.is a violation.(339/80-38-01) of 10CFR50

Appendix B Criterion V as icylemented by-VEPCO Topical Report VEP-3-A,

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" Quality Assurance Program Operations Phase" section 17.2.5 and the Nuclear

Power Station Quality Assurance Manual (NPSCAM), section

5,

in that

activities affecting quality were not accomplished in accordance with

written and approved procedures. When this matter was discussed with Station

Management, a commitment was made to complete IMP-P-MISC-11 prior to startup

from the current maintenance outage and the compleuo procedure was

subsequently reviewed.

T.S. 6.8.1.a also requires procedures to be followed.

IMP-P-MISC-11 was reviewed against station drawings to determine that all

ESF and RPS instrument transmitters were included in this verification. This

review showed that P -L'4-200 A, B, C, 0, " Containment Pressure" had not been

included.

These tiansmitters were added to the procedure by a Procedure

Deviation and included in the verification completed. The permanent change

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to the IMP to add these transmitters will be reviewed when complete

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(339/80-38-02).

It was also noted during this review that LT-QS-200A,B,C,0, " Refueling Water

Storage Tank" (RWST) level was not included in Technical Specification 3.3.2.1 concerning ESF instrumentation, nor were there requirements for the

automatic switchover to containment sump recirculation mode of cooling after

a Loss Of Coolant Accident in Technical Specification 3.5.2 and surveillance

requirements in 4.5.2.e(1).

This fact was discussed with the NRR Project

Manager, who is implementing a request to VEPC0 to have these Technical

Specifications modified.

This item is also applicable to Unit

1.

Completion of these changer is designated 338/80-41-01 and 339/80-38-03 and

will be' reviewed when compieted.

Procedure 2-PC-36.1 " Safety Injection

System Functional Test Breakers and Valves" conducted June 14 thru 22,1979,

did verify that the required valves did reposition to their recirculation

made upon actuation of the low low level in the RWST.

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Failure to Trip llevel Bistable (OPEN)

During a previous inspection, it was determined that a protection system

channel had not been placed in a tripped condition within the specified

timeframe of being considered inoperable. This instance was identified as

an Infraction, 338/80-29-01.

VEPCO letter no. 738 dated September 12,

1980, gave the corrective action for this infraction and stated that full

compliance would be achieved by September 10,1980. During this inspection

period, the infraction and the corrective . action were being reviewed in

order to close this issue. Standing Order #1 was reviewed and it was noted

that it had been revised to emphasize the actions ts be taken when

protective channels are determined to be inoperable and that these actions

should be taken first and then an. investigation into the cause of the

fai. lure should be commenced. This revision-was the stated corrective action

for the infraction.

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The inspector noted during the review of this item, that a recent LER No.

80-097/03LO, for Unit I reported as event similar to the initiating event

for this previvus infraction had been submitted. In the case of the event

recorted by the 'LER, the Channel I A Steam Generator (S/G) Level (LT-1474)

readinc at C200 on November it,1930,.was greater than 5% different from the

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average of three protection system channels for A S/G level. This condition

was logged again at 0600 and 1000 on November 14, 1980. At approximately

1130 on November 14, 1980, the determination that tne channel was inoperable

was made and the protection ChannelI for S/G A level was placed in a tripped

condition. This was approximately 9h hours after the condition was first

logged, where as license NPF-4 Technical Specification 3.3.1.1.

Action

Statement 7 states that the channel must be placed in trip within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of

being determined inoperable. This sequence of events is as reported in the

LER and has been verified by review of 1-LCG-4, " Control Room Operators

Surveillance Sheets", for November 13 and November 14, and 1-LOG-11, " Action

Statement Status Log." This failure to olace the protection system channel

in trip within the specified time of being inoperable is a violation of

Technical Specification 3.3.1.1 (338/80-al-02), identified by the licensee

and this item is considered to be a repetition of the previous inTraction.

8.

Fire Doors

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On December 15, 1980, while touring plant areas, the inspector noted that

the fire door for the 2H Emergency Diesel Generator Room did not close

automatically when released. A Maintenance Report sticker attached to the

door indicated that the door closer was broken and that a Maintenance Report

had been initiated on December 13, 1980. The inspector informed the shift

supervisor of the problem with the donc closer and that the door should be

considered inoperable and action taken as required by License NPF-7 Tech-

nical Specification 3.7.15.

The shift supervisor immediately posted a fire

watch as required and initiated a Deviation Report. In that the fire watch

was not stationed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of identifying the door as inoperable, this

is a violation of Technical Specification 3.7.15.

However, as this . item was

identified prior to the licensee's response to I.E. Report 339/80-33, this

' item is identified as another example of the . noncompliance (Infraction

'339/80-33-04) as discussed in I.E. Report 50-339/80-33.

9.

(Closed) Items (338/79-01-03 and 339/79-01-03)

Axial Power Distribution Monitoring System (APDMS) program errors - 10CFR Part 21 reports. These item numbers were previously identified to track

final resolution of two software errors identified in late 1978 and early

1979 which could result in nonconservative ' axial flux shapes existing

without detection or alarm by the on-line APDMS.

IE Report 338/79-01

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identified corrective action steps taken by the licensee for Unit 1, which

at that time was the only operational unit at North Anna.

This inspector

reconfirmed the licensee's corrective actions for both APCMS deficiencies

for both Units 1 and 2.

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The inspector reviewed flux map traces used during the' Unit 2 startup test

program and the T(Z) calculations performed by VEPCO's Fuel Resources Group

to provide alarm setpoints .for both the APCMS and its backup "FQSURVEY"

program of the PRODAC P-250 comouter.

Fuel Resource Group crocedures for

comoutation - of the APCMS limits were reviewed and verified that limit

reduction factors of 0.985 and 0.98, respectively were applied to the

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computer results to account for the APCMS two digit round-off and the

potential errors due to high background signal detected on APCMS monitoring.

The . inspector verified that the backup "FQSURVEY" program adecuately

functions to alert the operator of abnormal axial flux shapes or bad incere

data.

In a computer program checkout conducted in October 1980, the

licensee staff from the Fuel Resources Group tested the "FQSURVEY" program

on the Unit 2 computer. Their internal report, dated November 4,

1980,

verified the program functional and tested all alarm console messages. The

report verified that the "FQSURVEY" program does not round-off results, coes

subtract background signal and alarms to identify abnormally high background

signal (over 0.01) exists.

The inspector. reviewed the surveillance procedures to verify limit setpoint

inputs were properly inserted into APCMS and "FQSURVEY" program (procedure

PT-22) and verified. Further, the operator is capable of reviewing FQSURVEY

and APCMS limits at any time, to insure they are correct.

The inspector was not able to confirm licensee administrative controls of

the incore detector background levels during tnis inspection. Coen Items

(338/79-01-03 and 339/79-01-03) remains open pending review of surveillance

controls affecting incere detector performance.

10. Containment Supplementary Shielding (Closed)

On May 5, 1978, LER 78-33/0IT-0, reported that there were higher than

expected neutron dose rates being experienced at North Anna Power Station

Unit I due to streaming from the vicinity of the reactor cavity. This same

concern was identified for Unit 2 by VEPC0 letter no. 300 dated May 25,

1978, submitted in accordance with 10CFR50.55(e). Subsequently, modift-

cations were made to Unit 1 by Design Change 78-507 and to Unit 2 by

Engineering and Design-Coordination Reports (E&DCR) P-2502, 2530 thru 25300,

25778, 25779, 25785,' 40189, 40191 thru 401918 and 40195. Installation of

the hardware modifications was previously inspected as reported in IE Report

338/79-52 paragraph 5.b for Unit I and IE Report 339/79-44 paragraph 6.a for

Unit 2.

Items 338/78-14-04 and 339/78-12-02, were left open pending a

review of the radiation surveys conducted after installation of the

thielding.

During .this inspection, the following data was reviewed to

determine the adequacy of the shielding:

a.

1-SU-8, " Containment Shielding and Radiation Survey" Unit 1, dated

5/14/78, conducted at 100% power prior to shielding modifications.

b.

1-SU-8, Unit 1, dated February 7,1980, conducted at 100% power after

the shielding modifications.

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2-SU-8, Unit 2, dated October 15, 1980, conducted'at 100% after the

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shielding modifications.

The results of these surveys indicate that a significant reduction in

neutron dose rates was achieved. The' insoector had no further questions

concerning this subject anc items .338/78-14-04 and 339/78-12-02 are closed.

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11.

Engineered Safeguards Logic Testing (CLOSED)

During a previous inspection, it was determined that 2-PT-36.1 " Reactor

Protection and ESF Logic Test" did not adequately record all possible

results of the testing. This item was identified as 339/80-28-08.

During

this inspection 1-PT-36.1 Revision 11 dated 7/23/80, and 2-PT-36.1 Revision

5, dated 7/23/80 were reviewed. The inspector noted that step 4.7 in botn

procedures had been modified so as to record the results of the logic test

while the Blocking Function Test Switch was in both positions of Inhibit

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Blocks (IB) and Blocks Not Inhibit (BNI).

The inspector had no further

questions concerning this subject and item 339/80-28-08 is closed.

12. Tolerance on Test Inputs (Closed)

Items 338/80-30-04 and 339/80-29-10 identified an inspector concurn with the

failure to indicate a tolerance for test inputs in instrument functional

tests. During this inspection, Instrument Department Memorandum No. 23,

dated November 6, 1980, was reviewed. This memorandum states that test

inputs must be achieved with no tolerance. If the input can not be achieved

as stated, the test is to be suspended and the problem resolved with the

technician's supervisor. The inspector had no further questions on this

subject and items 338/80-30-04 and 339/80-29-10 are closed.

13. Qualification Records for Instrument Technicians (Closed)

During a previous inspection, the fact that contract instrument technicians

did not have qualification records was identified and designated as

inspector followup items 338/80-30-05 and 339/80-29-11.

During this

inspection, selected qualification records for contract instrument techni-

cians and VEPCO personnel were reviewed. Additionally, Instrument Depart-

ment Memorandum No. 14,. dated November 6, 1980, was reviewed. It was noted

that these records appear to be up to date and to indicate the qualification

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of instrument personnel, a status of qualification printout is also required

and is utilized by supervisory personnel in job assignments. The inspector

had no further questions on this subject and items 338/80-30-05 and

339/80-29-11 are closed.

14. Reactor Trip and Safety Injection (CLOSED)

Licensee Event Report (LER) 80-47/0IT-0 covered the react 9r trip and safety

injection event that occurred at North Anna Power Station Unit 1 on May 23,

1980. Item 338/80-19-03 stated that further review of the

initiating

event would be conducted at a later date.

.The initiating event for this occurrence was determined to be the starting

of a Reactor Coolant Pump (RCP) on ' Unit 2 that was being powered from the

same preferred offsite power supply as an emergency bus on Unit 1.

Additionally, the IJ Emergency Diesel Generator (D/G) was paralleled to the

emergency bus undergoing testing to determine acerability. The current

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surge. due to the starting of the RCP and the resulting voltage deco caused

the breaker to the emergency bus from tne offsite power source to trip on

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reverse current. This removed a significant load from the 0/G and caused

the voltage on the emergency bus to spike high. Due to this voltage spike,

the power supply fuses to 1-VB-I-03, inverter for vital bus III, opened and

Vital Bus III de-energized. The resultant sequence is described in the LER.

This event has been reviewed by the resident inspectors and was the suoject

of a discussion on July 24, 1980, between IE Headquarters, VEPC0 corporate

engineering, Station Management and this inspector.

Based upon these

discussions and reviews, the inspectee had no further questions concerning

the initiating event and item 338/80-19-23 is closed.

Corrective action outlined in LER 80-47 was reviewed for adequacy and to

determine the state of implementation. Procedure I-0P-5.2, dated 6/25/80,

was reviewed and the cautions added concerning starting Reactor Coolant

Pumps on Reserve Station Service power were noted. Standing Order NO. 52,

which discusses starting large electrical loads when an Emergency Diesel

Generator is paralleled to the bus, Maintenance Reports NI-50-0605-2031,

2032, 2033, 2034, 2035, which replaced the control and power fuses in the

four vital AC inverters and computer inverter; and Preventative Maintenance

M-20-0/R-6 which requires replacement of the D/G governors every five years

with rebuilt governors supplied by the vendor; were reviewed. The inspector

had no further questions concerning the corrective action required by LER

80-47.

15. Record Retention

In order to- determine the calibration history of the

T/TAVG protection.

channels, it was necessary for the inspector to review the results of

1-PT-31.2.1, " Reactor Coolant System Temperature Instrumentation Calibra-

tion" (T-412) Channel

I, 1-PT-31.2.2 (T-422) Protection Channel II and

1-PT-31.2.3 (T-432) Protection Channel III. When retrieval of these PT's

was requested,_it was determined that the PT's were not in Station Records

as required. The instrumen't calibration procedures ICP-P-1-T-412, 422, 423,

which are initiated by the respective periodic test (PT) were also requested

from Station Records, but only ICP-P-1-T412 was in the vault. Discussion

with the engineer responsible for logging completion of the PT's indicated

that his records showed only 1-PT-31.2.1 and 31.2.2 as being completed.

These calibrations were required to have been done during the last Unit I

refueling outage in the fall of 1979. Continued review showed that copies

of the completed instrument calibrations were available from the Instrument

Shop. Although not the formal record, these were sufficient to show the

calibration of the protection loops had been conducted as required. The

- problems 'with retrieving the completed periodic test proceduros, the

completed instrument calibration procedures and the record of completed

periodic tests maintained by Engineering is designated as inspector followup

item (338/80-41-03).

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16.

Plant Tours

Tours of various plant areas were conducted during the inspection period in

conjunction with other inspection activities.

The following i tems, as

available, were observed:

a.

Fire Equipment

Operability and evidence of periodic inspection of fire suppression

equipment.

b.

Houseke'eping

Minimal accumulations of debris of maintenance of required cleanliness

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levels in systems following testing. Cbservations regarding certain

areas were given to station management who acknowledged the inspector's

comments.

c.

Equipment Preservation

Maintenance of special preservative measures for installed equipment as

applicable.

d.

Component Tagging

Implementation and observance of - equipment tagging for - safety. or

equipment protection.

e.

Communication

Effectiveness of public system in all areas toured.

f.

Equipment Controls

Effectiveness of jurisdictional controls in precluding unauthorized

work or systems turned over for initial operations or preoperational

testing.

g. - Foreign Material Exclusion-

Maintenance of controls to assure systems which have been cleaned and

flushed are not reopened to admit foreign material.

h.

Security

lfmplementation of' security provisions for both Units.

Within the above areas, 'no violations or deviations were observed when

compared to the acolicable station program and procedures.

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