ML20198M686

Insp Repts 50-424/97-11 & 50-425/97-11 on 971102-1213. Violations Noted.Major Areas Inspected:Operations & Maint

ML20198M686
Person / Time
Site:	Vogtle
Issue date:	01/12/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198M315	List: ML20198M309 ML20198M340 ML20198M368 ML20198M686
References
50-424-97-11, 50-425-97-11, NUDOCS 9801200087
Download: ML20198M686 (18)

See also: IR 05000424/1997011

Text

33.

}l+

[ w, _

'

' ~

.. .-

,

'

.

,.

_

U. S. NUCLEAR REGULATORY-COMMISSIO,N'(NRC).-

'

"

4:

-

. REGION ll-~

i

,

-y--

l

-

Docket Nosi:50-424:and.50-425:

-

'

7 License Nos. NPF-68 and NPF.-81:

I

~ Report No:--

- 50-424/97-11,;50-425/97-11

Licensee:

' Southern Nuclear

rating. Company. Inc.

-

Facility:-

Vogtlel Electric Generating :lant (VEGP) Units 1 and 2

Location;.

7821 River Road

-

Waynesboro.;GA 30830

,

Dates:

November 2 through December 13. 1997--

Inspectors:

'M. Widmann. Acting Senior Resident Inspector

K. 0'Donohue. Resident'. Inspector

l Approved by:

P. - Skinner. - Chief

' ' '

Reactor Projects Branch 2

Division of Reactor Projects

.

>

>

t

j

khc

T.

ly..

-

-

Enclosure 3

.

~

9901200087 990112

PDR

ADOCK 0S000424

9

PDR

g

.

<

.

4

-%.,

,

,-

-l-

g

--

.--

. . _ _ . ,

s

e-

-

.

.

,

. .

-

.

.

.

.

- -

-.

..

.

.-

,

e-

-

EXECUTIVE' SUMMARY

U

-

.

Vogtle Electric Generating Plant: Units 1 and 2

L

-NRC-Inspection Report 50-424/97-11, 50-425/97-11

'

This integrated inspection included aspects of licensee operations

engineering. . maintenance, and plant suoport. The report-covers a 6-week.

>

period of resident: Inspection.

,

,

Ooerations-

In general, the conduct of operations was professional and

• -

-safety-conscious-(Section 01.1)..

'

The inspectors determined that technical specification (TS) minimum

>

.

-

requirements'for staffing were met, and that the licensee was adequately

staffed to respond to an event.

In addition, the inspectors concluded '~

. that the safety significt,nce of a- failure to aroperly implement standing

order (50) 2-97-04 " Residual Heat Removal (RiR) Train A Pump Room Drain -

2-1218-U4-101," which required an operator to be assigned non-

conflicting job functions, was minimal-. Although the licensee assigned.

multiple duties to one individual, that conflict did not impede the

licensee *s ability to. effectively respond to an accident (Section 01.2).

~

• '

' A non-cited violation was identified due to the assignment of multiple

-

'

< duties to operations personnel in conflict with 50 2-97-04

(Section 01.2)-.

The inspectors concluded that the licensee has the capability to close

dual function valves remotely with a safety injection (SI) signal

present (Section 01.3).

Clearances were performed (i.e., installed and removed) in accordance

established procedure guidance (Section 03.1).

The-freeze protection and heat tracing equipment was capable of

performing its intended function.

The improved equipment conditions

were the result of the license 2's effort to closecut previously

identified items (Section 03.2).

The inspectors concluded that the reactor systems for Units 1 and 2 were

operated and aligned in accordance with applicable plant procedures,

s

However, the inspectors identified a malfunctioning reactor power chart

recorder that went: undetected and uncorrected for approximately 32 days.

This was considered an example of. inattention to detail on.the part of

the control room reactor operators (Section 04.1).

.

Enclosure 3

,

l

x

.

v

,,,--e.

, ,

,

r

-

t

'

.

.

.

2

The inspectors concluded that the licensee's program for operator

.

requalification, specifically the implementation of segment

examinations. met the established program and procedure requirements.

Procedure 00715-C adequately addressed the various aspects of segment

examinctions to effectively administer exams and implement remedial

training as deemed appropriate (Section 05.1).

Maintenance

Observed maintenance and surveillance activities were thoroughly

+

m ipleted and professionally performed (Secticas M1.1 and M1.2).

A violation was identified for the licensee's failure to properly test

ti.? reactor tri) and bypass breakers in accordance with TS Surveillance

Requirements (Sls).

The inspectors concluded that the licensee's

surveillance procedures 14420-1/2 and 14421-1/2 were inadequate. In

that, the procedures did not test all required contacts for the reactor

trip and bypass breakers on a 31-day staggered Dasis consistent with the

trip actuation devite operability test (TAD 0T) requirements of TS

SR 3.3.1.4.

In addition, the inspectors also concluded that procedures

14752-1/2 were also inadequate. in that the procedures did not test the

P-4 signal generated by the bypass breaker to the electrohydraulic

control (EHC) system consistent with the TADOT requirement of TS SR 3.3.2.9 (Section M8.1).

A deviation was identified for the licensee's failure to perform

required testing of reactor coolant pump (RCP) circuit breakers per

Technical Requirements Manual (TRM) 13.8.1. Containment Penetration

Conductor Overcurrent Protection devices, at least once per 18 months

since initial startup of both units (Section M8.2).

Enclosure 3

I

- __ _

.

.

.

.

.

,

s

.

.

' '

-

.

.

,,

l

,

,

'Recort Detailst

ll

,

'

Summary of Plant Status

fUnit1

~

-The' unit operated ati full power-throughout the inspection period.

>

Lunit: 21

'

(The unit operated at full power throughout the inspection period.

I.

Ooerations

01

Conduct of _ Operations

'

01.1_ General Comments (71707)-

.

The inspectors conducted frequent reviews of ongoing plant operations.

In general, the reviews indicated that the conduct of operations was

,

professional and safety-conscious.

01.2' Shift Mannina-

- a '.

Insoection Scoce (71707)

The inspectors reviewed' operations department shift staffing to.

determine 'if the licensee has maintained requirements in accordance with

-

,

Procedure 00012-C, ' Shift Manning Requirements," Revision-(Rev.) 10 and

c

the staffing recuirements of Technical Specifications (TS).

Section 5.2.2. lnit Staff. . ThEinspectors reviewed control room logs:

'

the Emergency Plan. and applicable portions of the Updated Final Safety

Analysis Report (UFSAR).- As 3 art of this inspection effort. th

inspectors reviewed Standing Grder (S0) 2-97-04. " Residual Heat Removal

-

TRHi) Train A Pump Room Drain 2-1218 U4-101." The S0 was issued to

'2-1218-U4-101.perator to ensure that Unit 2 RHR drain valve-

. designate an o

be closed in an emergency situation. The drain valve,

.normally closed, was throttled open to allow continuous drainage of a

+

packing. leak on RHR train A suction valve 2-HV-8812A, The opened drain

valve, provided a potential pathway of radioactive material out of the

-auxiliary building following an Emergency-Core Cooling System (ECCS)

' injection and swap over to ECCS recirculation per Emergency Operating

'

-

- Procedure (EOP) 19013-C 'ES --1.3 Transfer to Cold Leg Recirculation '

"

manning: requirements :The inspectors also d', potential impact on shift

Rev.zl8.- 50-2-97-04 was reviewed due to the

V: _

~

scussed shift manning

-. issues _with cognizant operations personnel.

-

}bt : Observations and Findinas

Procedure 00012-C establishes-the minimum staffing. requirements for safe

Loperation of the plant as _ required by TSs.

Data Sheet 1. " Minimum-Shift

'

Enclosure'3

.

,

-

.,

-,

,.

.

.-

- .-.

-.

..

.

-.

. _ _ . _ _

. _ . _ . _ . . _ _ _ ,

_ _ _ , ,

_ . _ . _ _ _ _ .

.

"

!

.

t

2

i

.

~

"E rovides the licensee with a method to document the names of-

Hanning,l which fulfill the required TS and emergency response.

p

personne

positions.

The inspectors reviewed data' sheets from September through

~

- November 1997, ~ Based on this review, the licensee met the minimum--

staffing ~ requirements of TSs.

_;

'

During this review, the inspectors identified!that on several occasions.

a-non-licensed operator was assigned multiple duties. Specifically, on

two occasions. October 8 and 18, 1997, an operator was assigned as a

- member of the field monitoring team while also being designated to close

~

the RHR drain valve. The designation of an operator to multiple duties

was in conflict with the guidance of 50 2-97-04.

Theinspectors also

'noted during the review that an operator was assigned to the fire

brigade team on three different occasions while also being designated to-

close the RHR drain valve.

In addition. the inspectors identified that

the licensee failed to properly document in control room logs on -

.

numerous occasions the operator who was designated to close the RHR

valve.

Following review of Procedure-10002-C, ' Plant 0)erating Orders,"

Rev.12. E0P 19013-C and TS-5.4, Procedures, tie inspectors concluded

.that the 50 represented a procedure.

As such it required the review and

controls specified by TS 5.4.

Based on the review performed of the

control room shift supervisor logs and shift manning data sheets-

,

contained in Procedure 00012-C. the inspectors determined that the

measures of SO 2-97-04 were not properly implemented.

However, the safety significance of this issue was minimized, in part,

'

due to available personnel on site to respond to an event. A review of

records indicated that the licensee could have adequately staffed all

emergency response Jositions, as well as, designated an operator to

close the Unit 2 RH1 valve.

L

c,

Conclusions

The inspectors determined that the licensee met the TS minimum

requirements for staffing. The inspectors concluded that the licensee

,

-has been adequately staffed to respond.to an event. The safety

significance of the failure.to properly implement 50 2-97-04 was

4

minimal.

Although the-licensee assigned multiple duties to one

F

individual contrary to 50 2-97-04, that conflict would not have impeded

l-

the licensee's ability-to effectively respond to an accident.

However,

ithe assignment-of multiple duties to operations personnel was in-

conflict with-the S0. This failure constitutes a violation of minor

-significance and is treated as a Non; Cited Violation (NCV), consistent

E

with Section IV of the NRC Enforcement Policy. This is identified as

i

NCV-50-425/97-11-01. Failure to Properly-Implement Unit 2 Procedure

l

Promulgated As Standing Order.2-97-v4.

L

l0

_

_

Enclosure 3

L

l

r

L#

,

--

.

_

_

__

_

_

. - =

-

..

-

.. .

..

..

-

.

. . - -

--

.

-

--

-

.

,

i

g

i

'

3.

01.3: Dual-Function Valves

ca.

Insoection Scoce (TI 2515/136)

The-inspectors reviewed various dual function valves per guidance in

Temporary Instruction 2515/136, " Operation of vual-Function Containment-

Isolation Valves.1to determine if a design-deficiency concerning the -

ability of dual function valves to perform a-containment isolation.

. function existeu. . Specifically, the inspectors reviewed the licensee's

ability to remotely close' Containment isolation Valves (CIVs) with a

safety injection (SI) signal-present.

A dual function CIV is defined as

a valve that receives both an open signal for its safety function. as

>

u ll es a containment isolation signal.

For dual function valves. the

system safety function takes priority over the containment isolation

signal. Caring the ins)ection, the inspectors also reviewed the CIV

design and function wit 1 the system engineer,

b

Observations and Findinos

The1nspectors reviewed the containment isolation valves identified in-

the UFSAR and compared the list to the system piping and instrumentation

diagrams to verify all containment isolation valves were identified.

The UFSAR table of containment isolation valves appeared inclusive, and,

indicated which CIV had dual functions. The inspectors also reviewed

the control logic diagrams associated with dual function valves. The

inspectors ' determined that the engineering safety features actuation-

system (ESFAS) logic allows the SI signal to be reset with the

initiating condition still present..

Therefore, if there is a SI signal

present, the actuation signal can be re:,et, and effectively blocked, to

allow remote closure of the appropriate containment isolation valves

using its handswitch.

The reset of the SI signal. is addressed in the licensee's emergency

o)erating procedures. Operations personnel are frequently trained on

t1e emergency procedures and are expected to be familiar with the reset

process.

c._ Conclusions

The -inspectors concluded that the licensee has the capability to close

dual function valves. remotely with a SI signal present,

o

i-

Enclosure 3

.

.

-

_

.

.

-_

.

,

.

4

-03

Operations Procedures and Documentation

03.1 Walkdown of Clearances (71707)-

During the inspection period, the inspectors walked down the following

clearances:

-19700776

Nuclear service cooling water pump 5 discharge valve

1-HV-11605

29700307

Control room filter unit train A

29700417

Component cooling water pump I train A; rework outboard

bearing-

b.

Observations and Findinas

The inspectors did not identify any problems or concerns during these

walkdownr.

Clearances were performed (i.e.. installed and removed) in

'

accordar.ce with established procedural guidance.

03.2 Cold Weather Preoarations

a.

Scone (7171.4_1

The inspectors reviewed the licensee's cold weather program.

The review

included inspection of insulation and heat tracing on safety reiated

systems: freeze protection panels: verification of completed work orders

and review of open maintenance work orders (MWO): preventive maintenance

(PM) checklists. SCL01749. " Freeze Protection." and SCL00424. " Heat

Tracing." The inspectors also interviewed the responsible system

engineer,

b. Observations and Findinos

On November 24. 1997, the inspectors performed a walkdown of Unit 1 and

Unit 2 heat tracing and freeze protection equipment.

The inspectors

noted a general improvement in the equipment condition from arevious

inspections although additional work remains outstanding.

T1e

inspectors determined that the equipment was adequately maintained to

ensure performance of its intended safety functions.

Several concerns including missed preventive maintenance, work orders

that were several years old, and poor condition of field equipment, were

previously identified in Inspection Report 50-424, 425/96-12.

As part

of this inspection, the inspectors reviewed the status of the work

orders on heat tracing and freeze protection equipment. Work was

completed during the summer and fall of 1997 on heat trace and freeze

protection systems which resulted in the improved general condition of

equipment and control panels.

Enclosure 3

.-

.

.

5

Two MW0s. initiated in 1996. remained open due to plant conditions not-

allowing for the work' activity;'however, the remaining open MW0s were

initiated in 1997.

The inspectors also verified that preventive

. maintenance was prioritized, scheduled, and performed appropriately.

-

The inspectors performed.a walkdown with the system engineer of the

majority of the freeze protection control panels specifically to inspect

Discrepancies identifie, trol panels were

The con

for cleanliness conditions and general repair.

d during the

found to be in good condition.

walkdown were documented and are being tracked by the licensee.

Insulation observed during walkdown was also noted to be in acceptable

condition.

that operator aids were taped to most of the ninels.pectors observed

During the freeze protection panel walkdown, the ins

The cperator aids

were not controlled per administrative Procedure 10009-C. " Operator

Aids." Rev. 9.

The system engineer confirmed that information on the

operator aids was correr.t. therefore the inspectors' observation were

administrative in nature. The inspectors forwarded the minor issues

identified, such as the uncontrolled operator aids and inconsistent

spare circuit breaker positions in the freeze protection panels-. to

licensee management.

c.

Conclusion

The inspectors concluded that the freeze protection and heat tracing

equipment was capable of performing its intended function. The improved

system conditions were the result of the licensee's effort to closecut

previously identified items.

04

Operator Knowledge and Performance

04 1 Walkdown of Control Room Instrumentation

a.

Insoection Scoce 01707)

As part of routine plant observations the inspectors walked down the

Unit I and Unit 2 control room instrumentation. The inspectors reviewed

a)plicable procedures and drawings to verify proper system alignments.

.Tle inspectors also discussed plant system parameters and associated

indications with control room licensed operators.

b

Observations and Findinos

During the walk downs, the inspectors noted that systems were aligned

per procedureLrequirements. Plant parameters were within ex)ected

ranges.

No significant discrepancies were observed during tie walk

downs. However, the inspectors did identify one instrument not properly

responding to plant operation. The inspectors observed that Unit 2

,

reactor power chart recorder (NR-45) operatior, was slightly erratic.

Enclosure 3

.

_

__

_

.

-.

.~

__

_ _- . ..__ _

__

__

T

-

.

.

6-

"

The recorder indicated reactor power at approximately 101 to 102%. .

?

Investigation by the on-duty reactor operator determineo that the chart

i

recorder was not- functioning properly due to a bent spring. MWO

l

J29702956 was-generated-to address this issue. l Further review by the

-

inspectors of NR-45 recorder perfermance 1dentified that the recorder.

had not been operating properly forlapproximately 32 days. On

1

December 3, 1997, the licensee performed the MWO to restore the recorder-

to normal operation.

~

>

v

c.

Conclusions

1

The inspectors concluded that the reactor systems for Units 1 and 2 were

-

'

operated and aligned in accordance with applicable plant procedures.

^:

However.-the inspectors' identification of a malfunctioning reactor

_ power chart recorder, which existed for approximately 32 days, was an

.

example of inattention to detail on the part of the control room reactor

operators.

"

4 05

Operator Training and Qualification

-05,1 Review of Seament Examination Proaram'

,

a.

Insoection Scone (71707)

The inspectors reviewed a portion of the licensee's requalification-

program,-specifically, segment examinations. and the application of the

program requirements per Procedure 00715-C. " Licensed Operator

Requalification Program." Rev.15.

In addition, the inspectors

discussed the training requirements and implementation of the program

-with cognizant trairing personnel.

b.

Observations and Findqqs

A review of the training records for the previous four segment

>

examinations indicated that the majority of the operators tested met or-

exceeded the minimum acceptance criteria established in

Procedure 00715-C.

In the cases where operators either failed a

specific-segment examination (< 70%). or their rolling four segment

examination average fell below the 80% criteria, the appropriate actions-

were taken by the licensee.

In accordance with Procedure 00715-C.

remedial training was provided and a second exam administered,

Remedial

-

training provided was properly documented. The: inspectors noted during

review of Procedure 00715-C that it did-not_ address the status of an

- operator's license due to failure of a segmentJexam or whose four-

l segment' examination average drops below the 80% criteria.

Based on

discussions with training personnel, the licensee indicated that no

-

restrictions are ) laced on an operator's license due to a single segment-

4

exam failure or wio's average score falls below the minimum as the-

result of'one exam. The inspectors noted that a number of operators

performed licensed duties in the control room after failure of a segment

i

Enclosure 3

-

._

w hre ]'

-

s

-

w

c

g-

,

. . - -

.

- -

.

- - .-.. -- -. - -.

- -

--.--_

.

,

-

p

.-

,

'

7:

-

t

-

.

.

.

o

exame .Per Procedure 00715 C. operators who received remedial training-

have until the. end of the subsequent training _ segment-to successfully

i

pass the. failed segment.

In all cases-reviewed, operators who initially..

failed.a segment exam or fell below the minimum rolling' average!

acceptance criteria were retested and satisfactorily met the program

requirements.

,

-Procedure 00715 C states that an operator wh6-fails to meet the-

.

!

acceptance criteria established for a retest shall require the immediate

removal of that operator from licensed duties.

However, based on

.

records and the time period reviewed, no accelerated training was

required for any operator. Accordingly operators who assumed licensed

duties in the control room met the requirements of 00715-C.

.c.

Conclusions

The inspectors concluded that the licensee's program for operator

--

requalification, specifically the implementation of segment

examinations, met the established program and procedure requirements.

Based on this review. Procedure 00715-C adequately addressed the various

~

aspects of segment examinations to effectively administer exams and

'

implement remedial training as deemed appropriate.

08

Miscellaneous Operaticns Issues (92901)

08.1 (Closed ) Violation (VIO) 50-424/97-07-01: Failure to Document Entry

Into Proper Action Condition Following Airlock Maintenance

a.

IDipectionScoce(92901)

4

The inspectors reviewed the corrective actions associated with the

+

. licensee's failure to enter the appropr16te Limiting Condition for

Operation (LCO) action condition during the performance of a maintenance

activity on the Unit 1 airlock shaft seal.

.

b.

Observations and Findinas

The licensee's corrective actions were: identified in correspondence

,

dated September 25, 1997. The licensee )rovided operations personnel

additional training and guidance as to t1e proper action condition entry

for Technical S)ecification LC0 3.6.2 " Containment Air Locks."

_#

specifically, w1en maintenance is being performed on the air lock

bulkhead versus .the air -lock. door.

c.

Conclusions-

Based on.a review of the licensee's corrective actions, this violation-

..is closed.

'

!

-

Enclosure 3

'

=

,

1

^r

i

r

-

%

we-

T

w

h*T*

'--t-

-Tevt--==-+1'-

r'

-+

-'it9

W

~Bt-

-'

'W4-

.

.

8

08.2 (Closed) VIO 50-425/97-05-Q2: TS LCO Entry Not Documented Properly

a.

Inspection Scope (92901)

This violation dealt with the licensee's failure to properly document

entry into all applicable TS LCOs for a containment sump level

transmitter that was inoperable.

The inspectors reviewed the corrective actions identified in the

licensee's response to this violation in correspondence dated July 18,

1997,

b.

Observations and Findinos

The 'nvolved operations personnel were counseled as to the importance of

LC0 entry / exits, the need to reference all applicable TSs. and to list

applicable actions on the LC0 tracking sheets,

i

c.

Conclusions

Based on a review of the licensee's corrective actions, this violation

is closed.

II.

Maintenance

M1

Conduct of Maintenance

M1.1 tiaintenance Work Order Observations

_

a.

Inspection Scone (62707)

The inspectors observed portions of maintenance activities involving the

following work orders:

19703485

Investigate ground on isolation device panel OIP2 train B

19703544

Auxiliary relay room emergency safety feature fan switch

,

A-HS-12823A re)lacement

19703547

Fuel handling auilding unit relay change out

19703598

Main steam isolation valve 1-HV-3016B loop 2 train B

hydraulic pump cycling

29700055

Investigate annunciator ALB15D01 on 2-HV-30368 main steam

isolation valv

NR-45reactorh'owerrecordernotoperatingproperly

29702956

29703112

Spent fuel pool purification filter rep 4c? ment

b.

Observations and Findinas

The observed maintenance activities were thoroughly completed and

professionally performed.

Enclosure 3

H

.7

-

-

. . . . . - - -

...,-

--..

...~

-

.

~ - .

-.

- - . . . .

'

-

.

. -

,

9

_

-Hl.'21.-Jyf.veillance Observation'

-a. .105.)ectionScone(61726)

' Thifinspectors observed the performance or reviewed the following;

strveillar.ces:and plant-procedures:l

44490-1-

Containment cooling system operability and-response time-

test. Rev. 8 -

l14604 2

Solid. State Protection System (SSPS) slave relay K617 t,ain

A test safety injection, Rev. 2

14608 2

=SSPS slave relay K601 train A test safety injection Rev. 7

14802 2

~ Nuclear service cooling water pumps 1, 3 and 5 and check

valve inservice test and response time test. Rev. 13-

14905 2-

Reactor cooling system leakage calculation. Rev.16

~

14980-2

Diesel-generator operability test, Rev. 46

T ENG 97-30 Component cooling water pump performance test, Rev. 0

b.

Observations and Findinas

The observed surveillance activities were thoroughly completed and

professionally performed,

M8-

Miscellaneous Maintenance Issues (92902)

HO.1 -(Closed) Unresolved Item (URI) 50-424. 425/97-04-04: Interlock Testing

of Reactor Trip Bypass Breakers

,

a.

1DID stion Scone (37551) (61726) (92902) (973Q1),

'This URI documented inspector questions concerning the adequacy of

- surveillance testing of reactor trip bypass breakers.

Specifically, the

inspectors identified a concern that the licensee did not test the P-4

interlock feature of the bypass breaker prior to placing them in

service. Additionally. the inssectors were concerned that the P-4

signal generated by the by) ass areakers and supplied to the turbine

,-

Electrohydraulic Control (EHC) system was not verified in the licensee's

'

surveillances.

The inspectors reviewed the following procedures that

-were used to test the reactor trip and bypass breaker circuits:

,

Procedure 14420-1.

" Solid State Protection System and Reactor Trip

Breaker Train A Operability Test." Rev. 27:.

Procedure 14420-2,.

" Solid State Protection System and Reactor Trip

Breaker Train A Operability Test." Rev. 19:

Procedure 14421-1.

" Solid State Protection System and Reactor Trip

Breaker Train B Operability Test." Rev. 8:

.

R

Enclosure 3:

<

V

-

-_

-

..

- - .

.

. . - .

_

.

.

~'

.

,

.

e

10

Procedure 14421-2.

" Solid State Protection System and Reactor Trip

Breaker Train B Operability Test.' Rev. 6:

Procedure 14752-1.

" Reactor Trip Systen P-4 Interlock Test "

Rev. 4:

Procedure 14752-2.

" Reactor Trip System P-4 Interlock Test "

Rev. 4.

In addition, the inspectors reviewed the Technical Specification (TS)

surveillance requirements (SR): 18-month preventive maintenance

Procedures 27765-C. * Westinghouse Type DS 416 Circuit Breaker

Maintenance." Rev. 25. and 27767 C.

Reactor Trip Switchgear Check Out

and Maintenance." Rev. 5: and test circuit breaker drawings.

The

inspectors also reviewed this issue with cognizant licensee personnel,

b.

Observations and Findinas

The P-4 signal is developed by a combination of cell switches (33b

contacts) and auxiliary contacts (52b contacts) actuated by the reactor

trip breaker and bypass breakers.

Once generated, the P-4 signal is

provided to the SSPS to enable the feedwater isolation feature. and to

the turbine EHC system to actuate a turbine trip.

Different sets of 33b

and 52b contacts on the reactor trip and bypass breakers are used to

develop these two functions.

TS SR 3.3.1.4. Reactor Trip System Instrumentation, required the

licensee to perform a Trip Actuation Device Operability Test (TADOT) on

the bypass breakers prior to placing them in service on a 31-day

staggered test basis.

A TAD 0T consisted of operating the trip actuating

device and verifying the operability of required alarm. interlock, and

trip functions.

The TADOT included adjustment, as necessary, of the

tri) actuating device so that it actuated at the required setpoint

witlin the required accuracy.

Therefore, to satisfy the TAD 0f

requirements the licensee's test required a 31-day operability

verification of the reactor trip breaker and bypass breaker auxiliary

and cell switch contacts, used as P-4 interlock, to provide the

initiation signal to SSPS and EHC systems,

Based on the inspectors'

review, the licensee verified half of the total number of contacts used

in the P-4 interlock on a monthly basis.

TS SR 3.3.2.9. Engineered Safety Feature Actuation System

Instrumentation, required an 18-month TADOT to be performed to verify

that the P-4 signal was generated for both the SSPS and EHC systems.

This test verified that the P-4 signal was generated from both the

reactor trip and bypass breakers.

The TADOT verified the function of

the brcaker circuit, not just contact position. A review of the

licensee's surveillance procedures indicated that the P-4 signal to SSPS

was tested for both the reactor trip and bypass breakers.

However.-the

inspectors identified that the licensee surveillance procedares did not

Enclosure 3

. . -

,_

- . _

_ . _ _ . .

.

. _.

._

_ . _ . .

,

K

-

. . , .

,

.

.

r

~

11.

j

,

-contain a provision to test the P-4 signal-to the EHC system from the

reactor trip bypass breaker;

A' review of:the plant: design, indicated '

-

, '- .'

that a test circuit did not exist'.to test the P-4 signal to the EHC

-

system from the bypass breaker,

__

i

+

-c.

Con 61usions

1

The inspectors concluded that the licensee's surveillance procedures

14420-1/2 and 14424-1/2 were inadequate, in that, the procedures did not

test all 33b and 52b contacts for.the reactor trip and bypass breakers.

on a 31-day staggered basis consistent with the TAD 0T requirements of TS-

SR 3.3.1.4.

The inspectors also concluded that licensee procedures-

-

o

14752-1/2 were inadequate, in that, the procedures did not test the P-4

'

signal generated by the bypass breaker supplied to the EHC system:

consistent with the TADOT req)uirement of TS SR 3.3.2.9.

-

This-is

'

identified as Violation (VIO 50-424, 425/97-11-02. Inadequate

Surveillance Testing of P-4 Interlock for Reactor Trip Bypass Breakers,

w

Based on documenting this issue as a violation, this URI is closed.

M8.2 -(Closed) Licensee Event Reoort (LER) 50 424. 425/97-007-00: Containment

o

-Penetration Electrical Overcurrent Protection Not Tested

a.

Insoection Scone (61726) (92902) (92903) (92700)

This LER documented a missed Technical Requirements Manual (TRM)

surveillance for Reactor Coolant Pump (RCP) 125 volt direct current

.

control power circuit breakers. The inspectors reviewed the LER and

subsequent corrective actions, a Unit 2 temporary modification to

address the issue, and the deficiency cards generated.

The inspectors

also interviewed cognizant engineering personnel.

b.

Observations and Findinas

On September 12,- 1997 .during an engineering review, the licensee

determined that thcre were circuit breakers that provided control power

through containment penetrations to.RCP-lift oil pump pressure switches.

The licensee identified that those breakers were not tested in

accordance with.either the current TRM or former TS surveillance

requirements from the original plant startup for both units.

At the

itime of discovery, the Unit 1 breakers were deenergized due to an

'

'

ongoing refueling outage, subsequently, no immediate action was-

necessary.

The licensee installed temporary-fuses in the Unit 2 -

for testing.the circuit breakers.pping capability, obviating the need .-

circuits to provide redundant tri

The breakers wre successfully. tested

on Unit 1 prior to restart from the refueling outage.

.

h

The licensee determined that the Vidated Final Safety Analysis Report-

(UFSAR)! Table 16.3-5 Containment penetration' Conductor Overcurrent

~ Protection Devices and: Isolation Devices for Class IE to Non-Class 1E

Feeds, did not list a circuit breaker number for one of the two breakers

-

,

,

Enclosure 3

.

-4+9e:s

,.-,.

f

- - - - , -

9

7

pp,-

7

-r.y.-,-

, , . -

, ,

p.

4,.

.y,

,,c'.

cv.,.

.

.

-

-.

-

.

.

.

12

'

installed in the RCP lift oil pump penetratica.

This oversight resulted

in only one of the two breakers being included in the surveillance

procedure, and consequently, not all breakers were tested in accordance

with the TRM.

As part of the licensee's planned corrective action, the licensee

initiated a Request for Engineering Assistance (REA) to quantify the

potential affects of a circuit failure on these penetrations in order to

justify possible deletion of the dual overcurrent protection

requirement.

Pending completion of the REA. the Unit I and Unit 2

breakers will be tested or permanent fuses will be installed.

c.

Conclusions

Based on their review, the inspectors concluded that the licensee failed

to oerform required testing of RCP circuit breakers per TRM 13.8.1.

Containment Penetration Conductor Overcurrent Protection devices, at

least once per 18 months since initial startup of both units.

This is

identified as Deviation (DEV) 50-424, 425/97-11 03. Failure to Perform

Containment Penetration Circuit Breaker Surveillances.

Based on this

review, this LER is closed.

M8.3 (Closed ) VIO 50-425/97-01-01:

Auxiliary Feedwater (AFW) System

Surveillance Not Conducted _As Required by TS

a.

Insoection Scoce (61726) (92903)

This violation documented a missed surveillance as the result of NRC

identification that six valves in the Unit 2 auxiliary feedwater

recirculation flow path were not verified in the correct position within

the surveillance time frame of 31 days.

The inspectors reviewed the licensee's corrective actions identified in

the licensee correspondence d'ted May 9, 1997.

b.

Observations and Findinas

The licensee revised both the Unit 1 and Unit 2 " Safety Related Locked

Valve Verification Checklists." (Procedures 11867 1 Rev. 28. and

11867-2. Rev. 21).

In addition, the licensee incorporated this

violation example into the lessons learned program.

Saecific training

emphasizing component positioning and verification tec1niques and

expectations was also provided to operations personnel,

c,

Conclusions

l

Based on the review of the licensee's corrective actions, this violation

l

1s closed.

L

Enclosure 3

l

L

..

.

.

.

13

M8.4 (Closed) LER 50 425/97-001-00:

Surveillances Not Performed For Unlocked

Valves

This issue was documented in Inspection Re) ort 50 424, 425/97-01

(Section M3.1).. The inspectors reviewed tie corrective actions

identified in the LER and concluded that they are sufficient.

No new

issues wre identified in the LER.

This LER is closed.

IV.

Pl.antSupport

F8

Hiscellaneous Fire Protection Issues

F8.1

(Closed ) Violation (VIO) 50 424. 425/97-05-07:

Fire Extinguisher and

Hose Station Missed Surveillance

a.

Insoection Scooe (71707)

This violation documented a missed surveillance as the result of Nucit.r

Regulatory Commission (NRC) identification of six fire ho'e stations in

the Unit 2 nuclear service cooling water tower tunnels and five fire

extinguishers located in the fire pump house with expired inspection

stickers.

The inspectors reviewed the licensee's corrective actions documented in

correspondence dated July 18. 1997,

b.

Qblervations and Findinas

The licensee revised Procedures 29100-C. " Portable Fire Extinguisher and

Fire Hose Station Visual Inspection." Rev. 9 and 29134-C. " Portable

Fire Extinguisher Annual Surveillance." Rev. 5. to provide better

coordination for the performance of monthly and annual surveillances.

c.

Conclusions

Based on the review of the licensee's corrective actions, this violation

is closed.

Er. closure 3

.

l

l

l

l

.

-

..

.. -

_ _. _

_._.

.

_ . _ _ _ _ . -

,

'

e

P

-

-14

_

'

_

V.

Manaoement Meetinas and Other~ Areas

1

X

Review of Updated _ Final Safety. Analysis Report'(UFSAR)

>

A recent ' discovery of a licensee o>erating its facility in a manner

contrary to the UFSAR description lighlighted the need :for a special!

l

focused review that corr ares plant practices, procedures and/or

-

'

parameters to the UFSAR descriptions.

While performing the inspections

discussed in this resort, the inspectors reviewed the applicable

portions of.the UFSAR that related to the areas-inspected. The-

inspectors verified that the UFSAR wording was consistent with the

i

observed plant practices, procedures and/or parameters except where

noted in this report.

X1

Exit Meeting Summary

,.

The inspectors ) resented the inspection results to members of licensee

management at t1e conclusf on of the inspection on December 16. 1997.

Tine licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during

the inspection should be considered-proprietary.

No proprietary-

information was identified.

PARTIAL-LIST OF PERSONS CONTACTED

Licensee

J. Beasley. Nuclear Plant General Manager

.

J. Gasser. Plant Operations Assistant General Manager

S. Chestnut. Manager Operations

K. Holmes. Manager Maintenance

B. Burmeister. Manager Engineering Support

M. Sheibani.. Nuclear Safety and Compliance Supervisor

C? Tippins. Jr., imclear Specialist I

INSPECTION PROCEDURES USED

IP 37551:

Onsite Engineering

IP 61726:

Surveillance Observation

IP 62707:

Maintenance Observation

IP.71707:-

- Plant Operations

IP 71714:

Cold Weather Preparations

IP 92700:

- Onsite Notification of Written Reports of Non-routine Events

<

At Power Reactor Facilities

+

.-

.

IP 92901:

Followup - Operations

IP 92902:

Followup - Maintenance

.IP 92003:

.

- Followup _ - Engineering

f

TI 2515/136L

- Operation of Dual Function Containment Valves

Enclosure 3

'

,

.

i

~ - - - .

- - .

,

e

-+

_

,

,. ,

.,,m_g,,e,,

,

,,

, . -

,

m..,

-

,.wr_,

.

'

.

_

.-

15

,

.

ITEMS OPENED AND CLOSED

-

i

Doened

.

50-425/97-11-01

NCV

Failure to Properly Implement Unit 2

Procedure Promulgated As Standing Order

2-97-04 (Section 01.2).

50-424. 425/97-11-02

VIO

Inadequate Surveillance Testirq of P-4

Interlock for Reactor Trip Bypass Breakers

(Section M8.1)

'

50 424, 425/97-11-03

DEV

Failure to Perform Containment Penetration

Circuit Breaker Surve111ances

(Section M8.2)

0101ee

50-424/97-07-01

VIO

Failure to Document Entry Into Proper

Action Condition Following Airlock

Maintenance (Section 08.1)

50- 425/97-05 02

VIO

TS LC0 Entry Not Documented Properly

(Section 08.2)

50-424, 425/97-04-04

URI

Interlock Testing of Reactor Trip Bypass

Breakers (Section M8.1)

'

50-424, 425/97-007-00

LER

Containment Penetration Electrical

Overcurrent Protection Not Tested

(Section M8.2)

50-425/97-01-01-

VIO

AFW System Surveillance Not Conducted As

Required by TS (Section M8.3)

50-425/97-001-00

LER

Surveillances Not Performed For Unlocked

Valves (Section M3.4)

50-424. 425/97-05-07

VIO-

Fire Extinguisher and Hose Station Missed

Surveillance (Section F8.1)

Enclosure 3

. .