ML20127K927

Insp Repts 50-338/85-12 & 50-339/85-12 on 850401-0505. Violation Noted:Failure to Properly Perform Surveillance of Battery Electrolyte Levels.Deviation Noted:Failure to Properly Set Turbine Load Limiter

ML20127K927
Person / Time
Site:	North Anna
Issue date:	05/22/1985
From:	Branch M, Elrod S, Luehman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127K910	List: IR 05000401/2005005 ML20127K908 ML20127K913 ML20127K927
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.1, TASK-2.E.4.1, TASK-2.F.2, TASK-2.K.3.05, TASK-TM 50-338-85-12, 50-339-85-12, IEIN-83-84, NUDOCS 8506270658
Download: ML20127K927 (10)

See also: IR 05000338/1985012

Text

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UNITED STATES

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1. troo NUCLEAR REGULATORY COMMISSION

y . 'og$ REGION ll

g j- 101 MARIETTA STREET,N.W.

• s ATLANTA, GEORGI A 30323

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Report Nos.: 50-338/85-12 and 50-339/85-12

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Licensee: Virginia Electric and Power Company

Richmond,.VA 23261

Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7-

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.? Facility Name: North Anna 1 and 2.

Inspection Conducted: April'1 - May 5, 1985

Inspectors:

M. W.

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,' Senior Resident Insp64 tor

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Da'te S'igned

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J. G. ,

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sident Inspector [/

An s/vI9s

Da'te Signed

Approved by: [ X4ou

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N4.4

S.~Elrof. Section Chief

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Dhte Signed

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Division of Reactor Projects

SUPEARY

Scope: This routine inspection by the resident inspectors involved 167

inspector-hours on site in the areas of licensee event reports, previously

identified items, engineered safety features (ESF) walkdown,1NI action plan

items, operational safety . verification, monthly maintenance and monthly

> surveillance.

Results: One -violation and one deviation were identified: Failure to properly

perform ' surveillance, paragraph 10, and failure to properly set the turbine load

limiter, paragraph 9, respectively.

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REPORT DETAILS

1. Licensee Employees Contacted

E. W. Harrell, Station Manager

G. E. Kane, Assistant Station Manager

M. L. Bowling, Assistant Station Manager

J. A. Stall, Superintendent, Technical Services

J. R. Harper, Superintendent, Maintenance

R. O. Enfinger, Superintendent, Operations

G. Paxton, Superintendent, Administrative Services

A. L. Hogg, Jr., Quality Control (QC) Manager

S. B. Eisenhart, Licensing Coordinator

J. R. Hayes, Operations Coordinator

J. P. Smith, Engineering Supervisor

R. C. Sturgill, Engineering Supervisor

D. E. Thomas, Mechanical Maintenance Supervisor

A. H. Stafford, Health Physics Supervisor

E. C. Tuttle, Electrical Supervisor

R. A. Bergquist, Instrument Supervisor

F. P. Miller, Quality Assurance (QA) Supervisor

F. T. Terminella, QA Supervisor

G. Flowers, Licensing Coordinator ,

J. Leberstein, Licensing Coordinator .

Other licensee employees contacted included technicians, operators,

mechanics, security force members and office personnel.

2. Exit Interview

The inspection scope and findings were summarized on May 7, 1985, with those

persons indicated in paragraph 1 above. The licensee acknowledged the

inspection findings. The licensee did not identify as proprietary any of

the materials provided to or reviewed by the inspector during this

inspection.

3. Licensee Action on Previous Inspection Findings

Not inspected.

4. Unresolved Items

An Unresolved Item is a matter about which more information is required to

determine whether it is acceptable or may involve a violation or deviation.

One unresolved item was identified during this inspection and is discussed

in paragraph 8.

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5. Plant Status

Unit 1 operated at or near 100% during the entire inspection period.

Unit 2 entered the inspection period operating at or near 100%. However, on

April 18, at 0608, the unit was taken off line due to high unidentified

reactor coolant system leakage. The leakage was detennined to be packing

leakage from Unit 2 valve 2-RC-6. Injection of Furmanite into the packing

area reduced leakage to an acceptable value and the unit was returned to

100% power at 1952 on April 21.

On April 26, at 0915, the unit automatically tripped from 100% power when

125 VAC vital bus 2-1 was inadvertently deenergized. The loss of vital bus

2-1 caused the reactor protection system to sense a tripping of reactor

coolant pump A breaker; thereby, tripping the plant in anticipation of a

low flow condition. The unit was returned to 100% power at 1130 on April 30

after several days of operation at reduced power due to secondary plant

chemistry holds.

6. Licensee Event Report (LER) Followup

The following LERs were reviewed and closed. The inspector verified that

reporting requirements had been met; causes had been identified; corrective

actions appeared appropriate; generic applicability had been considered; and

the LER forms were complete. Additionally, for those reports identified by

asterisk, a more detailed review was performed to verify that the licensee

had reviewed the event; corrective action had been taken; no unreviewed

safety questions were involved; and violations of regulations or Technical

Specification (TS) conditions had been identified.

• 338/80-70 Containment Air Particulate Monitor Inoperable.

• 339/80-92 Train B of the Safety Injection System Failed to

Reset Following a Functional Test.

• 339/84-11 Rev. 2 2H Emergency Diesel Generator (EDG) Trips.

• 339/85-04 Forced Shutdown Caused by Inoperable EDG

(emergency diesel generator)

*339/85-05 Rev. 0 & 1 Unit 2 Reactor Trip.

(CLOSED) LER 338/80-70 Containment Air Particulate Monitor Inoperable. A

design change to correct the described problem has been implemented by the

licensee. LERs dealing with the same subject were addressed in Inspection

l Reports 338,339/84-09.

(CLOSED) LER 339/80-92 Train B of the Safety Injection System Failed to

Reset Following a Functional Test. LER 339/82-14, which was closed in

Inspection Reports 338, 339/83-31, addressed the same relays discussed in

this LER.

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(CLOSED) LER 339/84-11 Rev 2, 2H Emergency Diesel Generator (EDG) Trips.

The inspectors have reviewed and closed the two previous submittals of this

report. This revision supplies some additional information on the actions

the licensee r'ans to take or is taking.

(CLOSED) LE' '/85-04 Forced Shutdown Caused by Inoperable EDG. As

discussed '  ; report, inoperable EDGs have been the subject of a number

of reports by tne licensee. The Office of Nuclear Reactor Regulation (NRR)

and NRC Region II are closely monitoring the licensee's implementation of

the program discussed in this report.

(CLOSED) LER 339/85-05 Revisions 0 and 1, Unit 2 Reactor Trip. The

inspectors have reviewed the licensee's actions, and they appeared to have

been proper. The fact that the tripping of a grid transformer caused the

loss of two Reserve Station Transformers (RSS) was discussed with NRR and

the licensee. NRR stated that the licensee's off-site electrical distri-

bution system is of acceptable design. As stated in the LER, the licensee

is reviewing the design, because, eventhough the present design is

acceptable, it may not be the optimum design with respect to continuity of

power.

(OPEN) LER 338, 339/85-03 Flooding Potential Not Previously Evaluated. The

licensee identified this deviation from a commitment, reported it, and has

taken temporary corrective actions. Long term corrective actions are still

being evaluated by the licensee and will be reviewed upon implementation.

7. Followup of Previously Identified Items

(CLOSED) Inspector Followup Item (IFI) 338, 339/84-27-04 Service Water Spray

Riser Degradation. The licensee has committed to replacing the present

spray arrays with ones made of stainless steel. They have also increased

routine surveillance of the arrays by the operators to identify spray risers

requiring repair. In response to Violation 339/84-04-01, the licensee

increased the frequency of spray array inservice inspections to conform with

the requirements of North Anna Unit 2 License Condition 2.c.(5) and Regu-

latory Guide 1.72.

(CLOSED) IFI 338/83-24-02 Log Entry to Meet Surveillance Requirement 4.4.1.3.2. This log entry needed a change to fully address the requirements

of the surveillance. The inspectors have reviewed both 1-LOG-4 and 2-LOG-4,

and both have been changed to more completely address the surveillance.

(CLOSED) IFI 338, 339/84-09-01 Failure of a Single Fire Damper Causing

the Loss of Both Trains of Safeguards Area Ventilation System (SAVS). The

inspectors and the licensee have reviewed this issue. The inspectors can

find no other ventilation systems in the plant where a similar situation

exists. The licensee recognizes the potential problem with the damper

location in the SAVS but feels that the eighteen month damper inspection

along with the monthly flow test ensure that any problems are quickly

identified.

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(CLOSED) IFI 338, 339/84-01-03 Brown Bovery Type SHK Circuit Breakers.

The breaker inspection recommended by IE Notice 83-84 was conducted on both

units during the 1984 refueling outages. The periodic followup inspection

of the breakers has been incorporated into electrical maintenance procedure

EMP-P-PH-01 " Electrical Checkout of 4160 Volt Air Circuit Breakers."

(2-20-85).

(OPEN) IFI 338, 339/84-04-04 Correction of Discrepancies Found in the

Auxiliary Feedwater System Walkdowns. With the exception of the update of

drawing 11715-FM-74A, the identified problems have been corrected.

(OPEN) IFI 338, 339/84-27-05 Correction of Problems in Offsite Review

Committee Procedures. This item is no longer an Unresolved Item. The

licensee has committed to revising the present offsite review Technical

Specification to more accurately reflect the present organization structure.

Additionally, the licensee committed to revising their offsite review

committee administrative procedures to incorporate quorum requirements for

the required monthly meeting. The implementation of these changes is an

Inspector Followup Item.

8. Hydrogen Recombiner

a. While reviewing the North Anna TS, the inspectors discovered surveil-

lance requirements that appear to conflict with the North Anna Safety

Evaluation Report (SER) for TMI action item II.E.4.1 (Dedicated Hydro-

gen Penetrations). Specifically, TS 4.6.4.2.a, which may be conducted

during power operations, requires a six month hydrogen recombiner

functional test involving aperation of the equipment and comunicating

containment atmosphere with the external recombiner. Meanwhile,

TS 3.6.1.1 for containment integrity while in modes 1, 2, 3, and 4,

requires valves not receiving an automatic closure signal be maintained

closed. Revision 3 of the licensee response to TMI item II.E.4.1 dated

May 31, 1982, described the recombiner system and proposed several

modifications to the originally-installed system which did not require

automatic closure of the containment icolation valves. NRR accepted

the licensee modification in a letter dated January 12,1984 and

specified the containment penetration valves should be opened only

under specific administrative control as specified in post-accident

procedures. Additionally, the hydrogen recombiner is designed and

tested to 10 psig while containment pressure for the first hour after

the design basis accident may increase to approximately 45 psig. The

recombiner should not be needed during the first hour of the accident

and is normally not needed until approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the

accident when containment pressure has been reduced below the 10 psig

design pressure. However, every six months during testing, there

exists an approximately four hour time period where the system could be

overpressurized if an accident occurred.

An additional concern is that the system as described in the licensee's

TMI response, Revision 3, dated May 31, 1982, is not like the

actually-installed system as described on system drawings 11715-FM-

106A-8, 11715-FM-92A-11 and 1K 50-FM-92A-10. Specifically, the inlet

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to the hydrogen recombiner does not tap off the containment vacuum pump

suction downstream of the Phase "A" isolation as stated, and under

accident conditions, it will not be necessary to open the vacuum pump

isolation valves to establish flow to the recombiner and/or hydrogen

analyzer as stated. Additionally, the drawing submitted in the

licensee NUREG 0737 response is outdated and not correct.

The licensee has been requested to provide to the inspectors, the

latest correspondence between themselves and NRR on item II.E.4.1.

This item will be considered unresolved pending outcome of the licensee

efforts. This item is identified as Unresolved Item 356,339/85-12-01.

b. The inspectors observed portions of the testing accomplished on one of

the post accident thermal hydrogen recombiners following replacement of

the motors on that unit. Subsequently, the inspectors reviewed the

following procedures:

1-0P-63.1 " Post Accident Thermal Hydrogen Recombiner" (4/18/85)

1-PT-68.1.1 " Containment Hydrogen Recombiner Functional Test -

1-HC-HC-1 (10-05-83)

1-PT-68.1.2 " Containment Hydrogen Recombiner Functional Test -

2-HC-HC-1(10-05-83)

1-PT-68.2.1 " Containment Hydrogen Recombiner System - Operability

Testof1-HC-HC-1(10-27-82)

1-PT-68.2.2 " Containment Hydrogen Recombiner System - Operability

Testof2-HC-HC-1(10-05-83)

The inspectors had the following comments on their observations and

reviews.

(1) The functional test procedures for recombiners 1-HC-HC-1 and

The procedure

2-HC-HC-1

for 1-HC-HC-1 are(1-PT-68.1.1

substantially )different

referencesin format.

1-0P-63.1 for the

performance of many of the action steps. Engineering Work Request

(EWR)83-335 recommended that " stand alone" functional test

procedures, rather than those that reference other procedures, be

implemented for the hydrogen recombiners. This has been done for

2-HC-HC-1(1-PT-68.1.2).

(2) 1-PT-68.1.1 does not contain all the Initial Conditions and

Precauticns of 1-PT-68.1.2 and step 4.6 of 1-PT-68.1.1 references

the wrong section of 1-0P-63.1.

(3) 1-PT-68.2.1 does not contain the formula for computation of

corrected purge blower flow (Q) provided by the vendor (EWR

83-335).

(4) The inspectors noted that the operator performing the testing on

the hydrogen recombiner became confused when calculating the

measured purge blower flow rate (Qo). This confusion was caused

by the fact that purge blower inlet pressure (PBo) which was read

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on PI-HC-205-1 read out in inches of Hg while the formula requires

the reading to be entered in psia. Either a conversion factor

needs to be provided or the formula needs to be changed to reflect

the units being read.

Followup of these comments is identified as IFI 338, 339/85-12-02.

9. Turbine Load Limiter

The inspectors conducted a review of recent operational transients in which

the main electric turbine generator, o

mately 940 megawatts electrical (MWE) perating

assumed at 100%

an additional loadwhen

40 MWE (i.e.,a approxi-

large electrical station was removed from the grid resulting in voltage

and/or frequency droop. To better explain the significant of the turbine

load increase, a brief description of the North Anna design follows:

Each North Anna unit utilizes a 1000 MWE turbine generator that is oversized

when compared to the licensed electrical output equivalent of 2775 megawatts

thermal reactor power, or 954 MWE. This difference in rating results in the

four turbine governor valves being at an average position of 80% open when

the reactor is at 100% power. The turbine control system utilizes a

governor valve position limiter; however, in the past, this limiter was set

at 100% and did not restrict turbine load increases above the electrical

load equivalent of 100% reactor power. Section 15.2.11 of the Updated Final

Safety Analysis Report (UFSAR) states " excessive loading by the operator or

by system demand would be limited by the turbine load limiter".

The inspectors reviewed the UFSAR, system drawings and technical manuals

but were unable to locate a turbine load limiter as described in Safety

Analysis 15.2.11 of the UFSAR. The licensee was requested to review their

design and provide their findings. As an interim measure, licensee manage-

ment provided instructions to the operating crews to set the turbine

governor valve position limiter to a value of 2% above the 100% reactor

power governor valve position, i .e. , approximately 82%. Subsequent

correspondence with the turbine vendor indicated that the governor valve

position limiter was the load limiter discussed in the UFSAR. As discussed

earlier, licensee procedures previously set the governor valve position

limiter at 100% - effectively rendering it inoperable as the load limiter

described in the UFSAR.

Even though the turbine load limiter has not been used as described,

excessive load increase accident protection is provided by overpower delta

T, overtemperature delta T and power range high neutron flux trips. The

licensee has committed to modifying operating procedures to set the governor

valve position limiter where it will perform the load limiter function.

The failure to properly use the governor valve limiter as the load limiter

described in the UFSAR is identified as Deviation 338,339/85-12-03.

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10. Station Batteries

During a routine plant inspection of the station battery rooms, numerous

cell electrolyte levels were above the maximum level mark for seven of the

eight batteries on both Units 1 and 2. TS require the battery cell

electrolyte level to be raaintained between the minimum and maximum level

indication marks.

The vendor, when contacted by the licensee, informed the licensee that even

though cell electrolyte levels being slightly high posed no immediate

operational problems, the levels should be reduced into the normal operating

range.

The licensee determined that approximately two weeks before the inspectors

identified this concern, the cell electrolyte levels had been adjusted to

the top of the operating band, and during subsequent charging, levels must

have slowly increased to above the indicated maximum.

The inspectors reviewed the latest completed 1-PT-85 and 2-PT-85, "D.C.

Distribution System", which were performed on April 30, 1985. These per-

formance tests are performed every seven days to meet the requirements of TS

surveillance 4.8.2.3.2 which, in part, requires the verification of proper

electrolyte level for the battery pilot cells. On May 1, 1985, the elec-

trolyte level of at least one pilot cell (Battery 2-II) was clearly above

the maximum level indication mark, and as mentioned earlier, numerous other

cells exhibited the same condition.

The failure to properly conduct the surveillance requirements of TS 4.8.2.3.2 is identified as Violation 339/85-12-04.

11. ESF System Walkdown

The following selected ESF systems were verified operable by performing a

walkdown of the accessible and essential portions of the systems on May 3,

1985:

Unit 1

1H Diesel Engine Cooling Water (1-0P-6.1A)

IJ Diesel Engine Cooling Water (1-0P-6.2A)

1H Diesel Engine Lube Oil System (1-0P-6.3A)

IJ Diesel En

Diesel Air (gine Lube Oil System (1-0P-6.4A)

1-0P-46.4A)

Unit 2

2H Diesel Engine Cooling Water (2-0P-6.1A)

2J Diesel Engine Cooling Water (2-0P-6.2A)

2H Diesel Engine Lube Oil System (2-0P-6.3A)

2J Diesel En

Diesel Air (gine Lube Oil System (2-0P-6.4A)

2-0P-46.4A)

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Upon the completion of the walkdowns, the inspectors had the following

comments.

a. Valves 2-EB-16,17, 62, and 63 are required to be locked open by

Attachment 2 of North Anna Power Station Administrative Procedure

ADM 19.29. These valves are in fact locked open; however, 2-0P-46.4A

requires them only to be open.

b. Small air leaks were noted on valves 1-EB-39 and 2-EB-83.

Correction of these discrepancies is identified as Inspector Followup Item

338,339/85-12-05.

12. TMI Action Plan Items

The inspectors reviewed the status of outstanding TMI Action Plan Items and

performed the action specified in the applicable IE Manual Chapter 2515

Temporary Instruction. The status of those items reviewed are as follows:

a. Closed: (Units 1 and 2) II.B.1.2 (Install Reactor Coolant Vents): As

stated in the March 4, 1985, VEPC0 response, serial number 85-091, to

Enforcement Action EA 84-57 described in inspection report 50-338,

339/84-06, the installation was completed by opening the manual

isolation valve.

b. Closed: (Units 1 and 2) II.F.2.3.B (Implement Reactor Vessel Level *

Instruments): As stated in a March 7,1984, letter to NRR, Serial

Number 047A, VEPC0 ensured the level instruments were operable after

the 1984 refueling outages,

c. Closed: (Units 1 and 2) II.K.3.5.B (Auto Trip of Reactor Coolant

Pumps): The licensee proposal to include manual tripping instructions

in their emergency procedures was verified complete.

13. Routine Inspection

By observations during the inspection period, the inspectors verified inat

the control room manning requirements were being met. In addition, the

inspectors observed shift turnover to verify that continuity of system

status was maintained. The inspectors periodically questioned shift

personnel relative to their awareness of plant conditions.

Through log review and plant tours, the inspector verified corr,eliance with

selected TS and Limiting Conditions for Operations.

During the course of the inspection, observations relative to Protected and

Vital Area security were made, including access controls, boundary

integrity, search, escort and badging.

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On a regular basis, radiation work procedures (RWP) were reviewed and the

specific work activity was monitored to assure the activities were being

conducted per the RWPs. Radiation protection instruments were verified

operable and calibration / check frequencies were reviewed for completeness.

The inspector kept informed, on a daily basis, of the overall status of both

units and of any significant safety matters related to plant operations.

Discussions were held with plant management and various members of the

operations staff on a regular basis. Selected portions of operating logs

and data sheets were reviewed daily.

The inspector conducted various plant tours and made frequent visits to the

Control Room. Observations included: witnessing work activities in

progress; verifying the status of operating and standby safety systems and

equipment; confirming valve positions, instrument and recording readings,

annunciator alarms, housekeeping and vital area controls.

No violations or deviations were identified in these areas.