ML20150D504
| ML20150D504 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| 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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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET,N.W.
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ATLANTA, GEORGI A 30323
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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
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Inspectors:
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JP F. Roggy,' Senior R4Cdent Inspector
Date Signed
h//AA /A
2 }$Yh
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C V.' Bu geF,"8e Vent Inspector
"/Date Srigned
Approved By:
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O
M.'W. Sinkule, Section Chief
(fate St'gned
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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 ggggg,
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DR
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-
Violation 50-424/88-09-01 "Failure To Establish An Adequate Procedure
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For The Performance Of TS 4.3.3.6." - Paragraph 4.b.(1)(c).
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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
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unit obtained Mode 4.
On February 7, Hot Standoy (Mode 3) was entered and
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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-
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.
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Proper Control Room staffing
Control Room access and operator behavior
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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
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
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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 -
14601-1
RWST Low Level
1
14000
Operations Shift and Daily
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Surveillance Logs
14225
Operations Weekly Surveillance
Logs
(7) Maintenance Activities (62703)
The inspector observed
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maintenance activities to verify that correct equipment
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clearances were in effect; work requests and fire prevention
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:
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MWO No.
Work Description
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18800941
Repositioned limit switch and valve arm on
1 HV 15199 (Bypass Feed Isolation Valve,
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Loop 4).
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18800241
Investigate and repair excessive hydrogen
usage from main generator.
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MWO No.
Work Description
(cont'd)
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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
have hole drilled in upstream side of
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1 HV8716B.
18800609
Hole drilled in upstream side of valve discs
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from valves 1 HV8716A and 1 HV8716B.
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18800670
Replaced the duplex' fuel filter assembly and
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fuel filter for diesel generator B.
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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
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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.
b.
Licensee Event Reports and Deficiency Cards
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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
of the event prior to receipt of the written report.
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(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
isolation valve without realizing that the feedwater system
was in long cycle recirculation. Upon opening the valve,
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
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Reading Instrument Shorted The Main Exciter Field".
On
February 15, 1988, at 5:55 p.m., the unit tripped from 100%
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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
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
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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.
(a) 50-424/87-52, Rev. O "Inadvertent Containment Ventilation
Isolation During Source Check Of Radiation Monitor."
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.
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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,
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while reviewing fuel oil documentation, the reviewer noted
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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
the criteria for nan citation.
In order to track this
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 -
LER 87-71."
(d) 50-424/87-72,
Rev. 0
"Inadequate
Training
Causes A
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
surveillance on the Reactor Vessel Level Indication System
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(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
were performed satisfactorily indicating that the system
was operable. A second cause was that the reviewer failed
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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
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.
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Two corrective actions are being implemented to correct
these types of breakdowns.
The first is a training
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program called "Commitment to Safety", which was recently
completed.
This training is unique in the fact that
corporate and site managers are making the presentations.
Feedback from personnel attending the sessions indicates
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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.
This item has previcusly been identified as a violation
(NRC Rpt. 50-424/87-69-01).
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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
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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
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requires this auxiliary feedwater pump operable in this
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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
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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.
"Jacket Water Heat Exchangers
(2) (Closed)
50-424/P21 s '-
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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.
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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
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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
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surveillance, review of logs or a watchstanders report. This issue
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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
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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.
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50-424/87-44, the Nuclear Safety and Compliance (USAC) organization
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at the site determined that on July 24, 1987, a conflict existed
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between the corporate guidance and the NRC position as presented in
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
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
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 /> -
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1-87-1405
5-26-87
Failure to sample
waste gas decay tank
per due sample line blockage -
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
consti utes a separate violation, the inspector feels that it would
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be more appropriate to site the root cause of the violation (ie
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failure to report conditions prohibited by TS.)
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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.