ML20198R438

Insp Rept 50-416/86-11 on 860415-0519.Violation Noted: Failure to Maintain Control Room Ventilation Sys in Isolation Mode W/Chlorine & Radiation Detectors Bypassed

ML20198R438
Person / Time
Site:	Grand Gulf
Issue date:	05/29/1986
From:	Butcher R, Caldwell J, Dance H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198R349	List: ML20198R344 ML20198R385 ML20198R438
References
50-416-86-11, IEB-80-11, NUDOCS 8606100073
Download: ML20198R438 (14)

See also: IR 05000416/1986011

Text

UNITED STATES

[km ;tGuq'o NUCLEAR REGULATORY COMMISSION

[\, p REGION ll

y j 101 MARIETTA STREET, N.W.

• I f ATLANTA.GEORGtA 30323

\...../

Report No.: 50-416/86-11

Licensee: Mississippi Power And Light Company

Jackson, MS 39205

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

Facility Name: Grand Gulf Unit 1

Inspection Conducted: April 15 - May 19, 1986

Inspectors: ( d% O 23/r3

R.'C. Butcher', Senior / Resident Inspector 06te 51gned

C v S GfVZ

J. L. Caldweltl, Resident Inspector I)dte'51gned

Approved by: ( A%

H. C. Dance, Chief, Project Section 28

/06tef!J5

Signed

Division of Reactor Projects

SUMMARY

Scope: This routine inspection included resid'ent inspection at the site in the

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areas of Licensee Action on Previous Enforcement Matters, Operational Safety

Verification, Maintenance Observation, Surveillance Observation, Reportable

Occurrences, Operating Reactor Events, Inspector * Followup and Unresolved Items,

IE Bulletin, Confirmatory Action Letter & Generic' Letter Followup, Maintenance

Program Implementation, and Design, Design Changes & Modifications.

Results: Three Violations - Failure to maintain the control room ventilation

system in the isolation mode with the chlorine and radiation detectors bypassed;

Failure to utilize documented instructions for resetting safety / relief valve

(SRV) trip units resulting in the inadvertent opening of SRV F051B and failure to

update drawings to reflect a completed design change package modification;

Failure to adequately train personnel on fuse location / identification resulting

in the inadvertent startup of Division I of the combustible gas control sy: tem.

8606100073

DR 860602

ADOCK 05000416

PDR

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REPORT DETAILS

1. Licensee Employees Contacted -

1. W. Cavanaugh III, President & Chief Operating Officer

1. 0. D. Kingsley, Vice President, Nuclear Operations

1. T. H. Cloninger, ' :e President, Nuclear Engineering & Support

1. J. G. Cesare, Manager, Nuclear Licensing

1. F. W. Titus, Director, Nuclear Plant Engineering

1. S. M. Feith, Director, QA

1. • J. E. Cross, GGNS Site Director

• C. R. Hutchinson, GGNS General Manager

• R. c. Rogers, Technical Assistant

• J. D. Bailey, Compliance coordinator

M. J. Wright, Manaaer 9 ant Operations

• L. F. Daughtery, Ct- ance Superintendent

D. G. Cupstid, Tech. ;al Support Superintendent *

R. H. McAnulty, Electrical Superintendent

R. V. Moomaw, Manager, Plant Mair.tenance

W. P. Harris, Compliance Coordinator

• J. L. Robertson, Operations Superintendent

L. G. Temple, I & C Superintendent

J. H. Mueller, Mechanical Superintendent

• W. Eiff, Nuclear Plant Engineering QA

Other licensee employees contacted included technicians, operators, security

force members, and office personnel.

NRC Personnel

1. J. N. Grace, Regional Administrator, R II

1. D. M. Verrelli, Chief, Reactor Projects Branch 2, RII

• Attended exit interview.

1. Attended SALP meeting

2. Exit Interview

The inspection scope and findings were summarized on May 19, 1986 with those

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

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

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

inspection findings:

a. 416/86-11-01, Inspector Followup Item. 10 CFR 21 Report on Drywell

Personnel Air Lock Seals. (paragraph 7)

b. 416/86-11-02, Violation. Failure to maintain the control room

ventilation system in the isolation mode with the chlorine and

radiation detectors bypassed. (paragraph 8.a)

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c. 416/86-11-03, Violation. First example: Failure to utilize documented

instructions for resetting safety / relief valve trip units resulting in

the inadvertent opening of SRV F0518. (paragraph 8.b) Second example:

Failure to update drawings to reflect a completed design change package

modification. (paragraph 12)

d. 416/86-11-04, Violation. Failure to adequately train personnel on fuse

location / identification resulting in the inadvertent startup of

Division I of the combustible gas control system. (paragraph 8.c)

3. Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 84-23-01, Reorganization without a technical

specification change. This event was discussed with licensee management and

subsequent reorganization actions have been coordinated with NRC management.

4. Operational Safety Verification (71707)

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

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

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

plant operating staff.

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

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

instrument readings, setpoints and recordings status of operating systems,

tags and clearances on equipment controls and switches, annunciator alarms,

adherence to limiting conditions for operation, temporary alterations in

effect, daily journals and data sheet entries, control room manning, and

access controls. This inspection activity included numerous informal

discussions with operators and their supervisors.

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

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

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

lubrication, cooling and general condition; and instrumentation.

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

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

areas were visited. Observations included safety related tagout

verifications; shift turnover; sampling program; housekeeping and general

plant conditions; fire protection equipment; control of activities in

progress; radiation protection controls; physical security; problem

identification systems; and containment isolation.

No violations or deviations were identified.

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5. Maintenance Observation (62703)

During the report period, the inspector observed portions of the maintenance

activities listed below: The observations included a review of the work

documents for adequacy, adherence to procedure, proper tagouts, adherence to

Technical Specifications, radiological controls, observation of all or part

of the actual work and/or retesting in progress, specified retest

requirements, and adherence to the appropriate quality controls.

MWO IN6660, Control Building Fan Coil Unit Temperature Sensor

(07-S-53-Z17-5).

MWO M62273, Fire / Security Door Locking Mechanism Repair (LC0 86-476).

MWO EL1747, Inspection'& Cleaning Of Limitorque Valve Operators.

MWO I62844, Fuel Oil Transfer Pump Will Not Start In Automatic (Div. I Day

Tank).

No violations or deviations were identified.

6. Surveillance Observation (61726)

The inspector observed the performance of portions of the surveillances

listed below. The observation included a review of the procedure for

technical adequacy, conformance to Technical Specifications, verification of

test instrument calibration, observation of all or part of the actual

surveillances, removal from service and return to service of the system or

components affected, and review of the data for acceptability based upon the

acceptance criteria.

06-IC-IE31-M-1001, Revision 26, RWCU High Room & High Differential Room

Temperature (RWCU Isolation).

06-ME-SP64-R-1001, Revision 22, PGCC Halon System Flow Test.

06-IC-IC71-M-0001, Revision 25, Drywell High Pressure Functional Test

(RPS/PCIS).

06-IC-1E32-M-1001, Revision 21, MSIV Leakage Control System Pressure

Functional Test.

No violations or deviations were identified. .

7. Reportable Occurrences (90712 & 92700)

The below listed event reports were reviewed to determine if the information

provided met the NRC reporting requirements. The determination included

ade.quacy of event description and the corrective action taken or planned,

existence of potential generic problems and the relative safety significance

of each event. Additional inplant reviews and discussions with plant

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personnel as appropriate were conducted for the reports indicated by an

asterisk. The event reports were reviewed using the guidance of the general

policy and procedure for NRC enforcement actions. The following License

Event Reports (LERs) are closed. -

LER No. Event Date Event

• 86-009 March 19, 1986 Shutdown Due To Leak In ADS

Valve Pneumatic Supply.84-024 May 24, 1984 RHR Pipe Support Deficiencies.

• 85-040 October 21, 1985 Scram Accumulator Pressure

Alarm Drifts Low.

• 85-048 December 18, 1985 Loss of Power To Division 3 ESF

Bus.

• 85-050 December 31, 1985 Reactor Scram on Low Condenser

Hotwell Level.

Special Report 86-001/0 was submitted regarding the High Pressure Core Spray

(HPCS) diesel generator trip on March 22, 1986 while performing a monthly

functional surveillance. The cause of the trip was reverse power due to the

failure to increase the diesel generator load fast enough following

synchronization to the bus. No further action is required.

By letter dated October 24, 1983, the licensee reported a possible 10 CFR 21

defect on the drywell personnel air lock seal. The W. J. Woolley Company

informed the NRC that a Prespray airlock seal had failed the 465 F LOCA

environment qualification test for the Midland Nuclear Station. The

licensee's letter discussed the differences in the Midland test criteria and

the Grand Gulf test criteria. The licensee concluded that interim operation

was justified until the first refueling outage when new seals would be

qualified and available. By letter dated March 10, 1986, W. J. Woolley

Company informed the NRC that environmental qualification testing of a new

inflatable seal design and a qualicication report for Grand Gulf has been

prepared. This will be an Inspector Followup Item (416/86-11-01). The

licensee schedule for the fi'st refueling outage is now starting

September 1, 1986.

The event of LER 85-050 was addressed in IE Report 416/85-46 as part of

scram number 35.

The event of LER 86-009 was discussed in IE Report 416/86-08.

No violations or deviations were identified,

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8. Operating Reactor Events (93702)

The inspectors reviewed activities associated with the below listed reactor

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

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

examined instrument recordings, computer printouts, operations journal

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

engineering support personnel as appropriate.

a. Chlorine Detectors

On April 23, 1986 at 1:30 p.m. the licensee determined that both

Division I and Division II chlorine detectors in the control room fresh

air intake duct were inoperable due to the lack of intake air flow

through the detector sample line. Limiting Condition for Operation

(LCO)86-484 was initiated requiring that control room emergency

filtration system B be operated in the isolation mode to comply with

Technical Specification (TS) 3.3.7.8. b which states with both chlorine

detection channels inoperable, within one hour initiate and maintain

operation of at least one control room emergency filtration system

subsystem in the isolation mode of operation. Subsequently, on

April 25,1986 at 7:00 p.m. , the control room fresh air inlet damper

Z51-F016 was found to be open, this permitted air from the safeguards

switchgear room, which is supplied from outside air, to be lined up to

the control room filtration system and then to the control room. This

in effect brought outside air into the control room bypassing the

radiation monitors and the chlorine monitors located in the normal

ventilation duct.

The licensee interviewed the operators and an operator stated that he

had put the control room ventilation system in the fresh air mode

without notifying the shift superintendent. Also, the operators log

documents the operator putting the control room emergency ventilation

system in isolation mode but the operator did not log putting the

system in the fresh air configuration. System Operating Instruction

(501) 04-S-01-Z51-1, Control Room HVAC System, paragraph 5.4, Control

Room Isolation, states that after 10 minutes, if conditions permit, the

fresh air unit may be placed in the fresh air operation mode. The

operator was unaware that this action would require compensatory

actions to provide protection for bypassing the radiation monitors and

chlorine detectors. S0I 04-S-01-Z51-1 does not define what the

statement "if conditions permit" means or what compensatory actions are

required to be taken. FSAR 9.4.1.2, System Description, states that 10

minutes after isolation of the control room and when conditions permit,

fresh air can be brought in through the charcoal filter system. FSAR

6.4.4.2, Toxic Gas Protection, states that the isolation mode makeup

air flow, required after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of isolation (based on the buildup of

carbon dioxide to one percent by volume in the space due to the

respiration of 12 persons) must be initiated manually by the operator

after tests with portable air analyzers indicate the need to do so.

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The licensee has determined that the isolation mode makeup air flow

would realign to the isolation recirculation mode automatically upon

receipt of a LOCA signal. Also, in the isolation mode makeup air flow

configuration all outside air is processed through the control room

charcoal absorber train. A radiation monitor is provided in the

control room to detect abnormal radiation levels in the control room

area. This monitor alarms at 50.5 mr/hr. FSAR Table 2.2-6, Poten-

tially Hazardous Chemicals Stored Onsite, limits chlorine to 10

cylinders of 150 lbs/ cylinder in the yard area on the far side of the

Standby Service Water System basins. The chlorine does not appear to

be a significant hazard. The licensee has conducted a study that would

show the chlorine would not present a safety hazard and stated in LER

83-64 that a TS amendment to delete the chlorine detectors was being

processed. No TS change proposal for chlorine requirements has been

submitted to date. The licensee indicated that a TS change had

previously been proposed but, not submitted and would now be pursued

again. TS 3.3.7.8 and TS Table 3.3.7.1-1, item 6, requires that with

both chlorine detection channels or both control room ventilation

radiation monitors inoperable, within one hour initiate and maintain

operation of at least one control room emergency filtration system

subsystem in the isolation mode of operation.

TS 6.8.1 requires written procedures be established, implemented and

maintained covering procedures recommended in appendix A of Regulatory

Guide (RG) 1.33 Revision 2, February 1978. RG 1.33 recommends

procedures for the operation of control room heating and ventilation

systems. 501 04-S-01-Z51-1 was inadequate in that no criteria is given

for when the fresh air operation mode may be placed in service. From

1:30 p.m. on April 23, 1986 to 7:00 p.m. on April 25, 1986 the control

room emergency filtration system was not operating in the isolation

mode while both chlorine detection channels and both control room

ventilation radiation monitor channels were inoperable. This is a

violation (416/86-11-02). It was also noted that although SOI

04-S-01-Z51-1 is not specific, operator training might have prevented

this event. It was recommended that the licensee emphasize in training

the importance of determining what is required to realign the control

room ventilation system.

b. Scram No. 40

At 7:09 p.m. on April 7, 1986 Instrumentation & Controls (I & C)

technicians were in the process of resetting slave trip units on the

low-low set function of several Safety Relief Valves (SRVs) when SRV

1821-F051B was inadvertently opened. When the shift superintendent did

not have evidence that FU51B had closed after 2 minutes, he directed

the reactor operator to scram the plant. The licensee's review of

instrumentation traces and personnel interviews revealed that at

approximately 4:00 p.m. on April 7, a Maintenance Work Order (MWO) was

prepared to reset slave trip units B21-N616E, N616F, N617A and N6188

which were all in the tripped condition. At 6:30 p.m., upon learning

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the MWO had not completed processing, the shift supervisor directed the

I & C technicians to proceed to reset the trip units without waiting

for the MWO. While resetting the noted trip units with a Transmation

1040 Digital Calibrator unit, the technicians cleared the local trip

indication on trip units for channel F of the Division II trip system

but the trip relays locked in which would be indicated by a white light

and an annunciator on a front panel (P601). No one noticed this

indication. Subsequently, the technicians attempted to reset another

trip unit, for channel B of the Division II trip system, and caused SRV

F0518 to open. The instrumentation traces indicate that SRV F051B

opened for approximately 8 seconds, then closed for approximately 5

seconds and then reopened. The SRV was open for approximately 3

minutes and 40 seconds overall . Observations indicate that the

technicians observed the local indicators (red lights) on the trip

units went out but no check was made of the locking in of the trip

relays as indicated by the white light and annunciator on panel P601.

The operations personnel did not notice the indications or relate them

to the I & C operations. A Senior Reactor Operator trainee noticed the

Division II red light for a SRV solenoid energized on panel P601 and

alerted the operators. The operators attempted to close the SRV by

taking the handswitch on panel P601 to "off". The handswitch on P601

is for the Division I trip system and did not reset the Division II

trip system that was locked in by I & C. When this action did not

appear to close the SRV, the shift supervisor went to the back panel

and directed the I & C technicians to back off from the panel and stop

what they were doing. An operator obtained a key for the Division II

SRV handswitches (which are located on a back panel) and took the

switch for SRV F051B to "off". An operator at panel P601 attempted to

close SRV F0518 by taking the Division I handswitch to "on" and then

back to "off". This action possibly extended the time required for SRV

F051B to close. The shift superintendent asked the operator if two

minutes had passed and then directed the plant be scrammed.

Instrumentation data indicates SRV F051B closed within a few seconds of

the scram initiation. TS 3.4.2.1, action b, states in part that with

one or more safety / relief valves stuck open,. if unable to close the

open valve (s) within 2 minutes, place the reactor mode switch in the

shutdown position.

Material Nonconformance Report (MNCR) 0260-86 was written to document

the "apparently" long reclosure time of F051B and to clearup an

apparent discrepancy between data associated with this event and data

associated with SRV testing performed for MNCR 0369-85. GGNS relief

valves are steam assisted close action valves. When lifted, the valves

upper chamber is initially filled with steam that heats the valve body

and assists in closing. For a cold valve, if the valve is not quickly

reclosed, the steam in the upper chamber begins to condense and the

steam assist function is lost. This leads to long reclosure times

until the valve is sufficiently heated to flash the condensate and

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reestablish the steam assist function. However, cold valves which

receive a quick closure signal close quickly since the onset of the

condensing action does not have sufficient time to begin. Two valves

which were tested under MNCR 369-85 had sustained opening signals of

approximately 10 seconds. Condensate formed in the upper valve section

as the valves were heated. This led to closure times of 63 seconds for

one valve and 78 seconds for the other. Additionally, closure times

decreased (3 seconds) after a subsequent opening.

It should be noted that the solenoid actuated indication (a red light)

on panel P601 is for the Division II trip system and the solenoid

actuated indication (a red light) on the back panel is also for the

Division II trip system. There is no solenoid actuation indication for

the Division I trip system in the control room. Panel P601 also

contains another distinct indication of SRV opening by another set of

red lights which indicate a pressure of at least 30 psig in the SRV

discharge pipe.

TS 6.8.1 requires that applicable procedures recommended in

Appendix "A" of Regulatory Guide 1.33, Revision 2, 1978, be established

and implemented. Appendix "A" of Regulatory Guide 1.33 states that

Administrative Procedures for safety-related systems should be

implemented.

Administrative Procedure 01-S-07-1, Control of Work on Plant Equipment

and Facilities, paragraph 6.1.2, requires, except for trouble shooting

activities, all maintenance activities be accomplished using written

and approved work documents and/or work instructions and be authorized

by an approved maintenance work order or maintenance planning and

scheduling system task card. The failure to utilize documented

instructions for the resetting of the trip units of the low-low set

function of the safety relief valves and the resulting inadvertent

opening of SRV F0518 is a violation. This is the first example of

violation 416/86-11-03. See paragraph 12.

c. Combustible Gas Control System

At 3:35 a.m. on April 30, 1986 while hanging a tagout to deenergize

valves E61F009 and E61F057, the operator removed the wrong fuse which

inadvertently started Division I of the combustible gas control system.

This automatically started the Division I drywell purge system and

hydrogen analyzers. The fuse was reinstalled and the drywell purge

system and hydrogen analyzers were reset. An operator and an

electrician had taken the red tag equipment clearance sheet to tag

equipment to permit work on valves E61F009 and E61F057. The tag number

and equipment to be tagged were as follows:

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Equipment To Protected

Tag No. _Be Tagged Position

1 HSE 61F009 Auto / Closed

2 P871E61F01 Pulled

3 HSE 61F057 Auto / Closed

4 P871E61F02 Pulled

There is a fuse location aid at the panels which aids in locating the

correct fuse. An example of the location aid is as follows:

Fuse Fuse System Fuse Type Drawing

Location Number Number Size Voltage Number

TB-E F04 E61-F009 3 AMP DC E-1186-08

TB-E F08 E61-F001 3 AMP AC E-1186-01

The operator mistakenly went to system number E61-F009 which is for

fuse F09 instead of fuse F01 as called for in the tag clearance sheet.

Fuse F09 on the location aid is fuse number F04 which the operator then

pulled. This fuse initiated the Division I drywell purge system and

hydrogen analyzers. Fuse F01 on the location aid is correctly shown as

fuse number F08. The operator was confused in that the " System Number"

column is the actual fuse number with an extra zero and the " Fuse

Number" is the fuse location number in the panel. This confusion

coupled with the valve number being E61F009 contributed to the pulling

of the wrong fuse. 10 CFR 50, Appendix B, Criterion II and the

accepted QA program, MPL-TOP-1A, requires indoctrination and training

programs for personnel performing quality affecting activities which

assure that personnel performing quality affecting activities are

trained and qualified in the principles and techniques of the activity

being performed. The inadequate personnel training of fuse

indoctrination and identification resulted in the removal of the wrong

fuse and inadvertent startup of Division I of the combustible gas

control system is a violation (416/86-11-04)

9. Inspector Followup And Unresolved Items (92701)

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(Closed) Inspector Followup Item 416/84-51-06, Notification of Procedure

Revisions to Responsible Individuals. The licensee has completed

incorporating the master index for each directive into the TSO computer

system which is accessible to all plant staff through various TSO computer

terminals located in key locations. The master index is updated daily and

is a real time online index of all directives and TCNs.

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(Closed) Inspector Followup Item 416/83-14-04, Valve E12-CE-N001A not on

valve lineup sheet. The inspectors discussed this item with the licensee

and it was agreed that the personnel involved with ths removal / installation

of a conductivity element would be the only person required to operate

E12-CE-N001A.

10. IE Bulletin, Confirmatory Action Letter & Generic Letter Followup (92703)

(Closed) IE Bulletin 80-11, Masonry Wall Design

IE Bulletin (IEB) 80-11 was issued to Grand Gulf and other construction

sites for information only. This IEB was received and evaluated by the

licensee in order to respond to an NRC Office of Nuclear Reactor Regulation

information request which was transmitted to all licensee's who had plants

under construction by letter dated April 21, 1980. The information request

asked for data on the design and construction of Category I masonry walls in

plants under construction. The licensee provided the information requested

to NRR in a letter dated October 2, 1980. NRR documented review of the

licensee's design criteria for masonry walls in paragraph 3.8.3 of

Supplement 2 of the Safety Evaluation Report (SER), dated June 1982. The

SER stated that the licensee's design criteria for masonry was unacceptable

and a reevaluation was requested. The licensee submitted the reevaluation

in a letter to NRC dated January 19, 1982, in which they stated that the

masonry walls were reevaluated in accordance with IEB 80-11 requirements.

As a result of the reevaluation, it was necessary to modify 80 walls in the

control and auxiliary buildings. A condition was added to the Operating

License, License Condition 2.C.(8), which required that any additional

modification required as a result of NRC review of the licensee's

reevaluation criteria be completed prior to startup following the first

refueling outage. The licensee provided modifications to the masonry walls

in letters dated January 28, 1983 and April 13, 1983.

The inspector examined the licensee's action to complete IEB 80-11

requirements during inspections documented in Report Numbers 50-416/83-12,

50-416/83-36, and 50-416/83-41. Final acceptance of the licensee's criteria

for reevaluation of the masonry walls by NRR and the licensee's fulfillment

of License Condition 2.C.(8) is documented in a letter to the licensee from

NRR, dated November 4, 1985, Subject: Grand Gulf Nuclear Station -

Evaluation of Masonry Walls. IEB 80-11 is closed.

11. Maintenance Program Implementation (62700)

A review of maintenance activities associated with replacement of the A and

B recirculation pump shaft seals was conducted by the inspectors. These

maintenance activities were performed under Maintenance Work. Orders (MW0s)

M61952 for the A recirculation pump shaf t seal replacement and M60544 for

the B recirculation pump shaft seal replacement. The partial failure of the

B recirculation pump shaft seal resulted in a forced plant shutdown on

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February 12, 1986 due to exceeding the TS 3.4.3.2.b limit of 5 gpm for

unidentified leakage. The A recirculation pump shaft seal was replaced in

April 1986 due to a failure of the second of a pair of seals in series.

This replacement was completed during an unplanned reactor shutdown in April

of 1986 for an unrelated reason.

The cause of the seal failures was determined to be accelerated wear during

periods of pump operation with low seal differential pressures. These low

seal differential pressures occur when the plant pressure is well below

normal operating pressure. Since the recirculation pumps are required to be

operated during periods when the plant is shutdown and depressurized and

during plant start up and shut down, operation under low pressure conditions

is unavoidable. The licensee has investigated pump operation at low

pressures and determined that the recirculation pumps were not operated

during low pressure conditions unnecessarily. The licensee has also

determined an acceptable period of operation before seal replacement will be

necessary and the Maintenance Superintendent informed the inspector that a

recirculation pump shaft seal assembly will be replaced every refueling

outage. Therefore each pump shaft seal assembly will be replaced

approximately every three years.

The inspectors reviewed numerous aspects of the MWO M61952 and MWO M60544,

replacement of the A and B recirculation pump shaft seal assemblies

, respectively to ensure their compliance with the licensee's approved

program, procedures and requirements and applicable NRC rules and

regulations. This review did not reveal any associated problems. The

inspectors reviewed the licensee's maintenance history system which consists

of three computer systems. The basis of the system is the MWO which is

maintained in the licensee's document control system for the life of the

plant. Each of the computer systems use the MWO number and subject as the

historical data information referenced to a particular plant component. The

computer system will reference the MW0s related to a particular plant

component and state the MW0s location in the document control system. With

this information the MW0s can be pulled from document control and reviewed

for required information.

The review of the qualification and training of maintenance staff personnel

is discussed in inspection report 50-416/86-13.

12. Design, Design Changes and Modifications (37700)

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The inspectors reviewed a design change implementation package (DCIP) for

the installation of ductwork to supply cooling air from the outside air fan

system to provide spot cooling to diesel generator control panels 1H22-P113,

and 1H22-P115. Design Change Package 84/4063, Rev. O modified control

panels 1H22-P113, and 1H22-P115 for the Division I and Division II diesel l

generators. The control panels were subject to heat buildup which affected

control components and caused the loss of the diesel generators. MWO E60584

for Division I and K0 E60618 for Division II replaced the existing linear

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reactors with new linear reactors. The DCIP for the duct modification was

accomplished under MW0s F52304, F52305,F52354 and F52460. The DCIP had a .

completed 10 CFR 50.59 review. The design change was reviewed and approved

per established procedures and the retest was conducted per approved

directions.

A review of the diesel generator ventilation system drawing, M-1106A,

revealed the drawing had not been revised to reflect the incorporation of

DCP 84/4063. The Design Change Implementation Package (DCIP) review,

approval and implementation record (attachment 1 of administrative procedure

01-S-07-4) for DCP 84/4063 has a final close out review that states the

required documents were as-built and issued. The review sheet was signed as

completed on February 21, 1986. 10 CFR 50, Appendix B, Criterion V and the

accepted QA program, MPL-TOP-1A, requires activities affecting quality be

prescribed by documented instructions of a type appropriate to the

circumstances and be accomplished in accordance with these instructions.

Paragraph 6.6.2 of Administrative Procedure (AP)01-S-07-4, Plant Changes and

Modifications, requires the responsible engineer update the as-built drawing

list and ensure they are distributed prior to returning the affected system

to operation. As of May 21, 1986, drawing M-1106A had not been updated to

reflect the incorporation of DCP 84/4063.

The failure to update M-1106A is a violation. This is the second example of

Violation 416/86-11-03. See also paragraph 8b.

13. SALP Meeting

A meeting was held at the licensee's Corporate offices on May 12, 1986 to

brief the Regional Administrator and other NRC personnel on improvement actions

taken or planned in the Systematic Assessment of Licensee Performance (SALP)

program where the licensee received category 3 ratings for two consecutive

periods. These two areas, Licensing and Quality Programs and Administrative

Controls Affecting Quality received category 3 ratings for the SALP periods

September 1, 1982 thru September 30, 1983 and October 1, 1983 thru April 30,

1985. The attendees are listed in paragraph 1. This was the second progress

meeting with the licensee (See IE Report 416/86-02). In the area of

Licensing, the licensee emphasized the management attention being devoted to

enhance commitment adherence and closure; submittal accuracy, completeness &

timeliness; training of licensing & safety personnel; stabilization of

licensing by limiting contractor use and developement of a procedure for

Nuclear Production Department conduct of operations. Additionally, the

establishment of a plant licensing section and a Nuclear Production

Department deficiency reporting and evaluation system should ensure more

effective utilization of personnel.

In the area of Quality Programs the licensee emphasized the increased

personnel training in progress; management cross training efforts; increased

effort on root cause determination; expansion and implementation of detailed

nonconformance trending; expanded specific trend reports in functional areas

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with weekly reports to executive management. Developmental areas include

operability / functional assessments of syst' ems and increased QA involvement

in design, hardware and operational areas.

The licensee stated they welcomed the opportunity to review these issues

with the NRC and felt the meetings were useful and informative.

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