ML20126B753
| ML20126B753 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/08/1992 |
| From: | Larry Nicholson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20126B702 | List: |
| References | |
| 50-317-92-27, 50-318-92-27, EA-92-237, NUDOCS 9212220198 | |
| Download: ML20126B753 (22) | |
See also: IR 05000317/1992027
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U.S. NUCLEAR REGULATORY COMhilSSION
REGION I
Report Nos.
50 317/92-27; 50-318/92-27
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License Nos.
DPR-53/DPR-69
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Licensee:
Baltimore Gas hnd Electric Company
Post Office Box 1475
Baltimore, hiaryland 21203
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Facility:
Calvert Cliffs Nuclear Power Plant, Units I and 2
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Location:
Lusby, hiaryland
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inspection conducted:
October 11, 1992, through November 21,1992
Inspectors:
Peter R. Wilson, Senior Resident inspector
Carl F. Lyon, Resident inspector
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Scot A. Greenlee, Reactor Engineer, DRP
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Daniel T. Afoy, Reactor Engineer, DRS
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[Dar6 :. Nicholson, Chief
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Approved by:
)$at6
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Rea or Projects Section No.- l A
Division of Reactor Projects
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htsnu11on sununnrr
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This inspection report documents resident inspector core, regional initiative, and reactive
inspections performed during day and backshift hours of station activities including: plant
operations; radiological protection; surveillance and maintenance; emergency preparedness;
security; engineering and technical support; and safety assessment / quality verification.
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IlmilLS:
See Executive Summary.
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9212220198 921216'
ADOCK 05000317
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EXECUTIVE SUMMARY
CalmLCJjffs Nucienr Power Plant. Units 1 and 2
htwection Report Nos. 50-317/92-27 and 50-318/92-27
I'limt Opera 112nst (Operational Safety inspection Module 71707, Prompt Onsite Response to
Events at Operating Power Reactors Module 93702) 110th units operated without significant
events during the period. The inspectors noted varying levels of housekeeping. The Unit I
service water pump room had been restored and was in excellent condition,
llowever,
housekeeping in the control room ventilation room was weak.
Badiological Protec1]sn: (Module 71707) The inspector concluded, based on selected reviews,
that the radiciogical controls program and implementation was generally acceptable.
Mainitrutnce and Surveilliutte:
(Maintenance Observations Module 62703, Surveillance
Observations Module 61726) During the period,11G&E discovered that as part of a monthly
surveillance test, the emergency core cooling system was placed in a configuration that
potentially could have damaged safety injection and containment spray pumps during certain
accident conditions. This issue was unresolved pending further NRC and BG&E review.
Continuing weakness in the implementation of foreign material exclusion controls was observed
during the replacement of the No. 23 salt water pump. The inspectors noted that BG&E was
successful in reducing the number of control room deficiencies during the period.
Engineering and Technical Suppmi: (Module 71707) As part of a design basis reconstitution
effort, BG&E found that a postulated fire in the room containing the control room heating
ventilation and air conditioning units could potentially prevent the safe shutdown of both units.
BG&E interim compensatory measures were acceptable. ' This issue was unresolved at the end
of the inspection period. The inspectors also found that BG&E's response to several issues
identified by the Vendor Audits Unit was acceptable. The inspectors found that certain BG&E
actions in response to Generic Ixtter 88-17 %ss of Decay Heat Removal" were acceptable.
Snfety Assessment /Ounlity Verifiention: (Modules 71707,30703) 11G&E's actions to several
Vendor Audit Unit findings were reviewed. The inspectors found that BG&E was taking
appropriate actions to address the findings. However, in one instance the inspectors were
concerned that BG&E did not document their initial operability determination for the containment
lodine removal units.
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DETAILS
1.0
SUMMARY OF FACILITY ACTIVITIES
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Unit I completed escalation to full power on October 1I following a planned power reduction.
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On November 15, power was reduced to 65% as a precaution due to smoke emanating from oil
soaked lagging on the 12 steam generator feed pump. The lagging had become soaked over time
due to minor oil seepage from one of the journal bearings. The lagging, which had been
improperly installed during the previous pump overhaul and was obstructing normal oil leakoff,
was removed. The area was cleaned, and the unit returned to full power in approximately six
hours. The unit remained at power for the remainder of the period.
Unit 2 began the period at full power. On October 18, power was reduced to 60% for
approximately nine hours to establish safe conditions for removing a damaged breaker from a
turbine motor control center. The evolution was completed without incident and the unit
returned to full power the same day. The unit remained at power for the remainder of the
period.
2.0
PLANT OPEltATIONS
2.1
OperationaLSafety_Ystification
The inspectors observed plant operation and verified that the facility was operated safely and in
accordance with licensee procedures and regulatory requirements. Regular tours were conducted
of the following plant areas:
-- control room
-- security access point
- primary auxiliary building
-- protected area fence
-- radiological control point
-- intake structure
-- cicctrical switchgear rooms
-- diesel generator rooms
-- auxiliary feedwater pump rooms
- turbine building
Control room instruments and plant computer indications were observed for correlation between
channels and for conformance with technical specincation (TS) requirements. Operability of
engineered safety features, other safety related systems and onsite and offsite power murces was
verified. The inspectors observed various alarm conditions and confirmed that operator response
was in accordance with plant operating procedures. Routine operations surveillance testing was
also observed. Compliance with TS and implementation of appropriate action statements for
equipment out of service was inspected. Plant radiation monitoring system indications and plant
stack traces were reviewed for unexpected changes.
legs and records were reviewed to
determine if entries were accurate and identified equipment status or deficiencies. These records
included operating logs, turnover sheets, system safety tags and temporary modifications log.
Plant housekeeping controls were monitored, including control and storage of flammable material
and other potential safety hazards. The inspectors also examined the condition of various fire
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protection, meteorological, and scismic monitoring systems. Control room and shift manning
were compared to regulatory requirements and portions of shift turnovers were observed. The
inspectors found that control room access was properly controlled and that a professional
atmosphere was maintained.
In addition to normal utility working hours, the review of plant operations was routinely
conducted during backshifts (evening shifts) and deep backshifts (weekend and midnight shifts).
Extended coverage was provided for 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> during backshifts and 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> during deep
backshifts. Operators were alert and displayed no signs of inattention to duty or fatigue.
The inspectors observed an acceptable level of performance during the inspection tours detailed
above.
The inspectors noted varying levels of housekeeping during inspection tours. For instance, the
Unit I service water pump room has recently been restored and was in excellent condition. By
contrast, the inspectors found excessive dirt and debris under both the control room heating and
ventilation (HVAC) units, including dried leaves and a roll of tape. BG&E subsequently cleaned
thisarea.
2.2
Followup of Events Occurring During Insocction Period
No significant plant events occurred during the period.
3.0
RADIOLOGICAL CONTROLS
During tours of the accessible plant areas, the inspectors observed the implementation of selected
portions of the licensee's Radiological Controls Program. The utilization and compliance with
special work permits (SWPs) were reviewed to ensure detailed descriptions of radiological
conditions were provided and that personnel adhered to SWP requirements. The inspectors
observed that controls of access to various radiologically controlled areas and use of personnel
monitors and frisking methods upon exit from these areas were adequate. Posting and control
of radiation areas, contaminated areas and hot spots, and labelling and control of containers
holding radioactive materials were verified to be in accordance with licensee procedures.
Health Physics technician control and monitoring of these activities were determined to be
adequate. Overall, an acceptable level of performance was observed.
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4.0
MAINTENANCE AND SURVEILLANCE
4.1
hialntenance Observation
The inspector reviewed selected maintenance activities to assure that:
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the activity did not violate technical specification limiting conditions for operation and
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that redundant components were operable;
required approvals and releases had beca obtained prior to commencing work;
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procedures used for the task were adequate and work was within the skills of the trade;
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activities were accomplished by quallned personnel;
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where necessary, radiological and fire preventive controls were adequate and
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implemented;
quality verincation hold points were established where required and observed; and
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equipment was properly tested and returned to service.
The work observed was generally performed safely and in accordance with proper procedures,
inspectors noted that an appropriate level of supervisory attention was given to the work
depending on its priority and difnculty. Notable observations are included below for selected
activities hiaintenance activities reviewed included:
hio 29200632
Replace 2-SV-3830, the 22 SDCilX component cooling outlet valve
h10 29205683
Clean 22 ECCS cooler basket strainer
hiO 292N703
Bullet 22 SRWilX
h10 29204737
Bullet 22 CCllX
hiO 292N704
Bullet 21 SRWIIX
h10 29205062
Bullet 21 CCilX
hiO 19207487
Replace 1-RV-5200 relief valve for No.11 Salt Water Air Compressor
hiO 19200136
Replace Unit I axial power differential dual potentiometers
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MO 29285318
Remove and replace No. 23 Salt Water Pump Volute
See comments of section 4.2.
MO 29205396
Install new No. 23 Salt Water Pump
MO 29206300
Adjust position indication on 2-SI 648, the 22A SIT check valve leakage
drain
With regards to MO 29206300, the inspectors discussed the work package, scope, and
contingency plans with the instrument technicians and supervisors. The work required a
containment entry at power. Inspectors attended the radiological controls brief and observed the
entry. The post maintenance testing w.s observed from the control room. The radiological
controls brief was clear and comprehensive and good coordination was noted Intween
maintenance, radiation controls, and operations in performing the work.
4.2
While observing the replacement of the No. 23 salt water pump volute (MO 29285318), the
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inspectors found that the foreign material exclusion (FME) requirements specified for the
maintenance activity were not rigorously implemented. The foreign material controls checklist
associated with the maintenance orde-r required, in part, that maintenance personnel wear
protective clothing, remove loose articles from their pockets, and to secure their security badges
and dosimetry.
The inspectors observed that some maintenance personnel had loose articles in their coverall
pockets and had not secured their security badges and dosimetry. Of greater concem was that
a maintenance supervisor, who entered the work area to assist in removing an expansion joint,
did not meet any of the above requirements. Although the FME requtrements were not
rigorously followed, the inspectors did not Ond that any foreign material had been introduced
into the salt water system.
The failure to adequately implement foreign material exclusion control requirements is a
continuing problem.
In May 1992, the inspectors Uentified several instances where the
requirements of the foreign material check lists were not rigorously implemented (see Inspection
Report 50-317 and 318/92-15).
The inspectors discussed the above concerns with the General Supervisor-Mechanical
Maintenance (GS MM). The GS-MM subsequently conducted a review of the concern which
also found that the controls were not rigorously implemented. The GS-MM also concluded that
the foreign material controls checklist required controls that exceeded the measures required to
ensure FME in this application and should have been revised. The inspectors concurred with this
assessment.
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The key issue remaining was that the workers and a supervisor did not rigorously follow the
prescribed requirements for FME or change them to reDect the actual working conditions. The
GS-MM subsequently counselled the individuals involved concerning the importance of the FME
requirements, and the importance of initiating a formal change to the requirements if they do not
Gt the situation,
in summary, there were no safety consequences as a result of the above occurrence because no
foreign material was introduced into the salt water system. However, the inspectors were
concerned that implementation of foreign material exclusion control requirements continued to
be a weakness not only with some maintenance personnel but with at least one maintenance
supervisor as well.
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4.3
CnDkol ikum_Ddiciencies
During the inspection period, the inspectors held several discussions with maintenance and
ojwrations mangers concerning the large number of control room denciencies. At the beginning
of the period there were approximately 174 control room deficiencies being tracked by BG&E's
Instrumentation and Control section.
The inspectors were concerned that some of these
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deficiencies could present unnecessary challenges to control room operators during plant events.
The inspectors reviewed the list of outstanding deficiencies and determined that many identified
deficiencies were on secondary systems or actually identified concerns outside the control room.
However, there were several deficiencies including out of service instruments and valve position
indicators that could potentially impede prompt operator action. For example, there were several
isolation valve position indicators which indicated the valves to be in a mid position when the
valves were shut.
BG&E concurred that the number of control room deficiencies was too high and that some
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deficiencies represented potential challenges to prompt operator actions during plant events.
BG&E conducted a review of all the deficiencies and escalated the maintenance priority of those
items which would encumber operator actions. By the end of the period, BG&E had reduced
the number of denciencies by approximately 30 items. The inspectors will continue to monitor
BG&E's progress in reducing the number of deficiencies.
4.4
Surveillance Observation
The inspectors witnessed / reviewed selected surveillance tests to determine whether properly
approved procedures were in use, details were adequate, test instrumentation was properly
calibrated and used, techmcal specifications were satisRed, testing was performed by quali6ed
personnel, and test results satisfied acceptance criteria or were properly dispositioned.
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The surveillance testing was performed safely and in accordance with proper procedures.
Inspectors noted that an appropriate level of supervisory attention was given to the testing
depending on its sensitivity and difficulty. Notable observations are included below for selected
activities. The following surveillance testing activities were reviewed:
STP O-65-2
Stroke time test of the 22 SDCHX component cooling outlet valve,2-SV-
3830
STP O-8C-0
Semi annual test of 12 EDG and 14 4kV bus LOCl sequencer
STP O-8C-2
Semi annual test of 21 EDG and 24 4kV bus LOCl sequencer
STP hi-212C-1
Channel C reactor protection system functional test
STP O-5-1
AFW system monthly test
4.5
Main Steam Isolation Valve Partial Stroke Test
On October 12, the No. 22 main steam isolation valve (MSIV) failed to reopen after a partial
stroke test using the B hydraulic circuit. Operators were per:orming STP O-47B 2, "B Circuit
MSIV Partial Stroke Test," which tests the MSIV by stroking it 10% closed and then re-opening
it. Operators determined that the B hydraulle circuit was leaking back to the reservoir via the
main dump solenoid valve,2-SV-40478. The B hydraulic circuit was isolated and the MSIV
fully re-opened. Subsequent investigation determined that the dump solenoid valve spring was
incorrectly adjusted. The spring adjustment lock nut was also loose.
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The spring was readjusted and set in accordance with the technical manual. The M51V was
retested satisfactorily using the B hydraulic circuit.
The solenoid valve had been replaced following the August 17 Unit 2 trip. Since the spring -
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adjustment is normally set at the factory, it was not verified during installation. Although the
adjustment is described in a separate section of the manual, it is not described in the section used
for solenoid replacement. BG&E intends to add a note to the technical manual referencing the
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adjustment, in addition, other spare solenoids in stock have been placed on hold until their
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spring adjustment is verified.
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Inspectors observed the spring adjustment and testing of the MSIV and reviewed the technical
manual and operability assessment for the MSIV. Operations personnel demonstrated a good
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questioning attitude in discerning and inve<tigating the problem. Systems engineering unit's
input to the operability assessment' was prompt and thorough,
Good coordination was
demonstrated by operations, systems engineering, and maintenance in safely resolving the issue.
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4.6
ECCS Pumo Recirculation Line Testing
On November 12, BG&E determined that all Unit 2 cmergency core cooling systems (ECCSs)
could have failed if a small break loss of coolant accident (LOCA) had occurred during the
performance of monthly surveillance test procedure (STP) 0-7-2, ' Engineered Safety Features
(ESP) logie Test." Specincally, a portion of the STP required the closure of the isolation valves
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in the common ECCS minimum now recirculation line. With either recirculation line valve shut,
any ECCS pumps which were operated without an adequate discharge path (such as might exist
during some small break LOCA conditions) could have been damaged because of operation at
shutoff head. The same system con 0guration and testing requirements existed on Unit 1.
a.
Discovery of the Problem
11G&E discovered the problem while investigating a 10 CFR 21 notification issued by Liberty
Technologies on October 2 pertaining to their Valve Operation and Test Evaluation System
(VOTES) for motor operated valves (MOVs). The notincation concerned deficiencies in the
VOTES diagnostic software which could have led to indicated stem thrust measurements being
less than the actual thrust. As a result, the potential for exceeding the allowable thrust limits on
some MOVs was a concern.
As part of IlG&E's investigation, the MOV Group contacted STP and in-Service Test (IST)
personnel to get information on how often the suspect valves were cycled. They deduced that
2-SI-659 was being shut for ASME XI testing during cold shutdown as well as during STP O 7 2
while at power. The other minimum flow return to RWT valve, 2-SI-660-MOV, and the
duplicate valves on Unit I were similarly operated and tested. STP personnel recognized that
failure of one of the recirculation valves in the closed position during operation would cause loss
of recirculation capability for multiple trains of ECCS.
b.
System Description
Calvert Cliffs 2 has a common recirculation line to the RWT for all of its high pressure safety
injection (HPSI) pumps, low pressure safety injection (LPSI) pumps, and containment spray (CS)
pumps; As a result,2-SI-659 or 2-SI-660 isolate the recirculation now for all ECCS pumps.
Unit 1 is a duplicate system.
A safety injection actuation signal (SIAS) will start two HPSI pumps, both LPSI pumps and both
CS pumps. When reactor coolant system pressure falls below approximately 1275 psig, the
HPSI pumps start delivering now through both the high pressure header and the auxiliary high
pressure header. If reactor coolant pressure falls below approximately 200 psig, the passive
pressurized safety injection tanks will start delivering flow into each cold leg along with the LPSI
pumps. Both CS pumps start on a SIAS, but the CS header discharge valves do not open until
containment pressure rises to the containment spray actuation setpoint. The safety injection
= pumps initially drav. borated water from the RWT. This tank has suf0cient water volume to
supply safety injection flow for u'p to 36 minutes assuming two HPSI and two LPSI pumps and
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two CS pumps are running. When the RWT level reaches the Recirculation Actuation Signal
(RAS) setpoint, a recirculation actuation occurs which opens the isolation valves in thMwo lines
from the containment sump and shuts down the LPSI pumps. The earliest that automatic
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recirculation would occur is 36 minutes assuming all engineered safety features pumps are
running.
2-SI-659 and 660 are normally open, four inch gate valves which must be shut to isolate the
IIPSI, LPSI, and CS minimum flow recirculation lines from the RWT upon receipt of a RAS.
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The valves are operated from the control roomt however, power is normally removed from the
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valve operators by a "lockous" switch which is also in the control room. Additionally, the valves
are administratively controlled. When a RAS occurs, a " Safety injection Pump Recirculating
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MOV Closed / RAS Blocked" alarm would actuate in the control room to prompt the operator
to close 2-SI-659 and 660. The valves do not have an automatic open feature,
c.
Safety Concerns
if SI-659 or 660 are shut and a LOCA occurs, the ECCS and CS pumps will run at shutoff head.
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According to the vender, Bingham, the 11 PSI pumps would fail in less than one minute. The
LPSI pumps would fail after several minutes. Information on the CS pumps was not available;
however, if the CS path to the containment atmosphere was open, they would not be at shutoff
head.
The inspectors .identiDed one occasion in July,1992, when the 11 CS and i1 1-IPSI pumps were
run for over one minute at shutoff head without recirculation Dow (see NRC Inspection Report
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50 317 and 318/92-19, section 4.2.a.) Contrary to the vender infoimation above, testing and
analysis of pump performance data demonstrated that neither pump was signiDeantly affected by_
the short shutoff head run and both pumps remained operable.
SI-659 and 660 were shut for approximately ten minutes each month for 1 sting of:he RAS logic
modules during the performance of STP O-7. As directed by the procedure during RAS logic
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testing, the operators removed one train of IIPSI and LPCI by placing the pumps' control
switches in -" pull to lock" to prevent inadvertent actuation. The STP has been conducted with
this requirement since plant startup in 1974. BG&E's preliminary investigation concluded that
if the recirculation valves were shut for the performance of STP O-7 and a LOCA_ occurred,
operators would have sufficient time to open ths valves to prevent ECCS pump failure. They
also _ concluded that the Unit I recirculation valves would open against liPSI shutoff head.
BG&E initially concluded that 2-SI-659 and 660 would not have opened against liPSI shutoff
head because they have a lighter spring pack. Based on that conclusion, BG&E made a four
hour report to the NRC on November 12 in accordance with 10- CFR 5_0.72(b)(2)(iii).
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Subsequent to that report, BG&E has done further calculations that demonstrate that 2-SI-659 and-
660 would open against liPSI shutoff head. The inspectors reviewed these calculations and
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concurred with the results.
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IlG&L and the NRC have determined that there were several earlier possible opportunities to
identify and correct the condition.
NRC Ilulletin 86-03, " Potential Failure of hiultiple ECCS Pumps due to Single Failure
of Air Operated Valve in hiinimum Flow Recirculation Line"
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NRC llulletin 88-04, " Potential Safety kelated Pump Loss"
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ash!E Section XI Second Ten Year 'nterval IST Program: A letter from hir. J. Tiernan
(llG&E) to Document Control Desk (NRC), dated July 5,1988, Proposed Pump and
Valve IST Program, clearly identifies that failure of 1/2 h10V-659/660 in the closed
position during operation would cause an entire safety system to become inoperable. The
letter also says that these valves will be full stroke exercised at Cold Shutdown as allowed
by Section XI. The NRC accepted IlG&E's Second Ten Year Interval 1ST Program in
a letter to hir. G. Creel (IlG&E), dated September 20,1990.
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Correspondence from initial construction (letter from O. Parr (NRC) to J. Gore (IlG&E),
dated February 5,1976) also recognized that a failure of the minimum flow bypass
system could result in the loss of the ECCS function during the injection mode, or
prevent proper isolation of the RWT during the recirculation mode. BG&E's response
(letter from J. Gore (IlG&E) to O. Parr (NRC), dated hfarch 4,1976, ECCS) proposed
a modification to prevent single failure of hiOV-659/660 and noted that the valves are
open during normal unit operation and must remain open during SIAS until adequate
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cooling flow is established through the safety injection pumps.
There is also some question as to whether 11G&E program efforts such as the Technical
Adequacy Review Project, Individual Plant Evaluation, or the Procedure (Jpgrade Program could
have identified the issue earlier.
d.
Corrective Actions
BG&E has changed STP O-7 for both units to prevent the closure of the recirculation valves,
in addition, they have reviewed all other STPs to ensure that the valves are not operated at
power. BG&E is continuing to investigate the generic implications of this event, including why
the condition existed and was not discovered and corrected earlier, what opportunities existed for
the condition to be discovered and corrected, and if any other conditions or testing exist which
render multiple safety trains inoperable. The issue was promptly promulgated to operators and
supervisors and an Industry Operating Event notification was made. In addition, the Plant
General hianager directed that an independent investigation of the event be conducted.
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Conclusions
Notwithstanding the good work done by BG&E in identifying this issue as a result of the
thorough investigation by the MOV group into the 10 CFR 21 report and the questioning attitude
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exhibited by STP personnel, the NRC is concerned with the potential safety signihcance of the
activity and possible violation of regulatory requirements. In particular, questions remain
involving the earlier missed opportunities to identify and correct the condition, the notential of
operator oction to mitigate the consequences ofinadequate recirculation flow to the FCCS pumps
during a LOCA, and the thoroughness of BG&E corrective actions. As a result, the issue is an
apparent violation (eel 50-317 and 318/92 27-01) pending further review.
5.0
The inspectors tourod the onsite emergency respense facilities to verify that these facilities were
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in an adequate state of readiness for event response.
The inspectors discussed program
implementation with the applicable personnel. The resident inspectors had no noteworthy
findings in this area.
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6.0
SECURITY
During routine inspection tours, the inspectors observed implementation of portions of the
- security plan. Areas observed included access point search equipment operation, condition of
physical barriers, site access control, security force staffing, and response to system alarms and
degraded conditions. These areas of program implementation were determined to be adequate.
No unacceptable conditions were identified.
7.0
ENGINEERING AND TECilNICAL SUPPORT
7.1
Diesel Generator Loadingfalculations
in November of 1988, llG&E completed engineering calculation E-88-15 that calculates the
loading on the emergency diesel generators for various accident scenarios to ensure that the
generator loading is within design limits, in March of 1991, BG&E reviewed this calculation
as part or an internal audit, and questioned the adequacy of using brake horsepower for load
input data, rather than the more consnvative approach of using motor nameplate data. This led
BG&E to initiate a revision to the calculation in Decembe+ af 1991. The calculation revision
was to be performed by SE Technologies. In April of IW2, the NRC looked at_the original
calculation during an Electrical Distribution System Functional Inspection (EDSFI) and
questioned: 1) the me of a factor of 0.90 for small motor efficiency; 2) that the licensee did not
consider cable losses; and 3) that the calculation did not always bound the maximum load. These
issues were left as an Unresolved item (50-317/92-80-08 and 50 318/92-80-08). Finally, in May
1992, an audit finding by BG&E's Vendor Audits Unit questioned the use of the original
4
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manufacturer's curves for large loads (such as pumps and fans) as an input into the revision of
engineering calculation E-8815. The auditor questioned the use of the curves because the curves
were old (some dating back to early 1970), and not because of equipment changes that would
have invalidated the curves.
The inspectors reviewed some of BG&E's efforts to resolve the items listed above. BG&E has
committed to completely revising calculation E-88-15 by December 31, 1992, as stated in
BG&E's letter to the NRC dated July 8,1992. As part of this revision, BG&E has compared
pump in-service test (IST) baseline curves to the original manufacture's curves and found that,
in general, the manufacture's curves were conservative with respect to added load on the diesel
(i.e., the baseline curves show less How than the manufacturer's curves, so the latter curves
show more loading on the diesel). Additionally, BG&E was working on proving the adequacy
of the manufacture's curves by comparison to test data.
'
The inspectors assessed that BG&E was making progress in resolving the potential inaccuracies
in engineering calculation E-8815. The EDSFI Unresolved item,50-317 and 50-318/92 80-08,
remains open pending NRC review of the completed revision to engineering calculation E-88 15.
7.2
Westinghouse DS-206 Circuit Breakers
The inspectors reviewed BG&E's actions to address a Program Deficiency Report (number
92081) relating to deficiencies with Westinghouse type DS-206 circuit breakers. The deficiencies
,
were identified dt. ring a Quality Assurance surveillance on April 1,1992, conducted by BG&E's
Vendor Audits Unit, to authorize shipment of some DS-206 circuit breakers that were refurbished
by Westinghouse. A summary of the apparent de0ciencies from the surveillance is as follows:
,
1.
In 1984, Westinghouse performed an environmental qualification test " Test Report
EQ!P(84) 60," for BG&E on Westinghouse series DS-206 circuit breakers that did not
contain the same parts / components that were in the original circuit breakers supplied to
BG&E during plant construction. Furthermore, since 1984, Westinghouse has supplied
l
new and refurbished circuit breakers that have parts / components that do not conform to
the original circuit breakers (part numbers / form and 6t of some parts are not the same
as those on the original circuit breakers).
,
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2.
Westinghouse has made the changes to the circuit breakers described above without
l
obtaining approval from BG&E, contrary to the associated procurement specification.
BG&E's investigation of the above events concluded the following:
These same issues were previously addressed by Non-Conformance Reports in 1986
(numbers 3805 and 3808).
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Tim are two versions of the DS-206 circuit breaker: 1) a 600 A model that was sold
to 40&E duricg plant construction, which was discontinued in 1980; and 2) an 800 A
ir41 that replaced the 600 A model in 1980.
The envin cmental quali6 cation test performed in 1984 was used by BG&E, together with
the associated ecrti0 cates of conformance, to establish the Class 1E qualifications of both
the onyinal plant construction DS 206 600 A breakers and the upgraded DS-206 800 A
btrakers,
Westinghouse provided documentation to BG&E that certifies that the 600 A and the 800
e
A circuit breaker subassemblies are interchangeable; that is, moving the subassemblics
between the breakers will not affect the qualincation of the breakers. As documented in
" Renewal Parts Data llulletin 337090-lE," dated July 1981, Westinghouse does not
!
guarantee breaker qualification if parts are exchangal between subassemblics.
BU&E reviaed their procedures in late 1988 to state that parts may not be interchanged
between subassemblies on DS series circuit breakers. Prior to 1988, BG&E believes that
their Quality Assurance program requirements (that only parts exactly the same as the
original pads may be p aced in a safety related component without an engineering design
review) would have prevented an improper exchange of parts between the two types of
breakers. The Non Conformance Reports initiated in 1986 were evidence that their
synem worked (the reports were initiated because sc.ine replacement parts were not the
,
same as the original parts).
l
BG&B compared Westinghouse's !981 version of " Renewal Parts Data Bulletin 33790-
IE" to the 1990 version. They found three differences between part numbers that could
have indicated that changes were made to the breakers since 1981; however, BG&E has
verified, with Westinghouse, that there were no changes to these components. The part
i
numbers were changed to reflect changes in the me'. hod of procurement (e.g., some pads
l
can only be procured as part of a higher level assembly, vice individually).
l
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Westinghouse made all changes to the DS-206 series circuit breakers before the issuance
l
of BG&E procurement specincations that require written approval from the licensee prior
to making such changes.
The inspectors reviewed BG&E's documentation of the investigation that led to the conclusions
-
listed above. The inspectors assessed that BG&E's conclusions were well founded and adequate;
and their release of the breakers for shipment from Westinghouse to BG&E was appropriate.
Additionally, BG&E has changed their procurement speci6 cation to show the proper references
for part numbers to prevent confusion.
The inspectors noted that the baseline Class IE qualification data for the DS-206 circuit breakers
were scattered throu;;h various records, making it difficult to audit. BG&E stated that they plan
to draw together all of the breaker qualineation information in one reference document.
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7.3
Aoocndix R Fire Congms
On October 23,1992, BG&E completed a preliminary evaluation that found that a postulated fire
in the room containing the control room heating, ventilation and air conditioning (llVAC) units
could potentially prevent the safe shutdown of both units. These 11VAC units also serve the two
cable spreading rooms.
Specifically, the loss of the HVAC units would result in the loss of cooling supply to all Unit
I and Unit 2 vital bus inverters and distribution panels in the cable spreading rooms. BG&E's
evaluation found that the cable spreading rooms would overheat in approximately one hour. The
loss of the vital buses would prevent the safe shutdown of both units from both the control room
and the remote shutdown panels. Due to the possible safety significance of this concern, the
inspectors conducted an independent inspection to gain a detailed understanding of the issue and
'
to determine the adequacy of !!G&E's corrective actions.
BG&E discovered this concern during a ventilation systems design basis reconstitution effort
which was initiated in 1990. BG&E shifted the focus of this effort to Appendix R compliance
following the identification of a similar concern involving the emergency switch gear HVACs
in March 1992 during the NRC's Electrical Distribution Functional Safety inspection (see
Inspection Report 50-317 and 318/92 80).
10 CFR 50 Appendix R requires that redundant equipment trains necessary to achieve and
maintain hot shutdown conditions must meet one of the following methods of ensuring that one
redundant train remains free of fire damage. The trains must be separated by a fire barrier
having a three hour rating or by a fire barrier having a one hour rating provided the room is
equipped with both fire detectors and an automatic fire suppression system. - As an alternative,
the trains must be physically separated by more than 20 feet with no intervening combustibles
,
or fire hazards, provided the room has Dre detectors and an automatic fire suppression system.
There are two redundant control room HVAC units that supply cooling air to the control room
'
and to both cable spreading rooms. These HVAC units are h>cated in the same room. There
are no physical barriers or signi0 cant free space between the units. The room is equipped with
fire detectors; however, an automatic fire suppression system is not installed.
BG&E informed the inspectors that they had implemented several interim compensatory -
measures. This included an hourly firewatch patrol _in the HVAC room, verifying all the room
fire detectors were operable, res'ricting hot work, and limiting transient combustibles in_the;
room. The inspectors conducted a review of BG&E's firewatch patrol log and verified that the
,
room had been toured each hour. The inspectors conducted a'walkdown of the room and did not
'
identify any significant fire hazards. They concluded that BG&E's interim corrective measures
were adequate.
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The inspectors also reviewed BG&E's interactive Cable Analysis study to determine how BG&E
evaluated a postulated Gre in the control room HVAC room. The inspectors found that the
,
study, completed in 1982, concluded that there was no equipment in the room which when lost
,
could prevent the safe shutdown of the units. IlG&E informed the inspectors that at the time the
study was performed, the loss of HVAC units was generally not considered to adversely effect
equipment operability.
At the end of the period, BG&E was in the process of performing a detailed evaluation to more
accurately determine the adverse affects oflosing both trains of control room IIVAC following
a postulated fire, llG&E informed the inspectors that long term corrective actions would
subsequently be developed following the evaluation. This issue is unresolved pending the
6
completion of BG&E's detailed evaluation (URI 50-317 and 318/92-27 02).
7.4
Verification of BG&E's Action in Iksponse to Generic lxtter 88-17. "I oss of Decay
Heat Removal"
.
The purpose of this inspection was to review the status of the installation of instrumentation
committed by BG&E for Generic Letter (GL) 88-17.
The inspectors verified that these
'
instruments were installed in the Spring 1992 refueling outage on Unit 1. BG&E has scheduled
the installation of these instrumentation for Unit 2 during the Spring 1993 refueling outage.
The following packages were reviewed during this inspection:
(a)
Facility Change Request (FCR) 90-0074, "RCS hiid Loop Level and Temperature
hionitoring System" dated 8/30/91.
(b)
Facility Change Request (FCR) 90-0206, " Shutdown Cooling System hionitoring
Instrumentation" dated 9/5/91.
The inspectors reviewed the safety evaluations required by 10 CFR 50.59 for the above
modification packages and verified the technical adequacy as detailed below.
a.
RCS Water level Indication for hild Loop Operation
The inspectors verified that BG&E has procedures and administrative controls to provide at least
two independent, continuous RCS water level indications and audible alarms whenever the RCS
is in a reduced inventory and mid-loop condition. BG&E uses two RCS level transmitters (1 LE.
4139 and 1-LE-4138) to provide indication of RCS level in the control room. The wide range
level sensor monitors levels up to twenty feet above the bottom of the hot leg. This provides
one continuous wide range level indication during reduced inventory operation, overlapping the
_
existing reactor vessel level monitoring system (RVLhtS) level sensors. The narrow range level
monitor is an ultrasonic level monitoring system, with it's transducer attached to the bottom of
- hot leg No.12. The sensor monitors the entire hot leg flow area. The inspectors found that the-
above water level indication systems were installed consistent with GL 88-17 recommendations.
.
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16
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b.
Core Exit Thermocouple (CET) Temperature for Mid Loop Operation
I
The inspectors verified that for mid kiop operation, BG&E had taken adequate administrative and
j
procedural steps to provide at least two independent, continuous coolant temperature indications
that were representative of the core exit conditions (Operating Procedure (OP) 5, Appendix 5,
Step A). This procedure required that a high temperature indicator be operational with its
setpoint at about 20'F above CET temperature during normal shutdown condition. The system
'
provides an audible alarm in the control room. The inspectors found the temperature indication
system to be consistent with GL 88-17 and had no further questions concerning the core exit
temperature monitoring system,
c.
Shutdown Cooling System Monitoring During Mid loop Operation
Shutdown cooling pump suction pressure, discharge pressure, motor current, system now and
RCS level are monitored in this mode. These parameters are presently displayed in the control
room. The inspectors found the shutdown cooling system monitoring to be consistent with
G L 88-17.
8.0
SAFETY ASSESSMENT AND QUALITY VERIFICATION
,
8.1
Plant Operations and Safety Review Cotnmittec
The inspector attended several Plant Operations and Safety Review Committee (POSRC)
I
meetings. TS 6.5 requirements for required member attendance were verified. The meeting
'
agendas included procedural changes, proposed changes to the TS, Facility Change Requests, and
minutes from previous meetings. Items for which adequate review time was not available were
postponed to allow committee members time for further review and comment, Overall, the level -
'
of review and member participation was adequate in fulfilling the POSRC responsibilities. No
unacceptable conditions were identified.
,
8.2
SE Technologies Ouality Assurance Audit
1
The inspectors reviewed the results of a Quality Assurance (QA) audit of SE Technologies (QA
File QAG-SE92-Program-01) performed on April 7,1992, which was conducted by BG&E's
'
Vendor Audits Unit. The audit contained five Ondings. One finding related to use of the
original manufacture's curves for large loads (such as pumps and fans) as an input into a revision
of an emergency diesel generator loading calculation (E 88-15). This finding is discussed 'in
more detailin section 7. I of this report. The remaining findings related to apparent inadequacies
in QA procedures.
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17
The inspectors reviewed SE Technologics' responses to the audit findings (dated June 26,1992)
and reviewed the llG&E follow-up QA audit of SE Technologies on August 12 and 13,1992.
The inspectors agteed with the scope and detail involved in the responses and the follow-up
audit, and have assessed that the llG&E Vendor Audits Unit did a good job with resolution of
the audit findings.
8.3
lodine Removal Unit HEPA Filten
The inspectors reviewed BG&E's actions to address a Program Denciency Report (No. 92144)
relating to deficiencies with the containment iodine removal units. The deficiencies were
identified during a Quality Assurance (QA) surveillance on April 14, 1992, conducted by
_
llG&E's Vendor Audits Unit to authorize shipment of iodine removal unit ilEPA filters
manufactured by the American Air Filter (AAF) Company. A summary of the deficiencies
identified during the audit is as follows (note that the llechtet speciGcation mentioned below is
referenced by the BG&E procurement specification):
1.
The vendor did not have objective, auditable evidence to indicate that the filters met the
requirements of "Bechtel Specification Number 6750-M-200," Revision 3, Section 7.1.3,
dated October 13,1976, which requires that: " Components shall also be compatible for
operation in an environment of borated water spray (approximately 1720 ppm boron as
boric acid) containing smiium thiosulfate or sodium hydroxide and a maximum radiation
dose of 10" r occurring under a loss-of-coolant incident."
2.
The filters were fabricated with size .0015 inch aluminum separators, contrary to "Bechtel
Specification Number 675041-200," Revision 3, Section 7.1.3. dated October 13,1976,
which states that: " Aluminum materials shall not be acceptable."
3.
The vendor did not have objective, auditable evidence to indicate that the filters met the
_
requirements of "llechtel Specification Number 675041-200," Revision 3, Section 7.1.2,
dated October 13, 1976, which requires that: " Filter unit components shall be capable
of withstanding a radiation level of 100 mr/hr of principally gamma radiation with a 40
5
year cumulative dosage of 3.5 x 10 r under normal environmental conditions."
4.
"llechtel Specification Number 6750 41-200," Revision 3, Section 7.4.1, dated
October 13,1976, requires that: " Filter media shall be glass asbestos felt...." There was
no objective, auditable documentation to indicate that BG&E approved the present filter
media (astrocel-fiberglass).
Furthermore, there is a conflict between the BG&E
procurement specification and the Bechtel specification on this matter.
5.
The BG&E procurement specification requires that the vendor provide a certified
Production Test Report; however, the vendor maintained that the production test is the
same as the DOP test. Therefore, AAF cannot provide a separate Production Test
Report.
. . . . _
. . . . .
.
..
18
The above discrepancies were entered into the 13G&B issue report system on May 4,1992.
During the issue report screening process, BG&E appropriately questioned the operability of the
installed filters (and, consequently, the containment iodine removal units), which were also
manufactured by AAF, based on the possibility that they were manufactured using aluminum
separators and astrocel fiberglass filter media. Additionally, while addressing this operability
issue, the BG&E chemistry department recognized that part of the Bechtel environmental
specification for the containment iodine removal units was incorrect.
They thought the
specincation should have been 2300 ppm vice 172L ppm baron, and trisodium phosphate vice
sodium thiosulfate or sodium hydrotide. This brought into question another operability issue.
The inspectors determined that ilG&E performed a timely, technically sound -operability
evaluation on all three of the above issues, concluding that the iodine removal units were still
They also initiated more detailed technical evaluations to support their i_nitial
conclusions. BG&E did not, however, dwument the technical rationale behind their initial
At the time of the inspectors' review of the above issues, the Onal engineering evaluation of the
!
use of aluminum separators and astroccl-fiberglass filter media was complete. The evaluation
found that the materials had been previously evaluated as satisfactory for use in " Field Change
Request 841085" for the aluminum separators, and " Field Change Request 86-48" for the 61ter
media. Additionally, the " Updated Final Safety Analysis Heimrt" had already been revised to
reflect the use of these materials in the Elters. BG&E is updating their llEFA Glter procurement
specincation to allow the use of aluminum separators and astrocel Oberglass filter media.
9
Following questioning by the inspectors, BG&E documented their determination that the iodine
_
removal units remain operable in a chemical environment of 2300 ppm boron and trisodium
phosphate. BG&E intended to pursue, with AAF, the lack of documentation on the filter
environmental quali0 cations (as outlined in surveillance denciency number 1) after their detailed
-
engineering evaluation of the issue is complete. Additionally, they were verifying the adequacy
of the quali0 cation documentation provided by A AF during the initial procurement of the iodine
removal units.
l
BG&E initiated correspondence with AAF to resolve the audit discrepancy concerning the lack
'
of objective, auditable evidence to indicate that the filters shall be capable of withstanding a
radiation level of 100 mr/hr of principally gamma radiation with a 40 year cumulative dosage
of 3.5 x 10' r under normal environmental conditions. AAF responded by providing BG&E with
documentation of their exception to this requirement for the initial procurement of the iodine
removal units and the subsequent replacement Glter procurement request. AAF contends that the.
filter cells, by definition of function, are periodically replaced as they perform their function and
no reasonable interpretation could expect them to accept a 40 year cumulative radiation dose.
This response initiated another operability determination since the radiation quali6 cation of the
.
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,
,
19
installed Glters was in question. Again, the inspectors determined that BG&E made a timely,.
technically sound determination that the iodine removal units were still operable, but failed to
document their conclusion. BG&E completed a detailed engineering evaluation which supports
their initial operability determination.
While reviewing the filter radiation qualification issue, the inspectors noted a discrepancy
between the " Updated Final Safety Analysis Report" and the Bechtel specincation.
The
" Updated Final Safety Analysis Report" sates that the units shall be capable of withstanding a
'
radiation level of I r/hr vice the 100 mr/hr in the procurement specification. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
of this discovery, BG&E evaluated that the units were still operable despite the difference in
radiation Geld strength, and documented the evaluation. The inspectors assessed that the
operability determination was technically sound.
BG&E's detailed engineering evaluation
supported their initial operability determination, finding that the " Updated Final Safety Analysis
Report" specification of I r/hr is correct, and the units are qualified for this dose rate.
-
The surveillance deficiency concerning the vendor not providing a Production Test Report was
determined by the inspectors to be a matter of semantics. The inspectors reviewed the vendor's
procedures and found that the vendor was commited to performing the tests *: quired by the
" Updated Final Safety Analysis Report" and the BG&E procurement specification; however, the
,
vendor's terminology was slightly different than the procurement speci0 cation terminology.
The inspectors' assessed that BG&E's actions to address the issues resulting from the deficiencies
identiGed during the Vendor Audits Unit's QA surveillance at AAF were timely and adequate,
'!
and the operability determinations and the engineering evaluations appeared technically sound.
The inspectors noted that BG&B did not document the technical rationale behind their operability
,
determinations when a follow-up engineering evaluation was necessary to substantiate their earlier
conclusions; however, based on prior observations this appears to be an isolated occurrence.
8.4
Westinghouse Ouality Assurance Surveillance
i
The inspectors reviewed the results of a Quality Assurance (QA) surveillance, conducted by the
BG&E Vendor Audits Unit at the Westinghouse Electric Corporation, to approve the shipment
of a rewound component cooling pump motor.
The surveillance was performed on
May 13,1992. The Vendor Audits Unit had attempted to release the motor about two weeks
earlier, but a discrepancy between the BG&E procurement specification for the repair of a safety .
related electric motor, " Procurement Speci0 cation #5055," Revision 3, and the Westinghouse
QA procedures prevented the release.
The discrepancy -resulted from the wording"in
" Procurement Specification #5055," Revision 3,Section V, Step A.1, which stated that the
>
supplier-Quality Assurance Program shall be controlled by the supplier's " Quality Assurance
,
Manual," Revision 47, dated 9/4/90. The referenced document was not the actual document that
was in use at the time of the surveillance. Westinghouse was using a document titled "WCAP
9245," Revision 10, Interim Change C.
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investigation by the Vendor Audits Unit revealed that they had previously reviewed, and accepted
for use, "WCAP 9245," Revision 10 Interim Change C on October 2,1992, but had failed to-
update " Procurement Specification #5055 "
On April 30, 1992, Revision 4 to " Procurement Specification #5055" was issued, correctly
identifying the use of "WCAP 9245," Revision 10, Interim Change C, vice the supplier's
" Quality Assurance Manual," Revision 47, dated 9/4/90. This resolved the procurement
specification discrepancy, and allowed the Vendor Audits Unit to release the motor on May 13,
1992.
The inspectors assessed that the Quality Assurance surveillance and the subsequent release of the
rewound motor were conducted appropriately, in accordance with approved procedures, by the
!!G&E Vendor Audits Unit.
9.0
FOI.LOWUP OF PREVIOUS INSPECTION FINDINGS
Licensee actions taken in response to open items and findings from previous inspections were
reviewed. The inspectors determined if corrective actions were appropriate and thorough and
previous concerns were resolved, items were closed where the inspector determined that
corrective actions would prevent recurrence. Those items for which additional licensee action
was warranted remained open. The following items were reviewed.
9.1
Wglate) Unresolved Item 50-317 and 50 318/92-80-08
EDSFI Unresolved item 50-317 and 50-318/92-80-08, remains open pending NRC review of the
completed revision to engineering calculation E-8815. The inspectors assessed that ilG&E's
actions with respect to the unresolved item were aggressive.
10.0
MANAGEMENT MEETING
During this inspection, periodic meetings were held with station management to discuss
inspection observations and findings. At the close of the inspection period, an exit meeting was
held to summarire the conclusions of the inspection. No written material was given to the
licensee and no proprietary information related to this inspection was identified,
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4
10.1
PreliminaryJnspection Findings
l
One apparent violation was identified (EEI 50 317 and 318/92-27-01) concerning the safety
consequences and potential violation of regulatory requirements of isolating minimum
recirculation flow to all ECCS pumps during surveillance testing.
One unresolved item was identified (URI 50-317 and 318/92-27-02) pending completion of
BG&E's evaluation to determine the adverse affects ofloss of both trains of control room IIVAC
following a postulated fire.
10.2
Attendance at Management Meetings Conducted by Region Based Insocetors
'
Inspection
Reporting
Llalc
Subject
Ecoort No.
In3Defl0I
10/23/1992
Operator
50-317/92-24 (OL)
J. Prell
Requal Exam
50-318/92-24 (OL)
.
I1/6/1992
Erosion / Corrosion
50-317/92-28
R. McBrearty
,
& Chemistry
50-318/92-28
11. Kaplan
.
I1/20/1992
50-317/92-29
- L. Kay
50 318/92-29
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