ML20138C304

Insp Rept 50-416/86-04 on 860225-0317.Violations Noted: Failure to Properly Implement Surveillance Procedure & Perform Independent Verification & Failure to Promptly Correct Installation of Nonseismic Qualified Relay

ML20138C304
Person / Time
Site:	Grand Gulf
Issue date:	03/24/1986
From:	Butcher R, Caldwell J, Dance H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138C283	List: ML20138C279 ML20138C294 ML20138C304
References
50-416-86-04, 50-416-86-4, NUDOCS 8604020450
Download: ML20138C304 (9)

See also: IR 05000416/1986004

Text

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UNITED STATES

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NUCLIEAR REGULATORY COMMISSION

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Report No.: 50-416/86-04

Licensee: Mississippi Power And Light Company

Jackson, MS 39205

Docket No.: 50-416 License-No.: NPF-29

Facility Name: Grand Gulf Unit 1

Inspection Conduc ed : February 25 - March 17,1986

Inspectors: ( *

dent inspector

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R.'C.(Butcher Senior R

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ldwell Residerft Inspector

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Approved by: >-

H. C. Dance, Section Chief

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/Date/ Signed

Division of Reactor Proje:ts

SUMMARY

Scope: This routine inspection entailed 163 resident inspector-hours at the

site in the areas of Operational Safety Verification, Maintenance Observation,

Surveillance Observation, Reportable Occurrences, Operating Reactor Events,

Inspector Followup and Unresolved Items, and Design Changes and Modifications.

Results: Two violations - 1.) Failure to properly' implement a surveillance

procedure and ~ perform independent verification and 2.) failure to promptly

correct the installation of a non-seismic qualified relay.

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REPORT DETAILS 1

1. Licensee Employees Contacted

• J. E. Cross, Site Director

• C. R. Hutchinson, General Manager

• R. F.. Rogers, Technical Assistant

• J. D. Bailey, Compliance Coordinator

M. J. Wright, Manager, Plant Operations

• L. F. Daughtery, Compliance Superintendent

• D. G. Cupstid, Technical Support Superintendent

R. H. McAnuity, Electrical Superintendent

R. V. Moomaw, Manager, Plant Maintenance

W. P. Harris, Compliance Coordinator

J. L. Robertson, Operations Superintendent

L. G. Temple, I & C Superintendent

J. H. Mueller, Mechanical Superintendent

Other licensee employees contacted ircluded technicians, operators, security

force members, and office personnel.

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on March- 14, 1986 with

those persons indicated in paragraph 1 above. The licensee did not identify ,

as proprietary any of the materials provided to or reviewed by the

inspectors during this inspection. The licensee had no comment on the

following inspsction findings:

a. 416/86-04-01, Violation. Failure of electricians to properly

follow / implement a surveillance procedure, and failure to properly

perform independent verification. (Paragraph 6 and Paragraph 10)

b. 416/86-04-02, Inspector Followup Item. Potential 10 CFR 21 report

regarding B&B Promatech fire seals. (Paragraph 7)

c. 416/86-04-03, Violation. Failure to promptly correct the installation

of a non - seismic qualified relay. (Paragraph 8.a) ,

3. Licensee Action on Previous Enforcement Matters (92702)

a. (Closed) Violation 416/85-45-11, Failure to follow procedures when

performing diesel generator maintenance. The inspector reviewed

procedures 07-S-24-P75-E001AB-4, Rev. 2, Model EGB-35-C Woodward

Governor Drive Element Replacement; 07-S-24-P75-E001AB-5, Rev. 1,

Periodic 011 Change of the Standby Emer. Diesel Woodward Governor

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Model #EGB-35'C; 07-S-01-205, Rev. 2, Conduct of Maintenance

Activities; and 04-1-01-P75-1, Standby Diesel Generator System. The

procedures clarified the method to be used for Woodward Governor oil

replacement to prevent diesel engine overspeed. The diesel maintenance

personnel were given training on this incident. This item is closed.

b. (Closed) Violation 416/85-45-07,. Failure to adequately train personnel

performing activities affecting quality. The -licensee revised General

Maintenance Instruction 07-S-12-12, Calibration Checks of G.E. IAC Time

Overcurrent Relays, to add a caution note stating not to store the

relay paddle back in the relay case as a bus trip could result. Also,

electrical maintenance journeyman were instructed in the relationship

of protective relay circuits to other feeder breakers. This item is

closed.

c. (Closed) Violation 416/85-39-01, Failure to. follow administrative

procedures when making changes to technical section instructions.

Plant Administrative Procedure 01-S-06-12, GGNS Surveillance ~ Program,

paragraph 6.5.5, was revised to recognize the need to occasionally

deviate from the standard local leak rate test (LLRT) valve lineups.

The LLRT coordinator or responsible engineer may make pen and ink

changes on a copy of the appropriate valve lineup sheet and initial thu

' changes and sign and date the sheet. All changes are to be ' reviewed by

a qualified technical reviewer and the marked _ up sheets attached to the

LLRT data package. Technical Section Instruction 09-S-08-2 was also

revised as noted above. This item is closed.

d. (Closed) Violation 416/85-45-06, Failure to close LLRT valves by normal

means. The- licensee revised procedures 06-ME-1M61-V-001, Local Leak

Rate Test and 06-ME-1M10-0-0002, Containment Integrated Leak Rate Test

to add a- precaution on the closure of containment isolation valves by-

normal operation only. This item is closed.

4. Operational Safety Verification (71707)

The inspectors kept themselves informed on a daily basis of the overall

plant status and.any significant safety matters related to plant operations.

Daily discussions were held with plant management and various members of the

plant operating staff.

The inspectors made frequent visits to the control room such that it was

visited at least daily when an inspector was on site. Observations included

instrument readings, setpoints and recordings status of operating systems;

tags and clear ~ances on equipment controls and switches; annunciator alarms;

adherence to limiting conditions for operation; temporary alterations in

effect; daily journals and data sheet entries; control room manning; and '

access controls. This inspection activity included numerous informal

discussions with operators and their supervisors.

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~ Weekly, when onsite, a selected ESF system is confirmed operable. The

confirmation is made by verifying the following: accessible valve flow path

alignment, power supply breaker and fuse status, major component leakage,

lubrication, cooling and general condition, and instrumentation.

General plant tours were conducted on at least a biweekly basis. Portions

of the control building, turbine building, auxiliary building and outside

areas were visited. .0bservations included safety related tagout

verifications, shift turnover, sampling program, housekeeping and general

plant conditions, fire protection equipment- control of activities in

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progress, radiation protection controls, physical security, problem

identification systems, and containment isolation.

No violations or deviations were' identified.

5. Maintenance Observation (62703)

During the report period, the inspector -observed telected maintenance

activities: The observations included a review of the work doc' uments for

adequacy,. adherence to procedure, proper tagouts, adherence to technical

specifications, radiological controls, observation of all 'or. part of the

actual work and/or retesting in progress, speciited retest requirements, and

adherence to the appropriate quality controls.

No violations or deviations were identified.

6. Surveillance Testing Observation (61726)

The inspector observed the performance of selected surveillances. The

observation included a review of the procedure- for technical adequacy,

conformance to technical specifications, verification of test instrument

calibration, observation of all or part of the actual surveillances, removal

from~ service and return to service of the system or components affected, and

review of the data for acceptability based upon the acceptance criteria.

On February 20, 1986, with the plant operating at approximately 61% power,

Residual Heat Removal (RHR) system B was inadvertently initiated. At the

time of the event electrical technicians were performing Surveillance

Procedure (SP) 06-EL-1E12-M-0002, Containment Spray Time Delay Relay

Calibration and Functional Test. While performing step 5.4.5 of this SP the

technicians incorrectly connected a jumper, with a test switch, between

terminals T2 and M2 on the K98 relay instead of T1 and M as required by the

procedure. This jumper. was installed by one technician and independently

verified as installed properly by another technician. Because of this

incorrect jumper installation the B RHR system inadvertently initiated.when,

during the performance of step 5.4.6, the test switch was closed. The B RHR

system was subsequently secured and placed back in the standby LPCI mode.

Technical Specification 6.8.1 requires written procedures be established,

implemented and maintained covering surveillance and test activities of

safety related equipment. The failure of electrical technicians to properly

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follow / implement SP CS-EL-1E12-M-0002 resulting in the iniuation of

Emergency Core Cooling System (ECCS) RHR B will be identified as the first

example of Violation 416/86-04-01. See also paragraph 10.

7. Reportable Occurrences (90712 & 92700)

The below listed Event Reports were reviewed to determine if the information

provided met the NRC reporting requirements. The determination included

adequacy of event description and corrective action taken or planned,

existence of potential generic problems and the relative safety significance

of each event. Additional inplant reviews and discussions with plant

personnel as appropriate were conducted for the reports indicated by an

asterisk. The Event Reports were reviewed using the guidance of the general

policy and procedure for NRC enforcement actions.

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On February 21, 1986, the residents were notified of a potential 10 CFR 21 \

regarding B&B Promatech fire seals. B&B Promatech and Louisiana Power & ,

Light (LP&L)' conducted fire tests on two existing seal configurations and

both seals failed to perform properly causing the seal configuration to

become suspect. The licensee initia!.ed a Material Nonconformance Report

(MNCR) requiring furt:*r engineering evaluation to determine if Grand . Gulf

was affected. This wili ne an Inspector Followup Item (416/86-04-02).

By letter dated March 19, 1985, BBC Brown Boveri, Inc. notified the NRC of a

10 CFR 21 report regarding a potential deficiency with some of th.eir K line

circuit breakers. The condition reported was that the control wire

insulation on the eight pole K-1600 or K-2000 auxiliary switch may be cut by

the top edge of the dust shield when the circuit breaker is racked out to

the full disconnect position with the compartment door closed. This same

condition could occur on other size circuit breakers. The licensee

initiated Maintenance Work Order (MWO) E53414 to preform an inspection of

affected breaker auxiliary switch wiring and no discrepancies were found.

Also, MWO E53414 required that each control wire terminal be bent down to

ensure the wires were dressed as close as possible to the auxiliary switch.

This action completed the recommendations in the BBC Brown Boveri,.Inc.

report. This item (P2185-09) is closed.

The following License Event Reports (LERs) are closed.

LER No Event Date Event

• 82-072 September 24, 1982 ADS Valve Air Booster

Compressor Not Operating.83-115 August 3, 1983 Incorrect Voltage Applied To

Division 1 Control Circuits.83-123 September 6, 1983 Deficiency In Drywell Air

Cooler Condensate Monitoring

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(continued)

LER No Event Date Event

• 83-141 Saptember 19, 1983 Containment Spray Timer

Operation Less Conservative

than TS.83-171 October. 28, 1983 Diesel Generator 11 Fuel Oil

Leak.83-178 November 8, 1983 Diesel Generator 12 Air Start

Valve Failure.84-049 October 31, 1984 . Failure To Implement TS Fire

Protection Requirement.85-001 December 13, 1984 Identification Of An Unsealed

Penetration.85-029 July 24, 1985 Discovery Of' Unsealed Fire

Barriers.84-043 October 2,~1984 Inadvertent Suppression Pool

Makeup Actuation.83-182 November 29, 1983 Failure of HPCS Diesel

Generator To Start.

No violations or deviations were identified.

8. Operating Reactor Events (93702)

The inspectors reviewed activities associated with the below listed reactor

events. The review included determination of cause, safety significance,

performance of personnel and systems, and corrective action. The inspectors

examined instrument recordings, computer printouts, operations. journal

entries, scram reports and had discussions with operations, maintenance and

engineerin? support personnel as appropriate.

a. On March 3,1986, the licensee entered a shutdown Limiting Condition

for Operation (LCO) based on Technical Specification (TS) 3.0.3

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provisions .when it was found that the control room outside air intake

duct damper control system contained ~ relays that were not seismically

qualified. The Final Safety Analysis Report (FSAR), paragraph 9.4.1,

, states that the control room' fresh air inlet will isolate based on

signals from the following:

(1) High radiation in the outside air intake duct.

(2) Manual isolation.

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(3) High chlorine concentration in the outside air intake duct.

(4) Loss of coolant accident in either unit.

FSAR paragraph 9.4.1.1.1.d states that, except for noted exceptions,

the control room heating, ventilating, are air conditioning system is

designed to seismic Category I requirements. The licensee performed a

10 CFR 50.59 review and determined that the outside air intake duct

damper could be placed in the closed (isolated) position and the power

removed for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The outside air intake duct damper could

still be manually operated if required. The licensee then cancelled the

shutdown LCO. Seismic qualified relays were installed in the A train

of the'outside air intake duct damper controls on March 5, 1986, and on

the B train on March 7, 1986. A modification change notice MTCN

JS-1-588 was written on April 19, 1982, to replace the installed

non qualified relays with fully qualified relays (Agastat type ETR and

EGPD). The licensee received the low power license on June 16, 1982.

The licensee became aware on February 22, 1986 that the ETR and EGPD

relays were not installed and determined that the installed relays

(Agastat type 7014) had not been seismic qualified. 10 CFR 50,

Appendix B, Criterion XVI requires that measures be established to

assure that conditions adverse to quality are promptly identified and

corrected. The failure te promptly correct the installation of a

non qualified relay as identified on April 19, 1982 is a Violation

(416/86-04-03). Subsequently, the licensee conducted seismic testing

of one of the-Agastat 7014 relays. The one relay tested appears to

have passed the seismic test.

b. Scram No. 37

On January 22, 1986, the plant was operating at 60% thermal power when

at 7:42 a.m. the reactor scrammed as a result of a main generator load

reject signal. Earlier, alarms in the control room had actuated and

operators investigated and found that GGNS breakers 5240 and 5248

connecting the Franklin 500 kV transmission 1ine to the plant switch-

yard 500 kV buses were open. No automatic actuations of plant systems

occurred. Operators contacted the dispatcher and verified the

technical specification required offsite power sources were available.

The reactor scrammed shortly thereafter. It was determined that a

Franklin substation breaker 2420 had tripped earlier and had been

reclosed about one minute prior to the closing of GGNS breaker 5248.

However, breaker 2420 tripped again before plant breaker 5248 was

completely reclosed. After breaker 5248 was closed, breaker 5520

automatically reclosed. The north part of the electrical power grid,

including GGNS, was out of phase with the south part of the grid due to

separation distance. Although the grid was connected through other 500

kV lines, these lines were very long and due to power being transferred

from the north to the south part of the grid, it was calculated to have

been about 30 degrees phase differential with the northern grid

leading. The GGNS generator responded in an oscillating manner which

actuated the load reject relay. The load relay then initiated a main

turbine control valve fast closure which produced a reactor scram. The

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turbine and generator tripped on reverse power. The operators

recovered the plant to stable conditions without the use of emergency

core cooling ' systems. Tne load reject relay is set to actuate at a

load drop of at least 35 percent provided the load drop rate is greater

than 10 percent per second and the residual load is less than or equal

to 70 percent. When the Franklin substation ' breaker tripped and

reclosed, causing the phase differential, generator megawatts (MW)

. spiked from 750 MW to 1250 MW in less than 100 milliseconds and fell to-

250 MW over the next 300 milliseconds, which is much greater than the

load reject relay trip point. The relay actuates to vent Electro-

hydraulic Control (EHC) pressure which causes a fast closure of the j

turbine control valves. The licensee is reviewing the circumstances of  ;

this event to determine if an acceptable design alternative exist to

prevent this condition in the future. LER 86-003 reported this event

and will be tracked for any supplemental actions.

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9. Inspector Followup And Unresolved Items. (92701)

a. (Closed) Inspector Followup Item 416/83-10-06. The FSAR P&ID does not

address the' required-po:ition for valve E22F001. This item is closed.

b. (Closed) Inspector Followup Item 416/83-14-02. There is no regulatory

requirement fo* every motor operated valve to have local position

indication and the licensee does not use the local indicators on all

valves. This item is closed.

c. (Closed) Inspc: tor Followup Item 416/83-30-02. The inspector verified

that breaker 72-11C18 in the HPCS local panel was reidentified. This '

item is closed.

d. (C1'osed) Unresolved Item 416/85-45-01, Significance of plugging of ESF

room coolers. The licensee performed an evaluation to determine the

maximum temperatures in the Division 1 switchgear rooms with the room

coolers impaired as described' in MNCR 765-85. Since the temperature

would be less than 140 F, the safety related equipment would have been

able to perform its safety function. This item is closed.

, e. (Closed) Inspector Followup Item 416/85-46-03. The licensee issued a

Technical Specification Position Statement referencing IN 85-94 stating

that if the minimum flow valve on any ECCS will not perform its

intended function then the associated ECCS function is inoperable.

This item is closed.

10. Design Changes and Modifications (37700)

Design Change Package (DCP) 82/5020, Standby Service Water (SSW) Loop B

System' Modifications, was reviewed to determine if the design change was

controlled by established procedures and if it had been reviewed and

approved in accordance with technical specification and established QA/QC

controls. During the review the inspector determined that this DCP was

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implemented in the plant by eight Maintenance Work Orders (MWO). The review

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of MWO F56470, Electrical Support for SSW B Motor Replacement, revealed a

problem with a Troubleshooting Log Sheet which documented the lifting and

relanding of eight electrical leads. The documentation for the relanding of'

the eight leads was completed in the verified block but the restored block,

which must be signed prior to the verified block, was left blank for all

eight leads. The licensee was notified of this discrepancy and has verified

that the leads had been relanded properly.

Technical Specification 6.8.1 requires written procedures be established,

- implemented and maintained covering recommended procedures in Appendix A of

a Regulatory Guide 1.33, Revision 2, February 1978 for performing

maintenance activities. Administrative Procedure 01-S-07-1, Control of Work

on Plant Equipment and Facilities, requires that all changes related to

troubleshooting will be documented on a Troubleshooting Log Sheet ensuring

that the changes are restored and verified using independent verification

requirements prior to the MWO being released for retest. The failure of the

licensee to properly document the restoration of lifted leads will be

identified as the second example of Violation (416/86-04-01). See also

paragraph 6.

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