ML20150D504

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Insp Rept 50-424/88-09 on 880130-0226.Violations Noted.Major Areas Inspected:Plant Operations,Radiological Controls, Maint,Surveillance,Fire Protection,Security & Quality Programs & Administrative Controls Affecting Quality
ML20150D504
Person / Time
Site: Vogtle Southern Nuclear icon.png
Issue date: 03/16/1988
From: Burger C, Rogge J, Sinkule M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20150D487 List:
References
50-424-88-09, 50-424-88-9, NUDOCS 8803240309
Download: ML20150D504 (16)


See also: IR 05000424/1988009

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-'* u UNITED STATES 1

[pn aro ,D" o NUCLEAR REGULATORY COMMISSION l

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101 MARIETTA STREET,N.W.

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Report No.: 50-424/88-09

Licensee: Georgia Power Company

P.O. Box 4545

Atlanta, GA 30302

Docket No.: 50-424 License No.: NPF-68

Facility Name: Vogtle 1

Inspection Conducted: January 30 - February 26, .1988

Inspectors: 9 I

JP F. Roggy,' Senior R4Cdent Inspector

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Date Signed

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C V.' Bu geF,"8e Vent Inspector

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"/Date Srigned

Approved By: u 4 O

M.'W. Sinkule, Section Chief '

(fate St'gned

Division of Reactor Projects

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SUMMARY

Scope: This routine, unannounced inspection entailed resident inspection in

the following areas: plant operations, radiological controls, maintenance,

surveillance, fire protection, security, and quality programs and administra-

tive controls affecting quality.

Results: Two violations were identified in the areas of surveillance and

quality programs (Failure to establish.an adequate surveillance procedure for

the hydrogen monitors and failure to submit a LER for missed surveillances).  :

6803240309

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ADOCK 05000424

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DETAILS

1. Persons Contacted

Licensee Employees

  • G. Bockhold, Jr., General Manager Nuclear Operations
  • T. V. Greene, Plant Support Manager
  • R. M. Bellamy, Plant Manager

E. M. Dannemiller, Technical Assistant to General Manager

C. C. Echert, Manager Chemistry and Health Physics

  • J. E. Swartzwelder, Nuclear Safety & Compliance Manager
  • W. F. Kitchens, Manager Operations

R. E. Lide, Engineering Support Supervisor

H. Varnadoe, Plant Engineering Supervisor

  • R. E. Spinnatu, ISEG Supervisor

C. W. Hayes, Vogtle Quality Assurance Manager

  • G. R. Frederick, Quality Assurance Site Manager - Operations

W. E. Mundy, Quality Assurance Audit Supervisor

M. A. Griffis, Maintenance Superintendent

R. M. Odom, Plant Engineering Supervisor

S. F. Goff, Regulatory Specialist

A. L. Mosbaugh, Assistant Plant Support Manager

H. M. Handfinger, Assistant Plant Support Manager

F. R. Timmons, Nuclear Security Manager

  • K. Pointer, Senior Plant Engineer

Other licensee emp'ayees contacted included craftsmen, technicians,

supervision, engineers, operations, maintenance, chemistry, inspectors,

and office personnel.

  • Attended Exit Interview

2. Exit Interviews - (30703)

The inspection scope and findings were summarized on February 26, 1988,

with those persons indicated in paragraph 1 above. The inspector

described the areas inspected and discussed in detail the inspection

results. The licensee did not identify as proprietary any of the

materials provided to or reviewed by the inspector during this inspection.

Region based NRC exit interviews were attended during the inspection

period by a resident inspector. This inspection closed two Unresolved

Items, two Part 21 Reports, and five Licensee Event Reports. The items

identified during this inspection are-

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Violation 50-424/88-09-01 "Failure To Establish An Adequate Procedure j

For The Performance Of TS 4.3.3.6." - Paragraph 4.b.(1)(c). l

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Violation 50-424/88-09-02 "Failure To Report A Condition Prohibited

By Technical Specification Per 10 CFR 50.73(a)(2(1)." - Paragraph 5.

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The licensee informed the inspector at the exit, that Violation 50-424/

88-09-02 would be denied on the basis of an interpretation by an ex-NRC

employee who had worked on standard TS. The inspector noted to the

licensee that ex-NRC employees were not authorized to make interpretation

for the Commission.

3. Operational Safety Verification - (71707)(93702)

The plant began this inspection period in Hot Shutdown (Mode 4). On

January 29, during the performance of a surveillance test, both residual

heat removal crossover valve motors operators (1-HV8716 A & B) failed

while attempting to open them. On February 1, during testing to determine

the cause of failure, the licensee identified that valve pressure locking

had resulted during the heatup of the unit from Cold Shutdown (Mode 5).

The Unit returned to Mode 5 on February 2, to inspect the valve internals

and modify the valve discs to eliminate the effect. On February 6, the ,

unit obtained Mode 4. On February 7, Hot Standoy (Mode 3) was entered and l

on February 9, Startup (Mode 2) was entered with subsequent entry into

Power Operation (Mode 1) on February 10. Full power (100%) was achieved

on February 12. On February 15, the reactor tripped from 100% power when

the main generator field was shorted during vibration testing. Mode 2 was

entered and Mode 1 achieved on February 16. Mode 1 operation at 100% was

achieved on February 18.

On February 5, the unit experienced an ESF actuation of Feedwater Isola- l

tion when the No. 1 Steam Generator Level exceeded the Hi-Hi Setpoint. '

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a. Control Room Activities  !

Control Room tours and observations were performed to verify that

facility operations were being safely conducted within regulatory

requirements. These inspections consisted of one or more of the

following attributes as appropriate at the time of the inspection. i

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Proper Control Room staffing

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Control Room access and operator behavior  ;

Adherence to approved procedures for activities in progress

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Adherence to Technical Specification (TS) Limiting Conditions

for Operations (LCO)

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Observance of instruments and recorder traces of safety related

and important to safety systems for abnormalities

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Review of annunciators alarmed and action in progress to correct

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Control Board walkdowns

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Safety parameter display and the plant safety monitoring system

operability status

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Discussions and interviews with the On-Shift Operations

Supervisor, Shift Supervisor, Reactor Operators, and the Shift

Technical Advisor to determine the plant status, plans and to

assess operator knowledge

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- Review of the operator logs, unit log and shift turnover sheets

No violations or deviations were identified.

b. Facility Activities

Facility tours and observations were perforned to assess the effec-

tiveness of the administrative controls (stablished by direct

ob3ervation of plant activities, interviews and discussions with

licensee personnel, independent verification of safety systems status

and LCOs, licensee meetings and facility records. During these

inspections the following objectives are achieved:

(1) Safety System Status (71710) - Confirmation of system oper-

ability was obtained by verification that flowpath valve

alignment, control and power supply alignments, component

conditions, and support systems for the accessible portions of

the ESF trains were proper, The inaccessible portions are

confirmed as availability permits. Additional indepth inspec-

tion of the diesel generator system was performed to review the

system lineup procedure with the plant drawings and as-built

configurations, compare valve remote and local indications,

walkdowns were expanded to include hangers and supports, and

electrical equipment interiors. The inspector verified that the

lineup was in accordance with license requirements for system

operability.

(2) Plant Housekeeping Conditions -

Storage of material and

components and cleanliness conditions of various areas through-

out the facility were observed to determine whether safety

and/or fire hazards existed.

On February 23, 1988, the licensee conducted an extensive plant

cleanup effort. Teams were established to go through all plant

areas and actually cleanup.

(3) Fire Protection - Fire protection activities, staffing and

equipment were observed to verify that fire brigade staffing was

appropriate and that fire alarms, extinguishing equipment,

actuating controls, fire fighting equipment, emergency equip-

ment, and fire barriers were operable.

(4) Radiation Protection (71709) - Radiation protection activities,

staffing and equipment were observed to verify proper program

implementation. The inspection included review of the plant

program effectiveness. Radiation work permits and personnel

compliance were reviewed during the daily plant tours. Radia-

tion Control Areas (RCAs) were observed to verify proper

identification and implementation.

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(5) Security (71881) - Security controls were observed to verify

that security barriers were intact, guard forces were on

duty, and access to the Protected Area (PA) was controlled in

accordance with the facility security plan. Personnel within

the PA were observed to verify proper display of badges and that

personnel requiring escort were properly escorted. Personnel

within vital areas were observed to ensure proper authorization

for the area. Equipment operability of_ proper compensatory

activities were verified on a periodic basis.

(6) Surveillance (61726)(61700) - Surveillance tests were observed

to verify that approved procedures were being. used; qualified

personnel were conducting the tests; tests were adequate to

verify equipment operability; calibrated equipment was utilized;

and TS requirements were followed. The inspectors observed

portions of the following surveillances and reviewed completed

data against acceptance criteria:

Surv. No. Title

14600-1 & SSPS Slave Relay K733 Test - l

14601-1 RWST Low Level  !

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14000 Operations Shift and Daily j

Surveillance Logs

14225 Operations Weekly Surveillance

Logs

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(7) Maintenance Activities (62703) -

The inspector observed

3 maintenance activities to verify that correct equipment

clearances were in effect; work requests and fire prevention

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work permits, as required, were issued and being followed;

quality control personnel were available for inspection

activities as required; retesting and return _of systems to

service was prompt and correct; TS requirements were being

followed. Maintenance backlog was reviewed. Maintenance was

observed and work packages were reviewed for the following

maintenance activities: j

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MWO No. Work Description i

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18800941 Repositioned limit switch and valve arm on

1 HV 15199 (Bypass Feed Isolation Valve, ' l

Loop 4). l

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18800241 Investigate and repair excessive hydrogen l

usage from main generator.  !

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18800769 Main turbine bearing vibration and main

generator vibration readings taken. ' Balance

piLgs installed.

18800567 Performed,M0 VATS testing on valve 1 HV87168.

18800526 Performed M0 VATS testing on valve 1 HV8716A..

18800527 . Performed MOVATS testing on valve 1 HV8716B.

18800528 Performed MOVATS testing on valve.1 HV8716A.

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18800529 All wiring to valve 1 HV87168 checked in

accordance with procedure 26836-C.

18800583 Removed disc from valve stem and sent to

have hole drilled in upstream side of

1 HV3716A.

18800584 Removed disc from valve stem and sent to

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18800609 Hole drilled in upstream side of valve discs )

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from valves 1 HV8716A and 1 HV8716B. 1

18800670 Replaced the duplex' fuel filter assembly and j

fuel filter for diesel generator B. 1

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18708679 Diesel generator lube oil keep warm pump

relief valve removed and sent to shop for

testing and repair.

No violations or deviations were identified.

4. Review of Licensee Reports (90712)(90713)(92700)

a. In-Office Review of Periodic and Special Reports

This inspection consists of' reviewing the below listed report to

determine whether the information reported by the licensee is

technically adequate and consistent with the inspector knowledge of-

the material contained within the report. Selected material within a

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the report is questioned randomly to verify accuracy to provide a

reasonable assurance that other NRC personnel have an appropriate-

document for their activities.

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Monthly Operating Reports - The report dated February 12, 1988, was

reviewed. The inspector had no significant comments reqarding these

reports.

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b. Licensee Event Reports and Deficiency Cards

Licensee Event Reports (LER) and Deficiency Cards (DC) were reviewed

for potential generic impact, to detect trends, and to determine

whether corrective actions appeared appropriate. Events which.were

reported pursuant to 10 CFR 50.72, were reviewed as they occurred '

to determine if the technical specifications and other regulatory

requirements were satisfied. In-office review of LERs may result in

further followup to verify that the stated corrective actions have

been completed, or to identify violations in addition to those

described in the LER. Each LER is reviewed for enforcement action

in accordance with 10 CFR Part 2, Appendix C. Review of DCs was

performed to maintain a realtime status of deficiencies, determine

regulatory compliance, follow the licensee corrective actions, and

assist as a basis for closure of the LER when reviewed. Due to the

numerous DCs processed only those OCs which result in enforcement

action or further inspector followup with the licensee at the end of

the inspection are discussed as listed below. The LERs denoted with

an asterisk indicates that reactive inspection occurred at the time

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of the event prior to receipt of the written report.

(1) Deficiency Card reviews:

(a) DC 1-88-0316 "Main Feedwater Isolation On Hi Hi #1 Steam

Generator Water Level". On February 1, 1988, at 8:29 a.m., -

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the Balance of Plant Operator stroked the main feedwater I

isolation valve without realizing that the feedwater system l

was in long cycle recirculation. Upon opening the valve, l

the condensate pumps raised level until terminated by the

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isolation signal. This item will receive further followup

when submitted as an LER pursuant to 50.73 (a)(2)(iv).

(b) DC 1-88-0483 "Reactor Trip On Turbine Trip When Vibration i

Reading Instrument Shorted The Main Exciter Field". On

February 15, 1988, at 5:55 p.m., the unit tripped from 100% j

power. The inspector reviewed the post trip review report  !

regarding the trip. The licensee was able to demonstrate

that this was the actual cause of the event. All systems

functioned as designed during the transient. This item

will receive further followup when submitted as an LER

pursuant to 50.73 (a)(2)(iv).

(c) DC 1-88-322 "Containment Hydrogen Level Indication

Inoperable Due To Personnel Error." On February 1,1988,

personnel discovered that field leads had been reversed

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which resulted in monitor inoperability. The inspector

reviewed the details of this event with the I&C Supervisor

because it appeared to be a repetitive of the event

described in LER 87-54. In LER 87-54, the A train hydrogen

monitor had been rendered inoperable by field leads that

had been reversed, while in this event the B train was

inoperable. Corrective action for LER 87-54 included

counseling of the technicians involved and overall training

of the'I&C Department on the incident and reemphasizing the

importance of procedural compliance. The I&C Supervisor's

review of the latest event determined that the step which .

requires removal of the leads was not clear, the leads were

not permanently labeled and whoever had rolled the leads

must have bypassed the Wire at d Jumper Control System. To

positively ensure that the monitor is in an operable state

following surveillance, hydrogen gas will be utilized to

verify that the channel response is proper.

Since this violation is a recurrence of a previous

violation (LIV 50-424/88-02-02), where the corrective

action should have prevented this violation, this item does

not meet the criteria for non citation. As a result of the

licensee's additional review, the inspector has determined

that a failure to establish an adequate procedure for the

performance of a surveillance per TS 6.7.1 existed.

Maintenance Procedure 24551-1, Rev. 7 dated May 13, 1987,

"Containment Hydrogen Monitor Train A Analog Channel

Operational Test and Channel Calibration" and Maintenance

Procedure 24552-1, Rev. 7 dated May 13, 1987 "Containment

Hydrogen Monitor Train B Analog Channel Operational Test

and Channel Calibration" were established to perform the

surveillance testing required by TS 4.3.3.6 ard 4.6.4.1.

This item is identified as:

Violation 50-424/88-09-01 "Failure To Establish An Adequate

Procedure For The Performance Of TS 4.3.3.6."

(2) The following LERs were reviewed and are ready for closure

pending verification that the licensee's stated corrective

actions have been completed.

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(a) 50-424/87-52, Rev. O "Inadvertent Containment Ventilation l

Isolation During Source Check Of Radiation Monitor." l

Previous inspection was performed regarding this LER in NRC

Rpt. 50-424/88-02. 50-424/87-60, Rev. 0 "Control Room

Isolation Actuation Due To An Inadequate Procedure."

Chemi stry and Health Physics Procedures were reviewed _ to

verify that the corrective actions had been incorporated.

Training lesson plan number CH-LP-41001-03-C, dated

November 11, 1987, was reviewed and future training will be

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conducted on this LER and how to prevent recurrence. The

inspector learned that additional training is necessary to

complete the corrective action. This LER will remain open

pending completion of the training.

(b) *50-424/87-69, Rev. 0 "Operating Above The Maximum Power

Level Specified In Operating License". This item was  ;

inspected in NRC Rpt. 50-424/87-63 and 50-424/88-06. '

Pending review of the supplemented LER, this item will

remain open.

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(c) 50-424/87-71, Rev. 1 "Mi> communication Causes Inadequate

Analysis of Unit 1 Diesel Fuel 011". On December 4, 1987, ,

while reviewing fuel oil documentation, the reviewer noted )

that fuel oil designated for Unit 2 had been added to

the Unit 1 storage tanks. The required Unit 1 sampling

requirements had not been performed. Corrective action

consisted of revising Unit 2 sampling, review analysis of

the fuel was performed on a sample of the added fuel and

found to be within TS 4.8.1.1.2f. acceptance requirements.

While the LER discusses the reason for the surveillance it

was not clear in stating that the only portion of the

surveillance violated was not having the analysis results

prior to addition. Since the actual acceptance criteria

was verified there was no effect on plant safety. This

item represents a violation of NRC requirements which meets 1

the criteria for nan citation. In order to track this i

item, the following is identified.

LIV 50-424/88-09-01 "Failure To Complete TS Surveillance

4.8.1.1.2f Prior To Fuel Addition To The Storage Tanks - l

LER 87-71."

(d) 50-424/87-72, Rev. 0 "Inadequate Training Causes A I

Surveillance To Be Improperly Performed " On December 9,

1987, the licensee identified that on November 21, 1987, an

Auxiliary Plant Operator (AP0) improperly performed a l

surveillance on the Reactor Vessel Level Indication System j

(RVLIS). The cause was attributed to the fact that the

APO was not familiar with the console computer display.

Surveillance performed prior to and following the events i

were performed satisfactorily indicating that the system )

was operable. A second cause was that the reviewer failed '

to detect the error. Corrective action included counseling  ;

of the involved personnel, placing the LER in required  ;

reading, and providing additional training on the displays.

In addition, a console is being procured and incorporated

into the simulator in the next six months and a review of

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past surveillances will be performed. This item represents

a violation of NRC requirements which meets the criteria

for non citation. In order to track this item, the

following is identified.

LIV 50-424/88-09-02 "Failure To Perform TS Surveillance

4.3.3.6a Adequately - LER 87-72."

(e) 50-424/87-73, Rev. 0 "Containment Ventilation Isolation

Due To Sensing Tube Failure And Software Design" 50-424/

87-68, Rev. 0 "Control Room Isolation Due To Faulty Sensing

Tube And Software Design." 50-424/87-65,Rev. O "Contain-

ment Ventilation Isolation Due To Actuation Failure And

Software Design" 50-424/87-58, Revs. 0,1 "False Signal

From A Radiation Monitor Leads Tn Control Room Isolation".

These four LERs describe events which occurred from

detector spiking. Westinghouse is currently working on a

software fix to improve the performance of the instruments.

These LERs will remain open pending correction of the

software.

(f) 50-424/87-74, Rev. O "Technical Specification Violation

When Core Exit Thermocouples Not Declared Inoperable." On l

October 6, 1987, the licensee identified that a maintenance

work order had been written on April 13, 1987, to verify

that the thermocouple junction boxes were properly sealed

to address a lack of documentation concern. The October 6,

1987 deficiency was then processed without recognition of

the impact on Technical Specification requirements. The

sealing was performed on October 18, 1987. On December 18,

1987, the site determined that this item was reportable '

during the review of the October 6, 1987 deficiency.

Two corrective actions are being implemented to correct

these types of breakdowns. The first is a training I

program called "Commitment to Safety", which was recently  !

completed. This training is unique in the fact that I

corporate and site managers are making the presentations. l

Feedback from personnel attending the sessions indicates '

that the training may have a more long term payback as

personnel implement the ideals of the training. The

inspector viewed a video tape of the training. The second

corrective action was to expedite the review process. This

LER will remain open pending verification of corrective

action.

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This item has previcusly been identified as a violation

(NRC Rpt. 50-424/87-69-01). I

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(g) 50-424/87-76, Rev. 0 "Personnel Error Causes Loss of

Monitor Operability Resulting in TS Violation'2 On

December 27, 1987, while performing a surveillance

, procedure on the Train A containment hydrogen monitor, the

plant personnel identified that 3 of 4 panel bolts were

missing. The LER states that on November 26, 1987, during

the previous surveillance that the bolts were not replaced.

Corrective Actions includes the training of maintenance

personael on the requirements of procedure 00352-C "Control

Of In-Process Material". This item represents a violation

of NRC requirements which meets the criteria for non

citation. In order to track this item, the following is

identified.

LIV 50-424/88-09-03 "Failure To Maintain The A Train

Hydrogen Monitor Operable Per TS 3.3.3.6 - LER 87-76."

(3) The following LERs were reviewed and are considered closed.

(a) 50-424/87-59. Rev. 0 "Channel Checks Missed Due To An

Inadequate Procedure". On October 13, 1987, it was

discovered that channel checks on three containment

isolation valve had been missed. An additional valve ~ was

also missed. However, by reviewing other surveillances,

the licensee was able to conclude that the checks had been

performed. The inspector reviewed. procedure 14228-1,

Rev. 7T and noted that the four valves are included in

the procedure. This item represents a violation of NRC

requirements which meets the criteria for non citation. In

order to track this item, the following is identified.

LIV S0-424/88-09-04 "Failure to Perform TS 4.3.3.6 Channel

Checks - LER 87-59."

(b) *50-424/87-62, Rev.-0 "Inadequate Procedure Allows Improper

AFW Valve Lineup". On October 28,1987, at 6:42 p.m. , the

unit entered Mode 3 without the turbine driven AFW pump in

standby readiness. At 10:29 p.m., the failure to align the

system was identified and corrected. Since TS 3.7 1.2 i

requires this auxiliary feedwater pump operable in this  !

Mode, the licensee determined that TS 3.0.4 which precludes '

a Mode change unless the LCO can by met without reliance on

an action statement had been violated. Procedure Changes

to 10002-1 and 13610-1 were reviewed and corrective action

has been verified. This item represents a violation on NRC

requirements which meets the criteria for non citation. In

order to track this item, the following identified.

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LIV 50-42a/88-09-05 "Failure To Comply With TS 3.0.4 Mode

Change Requirements Regarding TS 3.7.1.2 - LER 87-62."

(c) 50-424/87-67, Rev. 0 "Technical Specification Surveillance

Missed Due To Personnel Error". On . November 16, 1987,

Surveillance Requirement 4.7.10 requiring a room tempera-

ture reading every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> was not performed due to wet

paint on the floors, making the area inaccessible. When

the error was identified, the shift supervisor took action

to complete the surveillance. This item represents a

violation of NRC requirements which meets the requirements

for non citation. In order to track this item, the follow-

ing is identified.

LIV 50-424/88-09-06 "Failure To Perform TS 4.7.10 Room 110

Temperature Surveillance - LER 87-67."

(d) *50-424/87-75, Rev. 0 "Missing Screws In The Nuclear

Instrumentation Drawer Leads To Technical 3 pacification

3.0.3 Entry". On December 22, 1987, a technician

identified that hold dcwn (cover) plate screws on a printed

circuit card rack were missing. This deficiency was found

to exist in the source, intermediate and power (except

Channel 1) ranges. The NIs were declared inoperable and

the plant entered TS 3.0.3, and was able to restore the

channels to operable service without having to place the

plant in a lower mode. Inspectors followed the event

at the time of occurrence and ensured the screws were

replaced. Training on procedure 00352-C "Control of

In-Process Material" corrective action and will be verified

with the closure of LER 50-424/87-76.

(e) *50-424/87-88 Rev. O "Malfunction Of A Reactor Coolant Pump

Protection Relay Causes Reactor Trip." On January 17,

1988, the unit tripped on low reactor coolant flow when #2

RCP tripped. The pump tripped as a result of a faulty

KD-10 relay used for pump overcurrent protection. During

the outage which followed the corrective action of relay

reelacement and the circuit design change was monitored.

Post trip review of this event was conducte'.f by the

inspector following the trip. The inspector has no further ,

questions regarding this LER.  !

c. Part 21 Reports

(1) (Closed) 50-424/P21-87-02 "Wound Rotor Pole Defect Supplied

With TDI Diesels". A letter dated December 3, 1987, by IMO

Delaval Inc., informed the licensee that a potential safety

hazard was identified to the NRC on November 16, 1987, regarding

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a failure of a wound rotor pole. While the cause of. failure

was not as yet known, this letter recommended that a visual

inspection of the generator rotor poles for damage be conducted.

The licensee inspected . both diesel generators and did not

identify any defect.

(2) (Closed) 50-424/P21 s '- "Jacket Water Heat Exchangers

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Inability To Meet The Maximun, Design Flow Rate". On January 19,

1988, IMO Delaval, Inc. informed the NRC that a potential

problem with the inability of the jacket water head exchanger

to achieve the maximum design flow rate as specified by the

manufacturer. Heat exchanger tube bundle damage was in the form

of the tube bundle being bent. The cause is att-ibuted to

excess water velocities when flushed at 1800 GPM. To preclude

damage, the flow rate should be limited to 750 GPM. The

licensee inspected both diesel generator heat exchangers and no

damage was evident. The origiral defect was discovered on this

unit. That heat exchanger is now on a Unit 2 diesel. This

deficiency was reported as CDR 50-424/86-109 and closed in the

NRC Report 50-424/87-48. Subsequent damage has been noted

on the Unit 2 diesels most likely as a result of flushing. ,

Bechtel is reviewing a design change to limit flow to the heat

exchangers to less than 750 GPM to preclude the potential for

damage. However, as a result of finding no damage on the Unit 1

diesel, the licensee has concluded that diesel operability is

not a concern. ,

5. Followup or Previous Inspection Items - (92701)

a. (Closed) UNR 50-424/88-02-01 "Review Reactor Startup Of July 12,

1988, and Determine If TS Requirements And Reportability Requirements

Were Met". The inspector reviewed the draft LER and DC card.

This review identified that the cause cf the event had not been ,

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determined. The draft LER noted that the startup procedure 12003-1

had been initialed as having procedure 14525-1 complete. The

inspector reviewed the Unit and Shift Supervisor Logs and the past

surveillances of 14525-1 and 12003-1. From this review, the

inspector concurred with the dr 't LER that the surveillance was not

in document corit.ol. The shift supervisor who initialed the 12003-1 i

was interviewed and the inspector learned that he initialed the

procedure berause he thought that someone had performed the surveil-

lance on the previous shifts. This shift supervisor realized that he ,

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should have utilized a direct verification such as a copy of the

, surveillance, review of logs or a watchstanders report. This issue

was also discussed with the Opera +, ions Manager to learn what specific

corrective action management hao taken regarding the individual .

From this discussion, the inspector learned that the individual had

'seen counseled regarding direct verification.

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The inspector concluded that a violation of NRC requirements had

occurred, had been identified by the licensee, and corrective action

had been completed. Since this meats criteria for non citation, this

item will be tracked for recurrence and is identified as.

50-424/ LIV 88-09-07 "Failure To Perform TS Surveillance 4.3.1.1 For

The Power Range Low Setpoint."

A second issue pertaining to this unresolved item concerned the

reportability of the missed surveillance. By corporate letter dated

August 18,'1987, the interpretation was made that TS section 4.0.2

would apply. The inspector reviewed with NRR the discussion

documented in NRC Rpt. 50-424/88-02 paragraph - 4.b.(6). and was

informed that the utility had made an incorrect interpretation

regarding 4.0.2 as applied to this surveillance.

TS Section 4.0.2 is to be applied to surveillance requirements only

and has no applicability to the limiting conditions for operability

or the action statements. Action statements invoking surveillance

requirements should be met without benefit of 4.0.2 provisions, since

the unit is in a degraded condition and licensee attention is focused

on ensuring that the plant is maintained in the safest condition. It

is for this reason, that a grace period does not exf st in the 3.0.X '

section of the TS.

Since this event represents a condition prohibited by Technical

Specification dua to a surveillance not being performed, the licensee

had failed to report the event pursuant to 10 CFR 50.73(a)(2)(1).

This item is one example of a violation and is identified as

Violation 50-4r ;'88-09-02 "Failure To Report A Condition Prohibited

By Technical S;aification Per 10 CFR 50.73(a)(2(i)."

b. (Closed) UNR 50-424/87-44-02 "Review Licensee's Findings Regarding

Missed Technical Specification Surveillances Not Reported." This

item was established to track the licensee's review of the potential

for failing to report missed surveillances. As stated in NRC Rpt. i

50-424/87-44, the Nuclear Safety and Compliance (USAC) organization i

at the site determined that on July 24, 1987, a conflict existed )

between the corporate guidance and the NRC position as presented in i

Generic Letter 87-09 dated June 4, 1987. Interim corrective action

was to inform all onsite departments that missed surveillances were

now reportable and a review was conducted to identify previous missed

surveillances. This review resulted in a two page evaluation .

describing the review process for missed surveillances and concluded l

that all missed surveillance prior to June 24, 1987, have been

evaluated for reportability in accordance with the above process.

The inspector questioned which surveillances prior to June 24, 1987,

were reviewed and which were reported. Since the licensee could not

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provide the details supporting the review, the inspector requested

that each DC be provided. The inspector was also provided a

interoffice memo which implies that only missed surveillances after

June 24, 1987, would be reviewed and reported. The inspector; was

provided six DCs which pertained to this subject. Of the six, the

inspector determined the following reportable based on the informa-

tion provided.

Event

DC Date Subject

1-87-865 3-8-87 28331-1 procedure to

perform 72 hr. leak

rate test on personnel

air lock was not

performed in allotted

time - TS 4.6.1.3

1 37-1055 4-3-87 Failure to satisfy the

frequency requirement

including allowable

grace period for

GE 400 amp circuit

breakers - TS 4.8.4.la.2

1-87-1214 5-1-87 Failure to sample waste

gas decay tank - TS 4.11.2.b

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1-87-1353 5-21-87 Failure to sample the

inservice waste gas decay

tank every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - 1

TS 4.11.2.6 l

1-87-1405 5-26-87 Failure to sample

waste gas decay tank

per due sample line blockage -

TS 4.11.2.6

The inspector notes with interest, that DCs 1-87-1214, 1-87-1353, and

1-87-1405 each discuss a similar missed surveillance. In addition,

LER 50-424/87-46 reports a missed surveillance of the same TS which

occurred on July 7,1987. During the NRC review of the LER, the

licensee was not issued a notice of violation based, in part, on the

event not being repetitive. The LER states in Section G.2 that there

are no previous similar events. Despite the fact that this could

constit utes a separate violation, the inspector feels that it would i

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be more appropriate to site the root cause of the violation (ie i

failure to report conditions prohibited by TS.)

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- Another example exists between DC 1-87-865 and LER 50-424/87-48, j

where the decision to not issue a notice of violation also was based,

-in part, on the_ event being non repetitive..

As a result of the above review, the inspector determined that a

second example of the violation regarding failure to report. missed

surveillance exists as~ identified in paragraph 5.a above.

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