ML20203N156

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Insp Repts 50-324/86-18 & 50-325/86-17 on 860701-31. Violations Noted:Failure to Follow Procedures Re Smoking & Rigging Scaffolding to Snubber Extension
ML20203N156
Person / Time
Site: Brunswick  
Issue date: 09/12/1986
From: Fredrickson P, Garner L, Ruland W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20203N119 List:
References
50-324-86-18, 50-325-86-17, NUDOCS 8609230172
Download: ML20203N156 (14)


See also: IR 05000324/1986018

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UNITES STATES

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NUCLEAR REGULATORY COMMISSION

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REGION 11

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101 MARIETTA STREET, N.W.'

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ATLANTA, GEORGI A 30323

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Report-Nos.: 50-325/86-17 and 50-324/86-18

l.icensee: Carolina Power and Light Company

P. O. Box 1551

Raleigh, NC" 27602

Docket Nos.: 50-325 and 50-324

License Nos.: DPR-71 and DPR-62

Facility Name: Brunswick 1 and 2

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Inspection Co(ducted:

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-31, 1986

Inspectors:[

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Approved by:

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P. E. Fredrickson, Section Chief

ate Signed

Division of Reactor Projects

SUMMARY

Scope: This routine resident inspector safety inspection examined the areas of

maintenance engineered safety features observation, surveillance observation,

operational safety verification, onsite follow-up of events, survey of licensee's

response to selected safety issues, ESF system walkdown, and TIP tube reversal.

Results:

Two violations were identified:

failure to follow procedures

concerning smoking and failure to follow procedure concerning rigging scaffolding

to a snubber extension.

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REPORT DETAILS

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Licensee Employees Contacted

P. Howe, Vice President - Brunswick Nuclear Project

C. Dietz, General Manager - Brunswick Nuclear Project

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T. Wyllie, Manager - Engineering and Construction

J. Holder, Manager - Outages

E. Bishop, Manager - Operations

L. Jones, Director - Quality Assurance (QA)/ Quality Control (QC)

R. Helme, Director - Onsite Nuclear Safety - BSEP

J. Chase, Assistant to General Manager

J. O'Sullivan, Manager - Maintenance

G. Cheatham, Manager - Environmental & Radiation Control

E. Enzor, Director - Regulatory Compliance

B. Hinkley, Manager - Technical Support

R. Groover, Manager - Project Construction

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A. Hegler, Superintendent - Operations

W. Hogle, Engineering Supervisor

B. Wilson, Engineering Supervisor

R. Creech, I&C/ Electrical Maintenance Supervisor (Unit 2)

R. Warden, I&C/ Electrical Maintenance Supervisor (Unit 1)

W. Dorman, Supervisor - Quality Assurance (QA)

W. Hatcher, Supervisor - Security

R. Kitchen, Mechanical Maintenance Supervisor (Unit 2)

C. Troubel, Mechanical Maintenance Supervisor (Unit 1)

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R. Poulk, Senior NRC Regulatory Specialist

D. Novotny, Senior Regulatory Specialist

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W. Murray, Senior Engineer - Nuclear Licensing Unit

W. Ziegler, Principal Engineer - Corporate Nuclear Fuels Section,

Operations Support

Other licensee employees contacted included construction craftsmen,

engineers, technicians, operators, office personnel, and security force

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members.

2.

Exit Interview (30703)

The inspection scope and findings were summarized on August 4,1986, with

the vice president and general manager.

The two violations, failure to

follow procedure regarding smoking and failure to follow procedure regarding

rigging scaffolding to a snubber attachment (parafcaph 6), were discussed in

detail. Also discussed was management tours of the vital areas (paragraph

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6). One Unresolved Item *, TIP Tubing Reversal (paragraph 10), was discussed

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with the general manager during a special meeting on July 25, 1986.

The

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  • Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or deviations.

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licensee acknowledged the findings without exception. The licensee did not

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

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inspectors during the inspection.

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3.

Followup on Previous Enforcement Matters (92702)

Not inspected.

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4.

Maintenance Observation (62703)

The inspectors observed maintenance activit.ies and reviewed records to

verify that work was conducted in accordance with approved procedures,

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Technical Specifications, and applicable industry codes and standards. The

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inspectors also verified that:

redundant components were operable;

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administrative controls were followed; tagouts were adequate; personnel were

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qualified; correct replacement parts were used; radiological controls were

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proper; fire protection was adequate; quality control hold points were

adequate and observed; adequate post-maintenance testing was performed; and

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independent verification requirements were implemented.

The inspectors

independently verified that selected equipment was properly returned to

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service.

Outstanding work requests were reviewed to ensure that the

licensee gave priority to safety-related maintenance.

The inspectors observed / reviewed portions of ' the following maintenance

activities:

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86-BDAG1

2-G31-F001 Failed to Close on Group 2 Signal.

86-BDGB1

Reactor Manual Control System Inadvertent Rod

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Movements.

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86-BFFC1

Nuclear Service Water Low Pressure Annunciator

Transmitter Calibration.

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86-BFQA1

Work on G16-F003 Valve.

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MI-03-03A

General

Pressure / Vacuum

Switches

Instrument

Calibration.

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MI-03-4U12

Texas Instrument TIGRAPH 200 Recorder Calibration.

MI-03-38A5

General

Electric

Power

Supply

Type

570-06

Calibration.

No violations or deviations were identified.

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5.

Survei'.ance Observation (61726)

The inspectors observed surveillance testing required by Technical

Specifications.

Through observation and record review, the inspectors

verified that:

terts conformed to Technical Specification requirements;

administrative controls were followed; personnel were qualified; instrumen-

tation was calibrated; and data was accurate and complete. The inspectors

independently verified selected test results and proper return to service of

equipment.

The inspectors witnessed / reviewed portions of the following test activities:

E&RC-0358

Weekly Check of the Area Radiation Monitors High

and Low Setpoint Alarms.

E&RC-1221

Sampling and Analysis Procedure for Routine Steam

Jet Air Ejector Off-Gas Analysis.

E&RC-1222

Operat. ion of Gas Chromatograph.

E&RC-2016

Sampling and Analysis of Drywell Purges.

1 MST-PCIS25M

PCIS High Main Steam Line Flow Trip Unit Channel Al

Calibration.

01-03.1

Periodic

Testing

and Control Operator Daily

Surveillance Report - Unit 1.

01-03.2

Periodic

Testing

and Control Operator Daily

Surveillance Report - Unit 2.

PT-01.11

Core Performance Parameter Check.

No violations or deviations were identified.

6.

Operational Safety Verification (71707)

The inspectors verified conformance with regulatory requirements by direct

observations of activities, facility tours, discussions with personnel,

reviewing of records and independent verification of safety system status.

The inspectors verified that control room manning requirements of 10 CFR 50.54 and the Technical Specifications were met.

Control room, shift

supervisor, clearance and jumper / bypass logs were reviewed to obtain

information concerning operating trends and out of service safety systems to

ensure that there were no conflicts with Technical Specifications Limiting

Conditions for Operations.

Direct observations were conducted of control

room panels, instrumentation and recorder traces important to safety to

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verify operability and that parameters were within Technical Specification

-limits.

The inspectors reviewed shift turnover sheets to verify that

continuity of system status was maintained.

The inspectors verified the

status of selected control room annunciators.

Operability of a selected Engineered Safety Feature (ESF) train was verified

by insuring that: each accessible valve in the flow path was in its correct

position; each power supply and breaker, including control room fuses, were

aligned for components that must activate upon initiation signal; removal of

power from those ESF motor-operated valves, so identified by Technical

Specifications, was completed; there was no leakage of major components;

there was proper lubrication and cooling water available; and a condition

did not exist which might prevent fulfillment of the system's functional

requirements.

Instrumentation essential to system actuation or performance

was verified operable by observing on-scale indication and proper instrument

valve lineup, if accessible.

The inspectors verified that the licensee's health physics policies /

procedures were followed. This included a review of area surveys, radiation

work permits, posting, and instrument calibration.

The inspectors verified that: the security organization was properly manned

and security personnel were capable of performing their assigned functions;

persons and packages were checked prior to entry into the protected area

(PA); vehicles were properly authorized, searched and escorted within the

PA; persons within the PA displayed photo identification badges; personnel

in vital areas were authorized; and effective compensatory measures were

employed when required.

The inspectors also observed plant housekeeping controls, verified position

of certain containment isolation valves, checked a clearance, and verified

the operability of onsite and offsite emergency power sources.

a.

Open Control Room Airlock Doors

On July 8,1986, at about 7:15 a.m. , the inspector observed that both

doors of an airlock leading into the back of the control room were

open. The inner door had been removed for modification and the outer

door had been wired opened.

In accordance with the security plan, a

security guard was posted at the vital entrance, the inner door. The

passageway leads to a metal office building which had been added to the

radwaste roof after original construction.

Onshift responsible

personnel were unaware of the condition and ifad not authorized opening

of the outer door. At the time work was authorized, verbal instruc-

tions had been issued to keep the outer door closed. The outer door is

clearly marked as " Fire Door / Keep Closed." However, at the time, the

outer door was posted as being an inoperable fire door and was being

monitored by a roving fire watch.

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Final Safety Analysis Report, amendment No. 4, dated June 2,1986,

cescribes .the leak tightness and toxic gas protections of the control

room.

Section 6.4.2.4, Interaction with Other Zones and Pressure-

Cuntaining Equipment, states:

The following provisions were taken into consideration in the

Control Room Area Ventilation System design to assure that there

are no toxic or radioactive gases and other hazardous material

that would transfer into the Control Room:

(a) The Control Room envelope is maintained at static pressures

slightly higher than atmospheric to prevent infiltration from

the outside.

(b) Doors and other openings into the Control Room are

conspicuously marked to assure that they will normally remain

closed.

This administrative control will assure that the

Control Room normally remains closed. The doors are equipped

with reclosers.

Section 6.4.4.2 states:

Infusion of chlorine contaminated air will be inhibited by:

1)

Quick-acting dampers having a maximum travel time . of

five seconds or less.

Total

isolation time (time

between 5 ppm chlorine signal at the control room

chlorine detector and completed damper travel) require-

ment is less than or equal to 10 seconds.

2)

Tightly fitting and weather-stripped doors, and

3)

By having all cable conduits to the Control Room potted

or sealed.

In addition, Technical Specification 3.7.2 requires two control

room emergency filtration systems be operable or the unit must be

in at least hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown

within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. One of the conditions of operability is

the successful completion of surveillance requirement 4.7.2.d.4,

which requires every 18 months a verification that the system

maintains the control room at a positive pressure relative to the

outside atmosphere during system operation.

The licensee is investigating the event.

The licensee reports

that the outer door was opened between 6 and 7 p.m. on the

preceding day (July 7,1986), was closed about midnight and then

re-opened some time prior to the inspector's discovery. Hence, it

appears that the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to be in hot shutdown was not exceeded.

Also, af ter the fact, the licensee performed a test with both the

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doors open and showed that with the emergency filtration system

operating, smoke would blow out the passageway away from the

control room.

The tank car siding chlorine monitors, not assumed

operable for the FSAR analysis, were also operable during this

time.

The licensee interviewed personnel involved. Because of the heat

and poor ventilation in the area, an individual apparently

attempted to find out why the outer door could not be opened. In

discussions with a non-licensed operations department staff

member, the individual thought that he had gotten permission to

leave the door open. However, the operations person, after seeing

that the fire door was already under fire watch, apparently

indicated that he saw no reason why it should not be opened. The

operations person believed that this was only for a short duration

to allow some air flow and did not intend to give the impression

that it could remain open.

This miscommunications led to the

first instance of wiring the door open. The circumstances around

the second instance is still being reviewed.

During the review, the licensee determined that the on-duty senior

auxiliary operator, a licensed individual, and a shift technical

advisor made one or more entrances or exits through the passageway

while both doors were open.

Neither apparently recognized that

the condition could adversely impact the control room habitability

as described in Technical Specifications and the FSAR.

The

inspectors have concluded that no violations ;of the control room

boundary occurred. The guard who was posted on the door, could

have shut the door in the event of an accidental chlorine release

maintaining the boundary.

The inspector plans to review the

licensee's determinations concerning the breakdown in work

controls and actions to prevent recurrence when the experience

report is completed.

This is an Inspector Followup Item, Review

of Unauthorized Control

Room Pressure Boundary Extensions

(325/86-17-03 and 324/86-18-03).

b.

Scaffolding Attached to Seismic Support

On July 11, 1986, the inspector ooserved scaffolding attached to the

Unit 1 Reactor Core Isolation Cooling (RCIC) System discharge line

seismic support. A 4 by 4 was resting on and wired to the snubber,

E51-41SS89, attachment rod and paddle assembly.

The scaffolding had

been erected on July 8,

1986, by a craft <farker of the mechanical

construction group.

Procedure WP-18, Temporary Construction Loads,

states that " Rigging from pipe hanger struts, spring cans, snubbers or

snubber parts shall not be allowed." The scaf folding had been rigged

on the snubber attachment, a snubber part, and thus was prohibited by

WP-18.

10 CFR 50, Appendix 8,

Criterion V,

requires activities

af fecting quality shall be accomplished by procedures.

Failure to

follow WP-18 in the rigging of scaffolding is a violation:

Rigging

Scaffolding to RCIC Snubber Attachment (325/86-17-01).

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c.

CAC-V10 Open During Walkdown

On July 17, 1986, while performing a walkdown of the Unit 2 main

control bcard, the inspector found CAC-V10, Outboard Drywell Purge

Exhaust Valve, open.

In accordance with procedure OP-24, Containment

Atmosphere Control System, Revision 67, the valve is normally closed

per valve check list page 107, and is specified to be closed after

primary containment inerting per step 7.1.B 9.

The on-duty operator

indicated that it had been closed during turnover, about 30 minutes

earlier. He cycled the valve and left it in the closed position. He

further commented that the valve had been slow to open during his last

use of the valve. However, no difficulty had been observed in closing

the valve. CAC-V10 receives a close signal during a Group 6 isolation.

CAC-V9, Drywell purge exhaust isolation valve, was closed when CAC-V10

was found open, maintaining the containment.

The licensee initiated

work request 86-BEAHl. Further review revealed that this condition had

been reported earlier on work request 86-BAEF1, dated June 18, 1986.

Apparently, an operator had given the valve an open signal and the

valve had stayed closed.

Then, at some later time, the valve opened.

The inspector verified that the valve logic would allow the valve to

perform in this fashion.

Instructions have now been issued to

operators to log the opening of the valve and any problems encountered.

The inspector has no further questions at this time.

d.

Smoking In Diesel Generator Building

The inspector found eight smoked cigarette butts in two ventilation

ducts in the diesel generator building. The ventilation ducts connect

the emergency switch gear rooms with the diesel generator fan room.

The rooms are separated by a concrete wall with the exception of the

ducts.

Both rooms are frequently patrolled by Technical Specification

required fire watches.

The inspector did not find anyone smoking

cigarettes in the diesel building.

However, the inspector believes

that evidence of smoking is sufficient reason to warrant further

management attention.

Fire Protection Procedure FPP-014, Rev. 2, Control of Combustible,

Transient Fire Loads and Ignition Sources, attachment 3,

lists the

Diesel Generator Building as a no smoking area.

The cigarette butts

found in the ventilation duct indicate that smoking had occurred in the

building.

This failure to follow procedure FPP-014 is a violation:

Cigarette Smoking in the Diesel Generator Building (375/86-17-02 and

324/86-18-02).

e.

Management Entry Into Vital Areas

The inspector reviewed security access logs to verify that plant

management toured the vital areas on a regular basis.

The inspector

reviewed the personnel transactions of management as recorded by the

Brunswick Security System from June 26 to July 28, and also on July 29,

1986.

The vice president and several managers, and most of the

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principal managers had made several tours during the above period. A

few managers had not conducted tours of the plant during this period.

The operations superintendent, whose office is in the control room, had

not entered either the reactor building, the service water building, or

the diesel generator building during the period.

Howeve'r, the

operations superintendent had been off-site about ten days during the

above period.

The inspector discussed the issue with senior plant

management.

Management visits to the plant will continue to be

monitored by the inspectors.

Two violations and no deviations were identified.

7.

Onsite Follow-up of Events (93702)

On July 11, 1986, at 3:03 a.m. Unit 2 was manually scrammed from 17% of full

power while conducting a normal reactor shutdown to repair a reactor water

cleanup (RWCU) valve. The licensee decided to scram the unit earlier than

anticipated because of problems with the reactor manual control system

(RMCS). After the scram, the licensee found that the inboard drywell floor

drain primary containment isolation valve, G16-F003, had failed to close on

a group 2 isolation signal and Source Range Monitor (SRM) C had failed

downscale. Excluding these items, all systems responded as expected and the

condensate /feedwater systems and main condenser were used for level and

pressure control.

Unit 2 was being shutdown to repair the inboard RWCU suction primary

containment isolation valve, G31-F001.

During surveillance testing, the

valve had been observed to bind and trip its breaker on 300% overload. In

accordance with Technical Specification 3.6.3.a,

the outboard isolation

valve was closed, thereby removing RWCU from service. The valve was found

to have the actuator bearing house cover cracked with some internal damage

to the actuator. The licensee believes the valve may have had a hairline

crack in the cover which had not been detected when the valve was repaired

during the last outage. The valve had been damaged when it was actuated with

the torque switch installed backwards during a post modification test.

The

licensee inspected the valve disc and seat for damage. None was found. The

actuator was repaired and the valve successfully timed and leak checked.

The RMCS malfunction involved the random insertion or withdrawal of a

control rod one notch when a rod was selected prior to the operator turning

the rod control switch. This was attributed to a loose wire in the RMCS

which would cause the RMCS electronic timer to reset af ter a rod movement

was complete and the rod deselected but before *the subsequent rod is

selected. When a different rod is selected, it can move one notch on its

own prior to a command from the operator.

The wire was properly secured.

The investigation revealed that this phenomenon can also occur if an

operator attempts to select a rod while the electronic timer is running. In

this case, the operator's action sets up a " relay race" between final rod

movement and deselection and selection of the next rod while the timer is

running; e.g., if a rod can be selected (rod movement complete, deselection

of a rod is complete and the timer is still running), the timer will reset

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and the newly selected rod will move one notch. The interval during which

this can occur is from final rod mavement (settle function complete) to the

end of the timer sequence, 0.5 seconds.

Administrative controls now

-instruct the operators to verify the timer has stopped prior to . selecting

the next rod.

The licensee is evaluating a modification to prevent the

" relay race". The problem with the RMCS did not effect the Rod Sequence

Control System (RSCS), that is, at no time was a rod pattern outside the

notch constraint pattern when RSCS was controlling.

G16-F003, which had failed to close on the group 2 isolation signal and from

the control board manual switch after the scram, functioned correctly during

trouble shooting.

The licensee suspects that some blockage in the air

solenoid may have caused the malfunction and the blockage subsequently

cleared. The licensee did not disassemble the solenoid because no rebuild

kit was found in stock.

The licensee instituted a program to weekly cycle

this valve and three similar ones until the affected solenoid is rebuilt and

examination of the solenoid internals can be performed. On July 31, 1986,

while performing the surveillance, G16-F003 would not shut. The licensee

closed the other isolation valve per Technical Specification 3.6.3.a.

Instrument and control technicians datermined that the solenoid was

sticking. Discussions between maintenance and engineering revealed that a

rebuild kit was available and had been all along.

The solenoid was

subsequently repaired and returned to service.

Apparently maintenance

planners had attempted to locate parts for the old style solenoid which had

been removed during the last outage. The inspector plans to review the

licensee's experience report concerning failure determination and part mixup

when it is issued.

No violations or deviations were found.

8.

Survey of Licensee's Response to Selected Safety Issues (TI 2515/77)

The subject Temporary Instruction (TI) involved surveying the actions that

the licensee is taking to address two safety issues:

reliability of the

High Pressure Coolant Injection / Reactor Core Isolation Cooling (HPCI/RCIC)

Systems and biofouling of cooling water heat exchangers.

Actions taken through the end of this report period associated with

HPCI/RCIC reliability include incorporation of information frum vendors,

General Electric and Institute of Nuclear Power Operations (INPO), as

applicable, into their preventive maintenance, calibration and testing

programs.

In addition, the licensee established in early 1986 an inter-

disciplinary task force to seek additional improvements to increase systems

reliability.

The areas and goals being studied include:

adequacy and

frequency of test program, development of methodologies for validating a

reliability monitoring program and establishment of an effective reliability

monitoring and predictive maintenance program.

Completion is expected in

1987.

The following NUREG-0737 items regarding HPCI and RCIC have been

closed:

II.K.3.13, II.K.3.15, II.K.3.22 and II.K.3.24.

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The only systems considered susceptible to biofouling are those -involving

water drawn from the Cape Fear River and marshes. Systems such as the fire

protection system using the county water system or deep wells are not

considered susceptible to biofoulin0

An event involving significant

degradation of the Residual Heat Removal (RHR) heat exchangers (Hx) was

described in Information Notice (IEN) No. 81-21, Potential Loss of Direct

Access to Ultimate Heat Sink.

The event was attributed to failure to

maintain the chlorination system operational during periods of anticipated

marine organism growth.

Since that time, the chlorination system has been

upgraded

and chlorination

is

provided continuously.

Since

1982,

non-availability of the chlorination system has been limited to less than

two weeks.

Success of the program has been verified during refueling

outages in which inspections of heat exchangers and associated piping has

shown little or no evidence of biofouling.

The licensee has established

procedures and trained operators for coping with significant heat exchanger

performance degradation if it should occur.

The licensee periodically

monitors the RHR Hx baffle plate differential pressure to ensure that

biofouling would be detected in time to prevent recurrence of the IEN 81-21

event.

The inspector concluded .that the licensee's actions taken in response to

these safety issues as well as ongoing actions demonstrate a positive

attitude and sensitivity to the importance of these items.

No violations or deviations were identified.

9.

Engineered Safety Features System Walkdown_(71710)

The inspector performed a complete walkdown of the accessible portions of

the Unit 1 and 2 Core Spray System to verify system operability.

The

inspector verified that: hangers and supports were functional, housekeeping

was adequate, valves and pumps were properly maintained, component labeling

was correct, instrumentation was properly installed and functioning, power

was available to motor-operated valves and that valves were in the correct

position, and that the room coolers were operable.

The inspector verified that all system instrumentation was listed on either

the periodic test scheduling designator report (for non Technical Specifi-

cation instruments) or calibrated using a PT or MST (for Technical

Specification instruments). All system instrumentation required for system

operability was verified installed and calibrated.

The inspector verified that the system checklists'in OP-18, Core Spray (CS)

System Opercting Procedure, Revision 6 for Unit 1 and Revision 24 for

Unit 2 contained the major system valves as indicated by the Core Spray

piping and instrumentation drawings (P&ID), [0-25024, Sh. 1 (Rev. 19),

0-25024, Sh. 2 (Rev.17), D-2524, Sh.1 (Rev. 20), 0-2524, Sh. 2 (Rev.19)].

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The inspector found two drawing discrepancies on the CS P&ID's.

The

isolation valves for the CS leak detection instrumentation (V87, V88) were

shown as open on the Unit 1 P&ID but shown as locked open on the Unit 2

P&ID. The Unit 1 P&ID did not show that pressure switches PS-N008A & B, and

PS-N009A & B supplied the ADS permissive logic. The licensee will correct

the drawings.

The licensee has removed the Unit 1 Division I & II core spray suction

relief valves, F032A & B.

The licensee has removed the valves because they

leaked by and replacements were not readily available.

EER 85-256 allows

continued operation of the system with 1-E21-F032A removed and the suction

valves caution tagged to prevent operation with both the torus and

condensate storage tank suction valves shut. A similar EER was issued for

1-E21-F0328. The relief valve's setpoint was 125 plus or minus 10 psig to

protect the suction piping in case both suction ifnes are isolated and the

discharge line valves leaked by.'The relief valve lines are now capped with

a 150 psig flange that has been operationally leak tested. The EER expires

September 15, 1986.

The inspector has no further questions about the

suction relief valves at this time.

The inspector verified that the

readings of the four core spray sparger high differential pressure switches

were consistent with the system description.

The inspector compared the readings of the four core spray sparker high

differential pressure switches. They read as follows:

1-E21-N004A:

110" with plus or minus 3" swings

1-E21-N004B:

100"

2-E21-N004A:

93"

2-E21-N004B:

156"

The inspector found the 3/4" instrument line to 2-E21-PSH-N007A not clamped

to two unistruts.

The licensee had previously identified a similar

condition during the blanket walkdown of Unit 1.

The blanket walkdown of

Unit 2, scheduled to start during the current operating cycle, most likely

would have identified the missing unistrut clamps. The inspector also found

that the Service Water (SW) valve solenoid valves to the CS room cooler for

both Units were not mounted properly.

The licensee reported to the

inspector the solenoid valves de-energize when core spray initiates, opening

the SW supply to the room coolers. The screws that fastened the solenoid

valve to a mounting bracket on the main valve body were missing on three of

four coolers and only one screw was in place for the remaining solenoid.

The licensee reported that a safety concern did not exist since, on loss of

air, the SW valves would open, supplying water to the room coolers.

The inspector found scaffolding erected near the Unit 1 CS F0048 and F0058

valves and the Unit 2 F004A and F0058 valves.

The scaffolding was

constructed of fire retardant wood. However, no work was being done near

those valves and the Unit 1 outage had been completed 200 days ago. The

licensee issued work requests to remove the scaffolding.

No violations or deviations were identified.

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1

10. TIP Tubing Reversal

At about 4:00 p.m. on July 22, 1984, with Unit 2 at 100% power, the licensee

discovered that Traversing Incore Probe (TIP) tubes might have been reversed

on Unit 2.

The licensee reduced power, confirmed the swap through control

red movements and. requested the corporate Incore Analysis Unit to calculate

the effect on thermal limits. Further testing was performed to verify that

no other TIP tubes were reversed. A modification to the process computer

program was made to compensate for the swap. Unit 2 was returned to 100%

power on July 25, 1986.

The licensee discovered the TIP tube swap during a routine review of TIP

traces by the Nuclear Engineering Staff. The TIPS are used to calibrate the

Local Power Range Monitors (LPRM) which are in turn used by the process

computer to calculate margins to thermal limits.

There are four TIP

machines, each with its associated detector. Each machine's detector can be

selected to traverse eight or nine LPRM strings. Position ten is the common

channel such that each machine can traverse the same LPRM location (28-29)

to cross-calibrate the TIP machines. The TIP output is also sent to an X-Y

plotter to draw a trace on graph paper. During a review of the A-10, B-10,

C-10 and D-10 traces (common location) taken during the 00-1 calibration,

the licensee noted that the i 10 trace did not match the A-10, C-10 and D-10

trace low in the core.

The center rod, near the common channel, was

inserted to position 36. Further review showed that the B-8 flux shape did

resemble A-10, C-10 and 0-10.

Reactor power was reduced to 95% within one hour for added assurance that no

Technical Specification thermal limits were being exceeded. The margin to

critical power ratio was approximately 5% before the power reduction. Thus,

after power was reduced, about a 10% margin to thermal limits was available

to compensate for any errors in the LPRM calibrations. The licensee used

control rod motions with TIP traverses to verify that B-8 and B-10 were

swapped.

Power was reduced to about 75% power.

A TIP trace was taken

before and after a rod was moved near a TIP locations.

The Incore Analysis Unit of the corpora e Nuclear Fuel Section conducted

off-line analysis of cycle 7 data to verify that no thermal limits had been

exceeded. The BACKUP code was used.

Since B-8 and B-10 were swapped, the

normalization of the TIP machines and their associated LPRMs were affected.

Since actual local power B-3 was predominantly lower than actual B-10 local

power, the swap forced the normalization process to raise the associated

readings for the TIP 8 machine calibrated LPRMs.

This resulted in

conservative thermal limit calculations for fuel fear TIP B calibrated LPRMs

but non-conservative thermal limit calculations for fuel near TIP A, C, and

D calibrated LPRMs.

However, since the cross-calibration process is a

normalization process, the magnitude of the conservative error in the single

B machine is averaged over machines A,

C and D,

leading to a smaller

non-conservative error.

The licensee reviewed all cycle 7 data and found

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that during high power when thermal limits could be approached, the most

limiting location for thermal limits were being monitored by a TIP B

calibrated LPRM. Since TIP B gave conservative readings, no thermal limits

had been exceeded during cycle 7.

The inspectors reviewed selected licensee P1 printouts and core thermal

limit data (PT 1.11) to verify that the licensee's claims regarding power

history were supported by the data.

On July 23, 1986, Special Procedure SP-86-041 was written and performed to

verify that no other TIP tubes were swapped.

No additional problems were

found.

On July 24, 1986, the licensee modified the process computer program to

compensate for the B-8, B-10 swap.

The changes were made to the Digital

Fast Scan program and to the TIP driver software to swap B-8 and B-10

locations.

The licensee verified that the computer program modifications

are functional.

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On the afternoon of July 25, 1986, the licensee returned Unit 2 to 100%

power. The licensee had, at that- time, presented their cycle 7 thermal

limit review information to the resident inspectors.

The licensee . had

previously agreed in a letter dated July 23, 1986, not to exceed 95% without

Region II concurrence.

Based upon information given to the

residents,

Region II concurred in Unit 2 return to 100% power. However, the licensee

has agreed to review cycle 6 data for compliance with thermal limits and to

further investigate how and when the TIP was reversed. The NRC will review

the licensee's additional information when available for possible enforce-

ment actions.

Pending completion of the licensee's review, this is an

Unresolved Item: TIP Tube Reversal (324/86-18-04).

O