IR 05000293/1985021

Insp Rept 50-293/85-21 on 850716-30.Violation Noted:Failure to Initiate Failure & Malfunction Repts on 850715 & 23, Resulting in Secondary Containment Integrity Not Being Maintained 850715-16

ML20134E656
Person / Time
Site:	Pilgrim
Issue date:	08/05/1985
From:	Mcbride M, Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20134E650	List: IR 05000293/1985021 ML20134E649
References
50-293-85-21, NUDOCS 8508200363
Download: ML20134E656 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-21 Docket N Category C Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility: Pilgrim Nuclear Power Station Dates: J ly 6 - 30, 1985 Inspector:

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h.M Mc l'fde, Resident Inspector Date 8$

Approved by: 8N t'. Trib$, Chief, Reactor Projects Section 3A 8[f/88

~ Da'te Inspection Summary: Inspection on July 16-30, 1985 (Report No. 50-293/85-21)

Areas Inspected: Special unannounced inspection of the licensee's response to a secondary containment damper surveillance test conducted on July 15, 1985 and to an emergency diesel generator fuel oil surveillance test conducted on July 23, 198 The inspection involved 24 inspector hours by one resident inspecto Results: Two examples of an apparent violation of a procedure for Failure and Malfunction Reports were noted (Failure to initiate Failure and Malfunction Reports on July 15 and 23, 1985, Detail 5). As a result of this apparent violation, secondary containment integrity was not maintained between July 15 and 16, 1985 (Detail 3) and surveillance testing required by the technical specifications was not conducted between July 23 and 26, 1985 (Detail 4). In addition, an overall concern was identified regarding the adequacy of secondary containment integrity considering the recent damper failures and decreasing ability to maintain vacuum (Detail 6).

8508200363 850813 PDR ADOCK 0D000293 G PDR

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TABLE OF CONTENTS Page 1. Persons Contacted .................................................... 1 2. Introduction ......................................................... 1 3. Sequence of Events for the Secondary Containment Damper Failure ...... 1 !

4. Sequence of Events for the Diesel Generator Fuel Oil Water Problem ... 2 5. Summary and Conclusions .............................................. 4 6. Secondary Containment Leakage Test ................................... 5 l 7. Management Meetings .................................................. 6 l

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l DETAILS 1. Persons Contacted Within this report period, interviews and discussions were conducted with members of the licensee staff and management to obtain information pertinent to the subjects being inspecte . Introduction On July 16, 1985 at 9:50 a.m. while the reactor was at 100% power, the in-spector discussed an ongoing inspection of automatic secondary containment isolation dampers with a licensee maintenance supervisor. The supervisor in-dicated that damper A0-N-90 had failed to meet inspection acceptance criteria and a maintenance request (MR) had been issued to repair it. The supervisor was not aware at that time of the implications of the failed damper and had not notified the Operations Department. Subsequently, the control room was informed of the damper problem and a redundant isolation damper was close On July 23, 1985, the Chief Chemical Engineer (CCE) was informed by a con-tractor laboratory that a fuel oil sample from the "A" emergency diesel gen-erator oil storage tank had an unacceptably high water content. The control room was not notified of the problem until July 26, 1985, three days late The "A" diesel generator was subsequently declared inoperable and appropriate surveillance tests were initiate . Sequence of Events for the Secondary Containment Damper Failure On July 15, 1985 at approximately 3:00 p.m., a contractor noted that the A0-N-90 damper would not fully close during an inspection of secondary contain-ment dampers, procedure no. 8.7.3.1. The inspection was conducted as part of an increased damper surveillance program initiated in response to damper failures earlier this yea The A0-N-90 damper is one of two secondary containment dampers mounted in series in the the refuel floor exhaust duc The other damper, A0-N-91, was verified to be operable during the inspection on July 15, 1985. Both dampers were opened (their normal position) shortly after the inspection of A0-N-90 and maintained open until the next mornin The contractor indicated that a small opening was detected between the sealing surfaces of four of twenty-four louvers in A0-N-90 while the damper was closed during the inspection. This opening was caused by slippage in damper drive gears. The opening extended over the total sealing surface of the four louvers and exceeded the acceptance criteria in procedure 8.7.3.1, i.e., a positive seal must exist over 90% of the damper edge seal when the dampers are close *

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The inspection was halted and an MR was issued to repair A0-N-90. The MR in-dicated that the maintenance problem was: " repair gears on A0-N-90 damper to meet 8.7.3.1". During the afternoon of July 15, the contractor submitted the maintenance request to the control room for approval. The MR (no. 85-21-122) was approved by supervisory personnel in the Maintenance and Operations Departments and given a "B" priorit This priority indicated that the main-tenance was not urgent and would not require interrupting lower priority work in progres A Failure and Malfunction Report (F&MR) describing the damper problem was not initiated on July 15. The maintenance supervisor in charge of the damper in-spection told the contractor that he (the supervisor) would write an F&MR if control room personnel asked for on No one in the control room subsequently asked about an F&MR when the contractor had the MR approve On July 16, 1985 at 9:50 a.m., the inspector discussed the damper inspection with the maintenance supervisor. During the discussion, the supervisor indi-cated that an MR had been issued for the repair of A0-N-90, but work had not started. The supervisor said that he did not know if A0-N-90 was operable.

The inspector suggested that the supervisor check with the control room to ensure that operations personnel understood the significance of the problem with A0-N-90.

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Ten minutes later, at 10:00 a.m. , the inspector entered the control room and i noted that both the A0-N-90 and A0-N-91 dampers were open. The maintenance supervisor was discussing the damper problem with the Watch Engineer at that time. Following this discussion, the Watch Engineer instructed the control

room supervisor to close both dampers, isolating the refueling exhaust ven-I tilation duct. The control switches for the dampers were tagged shut. The Watch Engineer also instructed the maintenance supervisor to submit an F&M At 10:35 a.m. , the licensee notified the NRC of the damper problem via the ENS telephone lin On July 19, 1985, the licensee determined that the opening between the four louvers in the A0-N-90 damper was large enough to make the damper inoperable.

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As a result, the licensee concluded that secondary containment integrity had

not been maintained between 3

00 p.m. on July 15 and 10:00 a.m. on July 16, l 1985.

I 4. Sequence of Events for the Olesel Generator Fuel Oil Water Problem On July 2, 1985, routine monthly composite samples were collected from the T-126A and T-126B emergency diesel generator fuel oil storage tanks, as re-quired by Technical Specification 4.9.A.1. Each tank has a 25,000 gallon capacity and supplias fuel oil to an 800 gallon diesel generator day tank via the diesel oil transfer system. The composite samples were formed by combin-ing grab samples from the top, middle, and bottom levels of the tanks. Quall-tative indicator tests were conducted on July 2 and did not detect water in either tank. The composite samples were subsequently sent to a contractor testing laboratory for analysi *

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On July 23, 1985, the CCE was notified by the contractor laboratory that the July 2 sample from the T-126A tank had a water and sediment content of 1.0%.

This exceeded the maximum level of water and sediment specified in Table 1 of ASTM 0975-77 for no. 2-D fuel oil, 0.05%. Technical Specification 4.9. requires that fuel oil quality meet the limits in Table 1 in the ASTM stan-dar No water was detected in the T126B tank sampl Confirmatory oil samples from both storage tanks were taken on July 23 and analyzed by the contractor laboratory the same day. The analysis detected 0.5% of water and sediment in the T-126A tank composite sample. The licen-see's qualitative test also indicated the presence of about a half inch of water in the bottom of the T-126A storage tank on July 23. No water was de-tected in the T-126B tank sampl The Nuclear Watch Engineer was notifled that there was water in the T-126A tank on July 23, but was apparently not told that the technical specification surveillance test limits had been exceeded. During the next two days, the Station Manager and the Chief Operating Engineer were also told that water had been found in the T-126A tank, but were not aware that the surveillance limit had been exceede About 60 gallons of water and all were subsequently pumped from the T-126A tank. However, water and sediment were still detected in a fuel oil sample collected on July 25 in excess of ASTM 0975-77 Ilmits after the pumping had been complete On July 26 at approximately 3:15 p.m. , the CCE notified the operations de-partment that the fuel oil in the T-126A tank did not meet the water and sediment requirements of the Technical Specification 4.9 A.1 (i.e., did not meet the Ilmit in Table 1 in ASTM D975-77). The "A" emergency diesel genera-tor was promptly declared inoperable and appropriate surveillance tests on the "B" diesel generator and core standby and containment cooling systems were initiated. The NRC was notified that the "A" diesel generator had been in-operable since July 23 via the ENS telephone lin An f&MR concerning the water in the fuel all was not initiated until July 2 The CCE later stated that he had not filled out an f&MR because he had boon involved with an evaluation of an unexpected hydrogen burn in the augmented offgas system on July 23. The offgas problem was resolved on July 23, 198 The licensee subsequently pumped out an additional 200 gallons of water and all from the bottom of the T-126A tank, following the pumping, a sampic an-alysis indicated that there was less than 0.015% water and sediment in the fuel oil. The "A" diesel generator was declared operable after the analysis on July 27, 198 On July 30, 1985 the inspector questioned the licensee about the quality of fuel oil in the "A" diesel generator day tank, T 124A. The licensee subsc-quently verified that no water was present in the day tank by visually in-specting an all sample from the bottom of the tank. Also, it was noted that the "A" diesel was successfully surveillance tested on July 29, 198 *

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At the end of the inspection period, the licensee had not identified the source of the water in the T-126A tank. At the exit meeting, the licensee stated that weekly samples would be collected and analyzed from the T-126A tank for the next several weeks. The analysis of these samples will be ex-pedite The licensee Indicated at the exit meeting that the "A" diesel generator was probably operable, despite the water in the bottom of the storage tank because the suction for the fuel oil transfer system was located several inches off the bottom of the tank. However, the licensee had not formally evaluated the condition at the end of the inspection. This evaluation, if performed, should determine what level of water is required to degrade diesel generator perfor-mance. The evaluation should also demonstrate that fuel oil additions to the tank would not cause sufficient turbulence in the tank to stir water off the tank bottom and into the suction for the oil transfer system, 5. Summary and Conclusions Two instances were identified during the inspection where the results of sur-veillance tests were not acted on in a timely manner. In both cases, failure and malfunction reports were not completed as soon as possible af ter abnormal conditions were identified during surveillance test Procedure no. 1.3.24 indicates that the purpose of the FAMRs is in part to ensure that an initial internal review and safety assessment is made of events of potential safety significance. The reports are turned in to the Nuclear

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Watch Engineer who reviews them to identify events that are related to tech-nical specification requirements and that may require NRC notification, i Procedure no. 1.3.24 states that FAMRs shall be initiated "whenever failures

or malfunctions are identified during survelliance testing ... of safety re-l lated ... structures or components that do or could prevent the systems from j fulfilling their individual functions in their intended manner". The proce-

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dure also states that "the individual responsibio for initiation of the report

{ shall be the person who first identifies an abnormality or a deviation from-i normal condition." failure to initiate f&MRs following the discovery of

! openings in the A0-N 90 damper on July 15 and af ter the discovery of water l In the T-126A storage tank on July 23 are examples of an apparent violation e

of Procedure no. 1.3.24. (85 21 01)

i Inchnical Specification 3.7.C requires, in part, that secondary containment

! Integrity be maintained while the reactor is at power or that procedures be

! Initiated to shut the reactor down. Secondary containment integrity is defined.

l In part, as having all automatic ventilation system isolation dampers operable

, or secured in the isolated position. Secondary containment Integrity was not i

maintained betwoon 3:00 p.m. on July 15, 198b and 10:00 a.m. on July 16, 1905 while the reactor was at power because A0 N 90 w.ts not operable and neither

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A0 N 90 nor A0 N 91 was secured in the Isolated position. As a result of the failure to complete an I&MR on July 15. Technical Specification 3.7.C was

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violated as a result of the above violation, i

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l Technical Specification 4.5.f requires that the remaining diesel generator i and all low pressure core and containment cooling systems be tested immedi- i ately and daily thereaf ter when one diesel generator is inoperable. Survell- i lance testing of the remaining diesel generator and the cooling systems were not conducted between July 23 and 26, 1985 while the "A" diesel generator was inoperable. As a result of the failure to complete an f&MR on July 23, 1985, ,

Technical Specification 4.5.F was violated. None of the low pressure core and l containment cooling systems on the remaining diesel generator were taken out '

of service between July 23 and 26, 198 ;

In response to the first incident, the licensee indicated that the supervisor  !

and all maintenance personnel had been instructed on the importance of -

promptly initiating f&MRs. In response to the second incident, the CCE and ,

the chemistry supervisors were also reminded of the requirement for f&MR sub-  ;

mittal. At the exit interview, the licensee stated that plans were being made  !

to instruct all station personnel on the f&MR syste [

6. Secondary containment leakage Test i l

During the inspection, the inspector discussed the significance of recent l secondary containment damper problems with the Itconsee. During the damper l Inspection on July 15 to 17, 1985, for example, two secondary containment  !

dampers (AP-N 90 and A0 N 83) did not fully close. The inspector questioned {

the reliability of current dampers and expresseJ concern about the operability of four secondary containment dampers that are not routinely inspected because '

they are inaccessibic while the plant is at powe (

Secondary containment Icakage has increased during the current operating cycle, f The reactor building vacuum ranged between 0.34 and 0.40 In. of water during j a leak rate test prior to startup on October 28, 1984. A subsequent leak rate ,

test on March 18, 1985 indicated a lower vacuum of 0.25 to 0.29 In. of wate !

fechnical Specification 4.7 C requires that a vacuum of 0.25 in, of water be [

demonstrated for secondary containment integrity. The licensee has no explana-  :

tion for the increased leakage, j in light of the damper failures this year and the marginal secondary contain- f mont leakago test results in March, 1985, the inspector asked the lleannco i to consider conducting another lenknye test to confirm the operability of the inaccessible dampers, j i

At the exit meeting on July 30, 1985, the licenseo stated than an evaluation i of secondary cnntainment integrity would be completed by August 2, 1985 and i includn the following items: j

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A review of the damper maintenance conducted in 1905 to determine which damper problems would have affected secondary containment Integrity, j

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An evaluation of the operability of the four inaccessible secondary con-tainment dampers i

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The results from a walkdown of secondary containment penetrations, and (

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An evaluation of the risks of conducting a secondary containment leakage test at power. The licensee is concerned that the main steam isolation i valves may isolate and scram the reactor during a leakaDe test, due to !

increasing main steam turbine tunnel temperatures during the tes l The secondary containment integrity evaluation will be reviewed during a future inspection of the licensed pro 0 ram. (85 21-02) f Management Meetinas '

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Preliminary findings were discussed with licensee management in exit meetings I on July 22 and 30,1985. No written material was provided to the Ilconsee ;

during this inspection. No proprietary information was identified as being included in this repor l t

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