ML20207D037

Insp Rept 50-416/86-17 on 860520-0612.Violation Noted: Failure to Have Procedural Controls Requiring Personnel Revising Procedures Affecting Safety to Make Determination Re Unreviewed Safety Question

ML20207D037
Person / Time
Site:	Grand Gulf
Issue date:	06/24/1986
From:	Butcher R, Caldwell J, Dance H, Modenos L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207D014	List: ML20207D009 ML20207D018 ML20207D037
References
50-416-86-17, GL-86-01, GL-86-1, IEB-81-03, IEB-81-3, IEB-81-36, IEB-82-16, IEB-82-26, IEB-84-64, NUDOCS 8607220007
Download: ML20207D037 (10)

See also: IR 05000416/1986017

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UN[TG3 STATES

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Report No.: .50-416/86-17

Licensee: . Mississippi Power And Lf hb 3 Company

Jackson, MS 2920*,

Docket "o.: 50-416 Licen:e No.: NPP 29

Facility Name: Grand Gulf 1

Inspection Con ucted: 'May 20. 1986 throgijh June 12, 1986

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[. C. Datcher, Senio.c ilesidant Inspector Cate Signed ~

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R. C. Dance, Section Chief Dice igned

Division of Reactor Projects

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SUMMARY

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Scope: This routine inspection was co? ducted by the resident arid regional

inspectors at the site in the areas of Licensee .Sction on Previcus fnforcament

Matters, Operational Safety Verification, Maintenance Observation, surveillance

Observation, ESF System Walkdown, Reportable Occurreces, Operating Reactor

Events, Inspector Followup and Unresolved Items, and IE Bulletin, Confirmatory  ;

Action Letter and Generic Letter Followup.

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Results: One violation - Failure to have procedural controit requirthg parsorinel

revising procedures which affect nuclear safety to make a detere;ination that an '

unreviewed safety question is or is not involved.

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8607220007 860703 ,

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AEPORT DETAILS

1. Licensae Employees Contacted -

J. E. Crnes, GGNS Site Director

• C. R. Hutchinson, GGNS Gene.a: Manager

• R. F Foger s, Tschnical Assittant

• J. Q. Bailey, Compliance Coordinator

• M. J. Wright, Manager, Plant Operations

• L. F. Daughtery, Compliance Superintendent

D. G. Cupstid, Start-up Stpervisor

R. H. ,McAnulty, Electrical Surerintendent

n. V. Koomaw, Manager, Plant Ma'intenance

W. P. Harris, C8mpliance Coordi nator

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• J. [.. Robertson Operations Superintendent

' .. O, Terople, I&C Superintendent

J, H. Mueller, Kachanical Superintendent

• S. F. Ttnner, Manager, Nuclear Site QA

• J. P. Czatka, SMEPA

• V A. Russr11, Operations Ess(stant

• P. S. Ccllins, Bechtel QA

Other licensee employees contacted included technicians, operators, security

force (lembers, aad office personnel,

"Attanded exit interview.

2 Exit Interyiet<

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'fhe inspection scope and find 1ngs were sumnarf zed on June 12, 1986 with

those persons indicated in caragrr.ph 1 above. The licensee did not identify -

as prop.-f etary ay/ of the materials provided to or reviewed by the

inspectors during this inspection. The licensca had no comment on the

follo.<ing inspection findings:

a. 41C/86-17-01 Inspector Followup Item. Program to ensure local valve

posftion indicEtion is avcilable (paragraph 4.a.)

6. 416/86-17-02, Inspector Fol)owup Item. Potential valve misalignment

during shutdown cooling cperation (paragraph A.b.)

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c. 416/86-17-03, Vfol.ation. Failure to have procedural controls requiring

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personnel ravis109 pre edures which affect nuclear safety to make a

determinatior, that an unreviewed safety question s or is not involved

(paragr.3ph 4. c. ')

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d. 416/86-17-04, Inspector Followup Item. Minor discrepancies noted

during containment spray system walkdown (paragraph 7)

e. 416/86-17-05, Inspector Followup Item. SGTS fire detection circuitry

interface with exhaust fan control (paragraph 9)

3. Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 416/86-03-01, Failure to train decontamination workers.

The licensee has changed Administrative Procedure 01-S-04-25, Decontamina-

tion Training Program, clarifying the requirements for decontamination

training. This procedure now allows personnel who have not received

decontamination training to perform decontamination activities as long as

they are under the direct supervision of health physics personnel or

labor / decontamination supervisory personnel who have attended the

decontamination training program.

(Closed) Violation 416/86-04-01, Failure of electricians to properly

follow / implement a surveillance procedure, and failure to properly perform

independent verification. The inspectors have reviewed the licensee's

corrective actions and found them adequate. Personnel involved with both

examples of violation 86-04-01 are removed from independent verification

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duties or have been counseled on the importance of proper performance of

independent verification.

(Closed) Violation 416/85-33-04, Failure to submit an LER within 30 days.

Through discussions with licensee personnel the inspectors have determined

that the licensee understands the requirements for reporting LERs within 30

days of the discovery of the reportable event. Since the identification of

the failure to meet the 30 day criteria the inspectors have not identified

any further examples of this violation.

(Closed) Violation 416/85-33-05, Failure to leak test containment and

drywell air lock test flanges. The inspectors reviewed the licensee's

change to Surveillance Procedure 06-ME-1M61-V-001, Local Leak Rate Test,

which now require leak checks of the drywell and containment air lock test

flanges and found the change acceptable.

( (Closed) Violation 416/85-28-02, Failure to document entering an LCO. The

licensee has issued a Technical Specification Position Statement (TSPS) and

reinstructed operations personnel emphasizing the requirement to declare

High Pressure Core Spray (HPCS) inoperable anytime the suction valve is

manually realigned to the condensate storage tank when a high level exists

in the suppression pool.

(Closed) Deviation 416/84-11-05, Failure to test the remote shutdown panel

(RSP) instrumentation and controls. The licensee has issued Surveillance

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Procedure 06-0P-1C61-R-0002, which test the RSP instrumentation and controls

to be in compliance with the Final Safety and Analysis Report (FSAR) and

Technical Specification (TS) requirements.

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4. Operational Safety Verification (71707)

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

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

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

plant operating staff.

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

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

instrument readings, setpoints and recordings status of operating systems,

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

adherence to limiting conditiens 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, selected ESF systems were 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 verifica-

tions; 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.

The following comments were noted:

a. The inspectors questioned the licensee regarding the adequacy of local

valve position indication which would allow the operator to accurately

, determine valve positions in the field. The licensee has initiated a

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program designed to ensure local valve position indication is available

where necessary. Additionally, additional retest requirements to check

the local indication is functional following maintenance will be

required. The licensee has targeted completion of this program to the

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end of refueling outage number 1 which is due to start September 1,

1986. This will be Inspector Followup Item 416/86-17-01.

l b. A potential generic memorandum regarding BWR valve misalignment during

l shutdown cooling operation resulting in inadvertent reductions in

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reactor vessel inventory was sent to each affected Resident Inspector

j for review for applicability at their site. The inspectors review

i indicates that the potential generic problems noted exist at the Grand

Gulf Nuclear Station (GGNS) also. The problems noted were as follows:

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(1) Residual Heat Removal (RHR) system isolation by RHR shutdown

cooling valves E12-F008 and E12-F009 (valve group 3) is initiated

by low reactor vessel water level (+11.4 inches) but TS table

3.3.2-1 only requires the isolation instrumentation to be operable

in operational conditions 1,2 end 3. In the inspector's judge-

ment, the TS should require the noted instrumentation be operable

in operational conditions 4 and 5 (cold shutdown and refueling)

also. There is no TS required isolation on excessive flow in the

shutdown cooling suction line.

(2) The RHR system in shutdown (S/D) cooling mode has an interlock

such that the suppression pool suction valve E12F004 cannot be

opened if the S/D cooling suction valve E12F006 is open. However,

if E12F006 is open, there is no interlock to prevent E12F004 from

being open. The operability of the interlock is not addressed by

TS.

(3) TS do refer to operations with potential for draining the

reactor vessel (OPDRV) in certain action statements but there

is no definition of OPDRV in the TS.

The inspector discussed the items noted above with the licensee and

requested the licensee take appropriate corrective actions to prevent

inadvertent reactor vessel draining. The licensee committed to the

following:

(1) The licensee is reviewing the potential impact on operations if

TSs were expanded to require isolation instrumentation be operable

in operational conditions 4 and 5.

(2) A Design Change Request (DCR 86-085) has been initiated by the

licensee to provide an interlock such that if the shutdown cooling

suction valve (E12F006) is open, the suppression suction valve

(E12F004) could not be opened.

(3) The licensee has issued a TSPS to define OPDRV. This statement

states:

(a) Any process which involves use of a temporary plug, i.e.,

freeze seal, plumbers plug, inflatable bladder, etc., to

isolate a portion of the primary coolant boundary, without

the use of a closed administratively controlled valve between

the temporary plug and the RPV.

(b) Any procedure or cperation which is used to drain the RPV,  ;

with the applicable RPV level isolations, for the system

being used, jumpered out or otherwise disabled.

(c) The removal of a control rod drive from the RPV, during any

period that a blind flange is not being used to blank the

open CRD housing.

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(d) Disassembly of any portion of the primary coolant boundary

where the open portion of the system is not isolated from the

RPV by at least one closed, administratively controlled

valve.

The above items will be followed by the residents as inspector followup

item 416/86-17-02.

c. When inspecting the chlorine storage facilities located in the Unit 2

area, it was noted that control procedures did not limit the total

number of 150 lb. cylinders permitted to be stored. FSAR Table 2.2-6,

Potentially Hazardous Chemicals Stored Onsite, limits the amount of

chlorine to ten cylinders of 150 lbs/ cylinder. The storage areas

designated in FSAR Figure 2.2-5 is outside the Unit 1 protected area

and is being controlled by Bechtel procedures as part of the Unit 2

construction project. The inspector reviewed the chlorine storage

logs and it appears the licensee never had more than nine 150 lb

cylinders of chlorine in storage at one time. The licensee has

revised procedure WP/P-14, Material Control, to specify the applicable

FSAR limit to ten 150 lb cylinders. The inspectors review of

revision 8 to WP/P-14 revealed that no review or approval by Unit 1

personnel is required and also no 10 CFR 50.59 review was accomplished

to determine that an unreviewed safety question did not exist. TS 6.5.3.1.f requires that technical review and control activities which

affect nuclear safety include a determination of whether or not an

unreviewed safety question is involved. The failure to have procedural

controls requiring personnel revising procedures which affect nuclear

safety to make a determination that an unreviewed safety question is

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or is not involved is a violation. This is identified as violation

j 416/86-17-03.

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! 5. Maintenance Observation (62703)

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

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

l 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 require-

ments, and adherence to the appropriate quality controls.

MWO I63328, Drywell Particulate Monitor Troubleshooting.

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MWO M63414, Replace Halon Bottle In Control Room Panel (LCO 86-625).

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07-S-12-9, Rev.2, Calibration Checks of G.E. Type 195 Center Zero Meter

Relays.

No violations or deviations were identified.

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6. ' Surveillance Testing Observation (61726)

The inspector observed the performance of portions of the surveillances  !

li sted . below. The observation included a review of the procedure for

technical adequacy, conformance to TSs, verification of test instrument

calibration, _observat. ion 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.

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06-0P-1T48-M-0001,Rev.26, Standby Gas Treatment Operability.

06-ME-1M61-V-0001,Rev.27, Local Leak Rate Test.

06-0P-1000-Q-0003,Rev. 24, Leakage Reduction Program - System Walkdown.

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06-EL-1R21-M-0001, Rev.22, 4.16 KV Degraded Voltage Functional Test &

Calibration.

f No violations or deviations were identified.

7. ESF System Waltdown (71710)

A' complete walr.down was conducted on the accessible portions of the

3 Containment Spray System (CSS). The walkdown consisted of an inspection and

verification, where possible, of the required system valve alignment,

including valve power available and valve locking, where required;

instrumentation valved in and functioning; electrical and instrumentation

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cabinets free from debris, loose materials, jumpers and evidence of rodents,

and system free from other degrading conditions. Containment spray is a

mode of operation of the RHR system consisting of two independent loops,

each loop consisting of one operable RHR pump and-an operable flow path

capable of recirculating water from the suppression pool thru an RHR heat

exchanger and the containment spray corayers.

The following discrepancies were noted:

-a. The updated Final Safety Analysis Report (UFSAR), paragraph 6.5 '.2,

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System Design, states the CSS will automatically initiate after 10

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minutes of a LOCA signal if containment ~ pressure exceeds 9 psig.

Emergency Procedure (EP) 05-S01-EP-3,Rev.17, Containment Control,

{ paragraph 3.1.4 note, states that containment spray should automati-

cally initiate at 7.84 psig containment pressure (after a 10.85 minute

! time delay) provided that 1.39 psig exists in the drywell.

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b. The UFSAR, paragraph 6.5.2.2 states that if containment pressure is

less than 9 psig, the control room operator will actuate the system

manually within 30 minutes to remove radioactive iodine in the

containment atmosphere. None of the emergency procedures direct

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operators to accomplish this task. EP 05-S-01-EP-1, paragraph 3.7.1

states that if EP-4 (Level Restoration) was entered due to vessel water

level being below the top of active fuel (TAF) or unknown, monitor the

Containment Post Accident High Range Area Radiation Monitors

(D21-RITS-K648 C&B, Panels P871 and P872). If both of these instru-

ments indicate greater then 100 Rem, and at least one RHR loop can be

made available (not needed for level control or suppression pool

cooling), then initiate Containment Spray with the available RHR loop

for containment iodine removal.

c. System Operating Instruction 04-1-01-E12-1, Rev. 33, Residual Heat

Removal System, attachment III, Electrical Lineup Checksheet lists

breaker 52-161115 on panel 16811 as required to be closed for motor

operated valve E12F394. Breaker 52-161115 is the control breaker for

valve P44F070. Breaker 52-161116 is the correct breaker for valve

E12F394. Although the component description and number do not match

the breaker number, the discrepancy was not picked up on the last valve

lineup.

The inspector considered the above findings minor and will follow the

licensee's corrective actions. This will be inspector followup item

416/86-17-04.

No violations or deviations were identified.

8. 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

adequacy of event descri1 tion ind corrective action taken or planned,

existence of potential generic problems and the relative safety significance

of each event. Additional in plant reviews and discussione with plant

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 Report (LER) is closed.

LER No. Event Date Event

85-038 September 25, 1985 ESF Actuation Due To A

Failed Inverter.

No violations or deviations were identified.

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9. 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.

On June 3,1986, the licensee determined that the fire detection circuitry

in the Standby Gas Treatment System (SGTS) for high charcoal filter

temperatures provides an alarm function and also shutdowns the SGTS exhaust

fan. Since the fire detection circuitry is not environmentally qualified, a

common mode failure of the charcoal bed temperature sensing circuitry during

accident conditions could make both SGTS filter trains inoperable through a

fan shutdown. The FSAR paragraph 6.5.3.2 states that in order to detect

any abnormal temperature rise at the outlet of the charcoal absorber, each

charcoal bed is provided with temperature sensors. At the first temperature

setpoint there is an alarm in the control room which alerts the operator

that an off-design temperature level exists. When the second setpoint is

reached another alarm sounds and the exhaust fan automatically shuts down.

Manual actuation of the deluge spray systems can be accomplished locally.

FSAR paragraph 7.3.1.1.8.3 states a fire detection signal from a charcoal

filter bed stops and isolates the charcoal filter train and fans, bypassing

a start signal from the SGTS control system. The licensee declared both

trains of the SGTS inoperable until a fire watch was established and the

fire detection panel power supply was tagged open. Subsequently, on June 4,

1986, a temporary alteration was installed which jumpered out the high

temperature in the charcoal filter train input to the SGTS exhaust fan

control and the fire panel alarm function was returned to normal operation.

A warning tag was installed on the SGTS exhaust fan control switch on the

870 panel warning the operators to manually turn the fan switch off if a

high-high temperature alarm was received. The licensee had previously

determined that the charcoal filter temperature circuitry did not require

environmental qualification per 10 CFR 50.49. During a second review to

veri fy applicability of systems / components to the requirements of

10 CFR 50.49, it was identified that the fire detection circuitry interfaced

with the SGTS exhaust fan circuitry which initiated the licensee's actions

noted above. The inspector will followup the licensee's actions to resolve

this discrepancy. This will be inspector followup item 416/86-17-05.

No violations or deviations were identified.

10. Inspector Followup And Unresolved Items (92701)

(Closed) Inspector Followup Item 416/85-33-01, Clarify TS to reflect valve

E12F023 function. TS 3.3.7.4 has been changed to delete valve E12F023,

RHR to RCIC Head Spray Line Valve, from Table 3.3.7.4-1 clarifying the

requirement for E12F023 operability on the RSP.

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(Closed) Unresolved Item 416/85-45-04, MSIV Accumulator Check Valves Not

Addressed in the IST Program. The licensee has determined that the MSIV

accumulator check valves met the criteria of ASME Section XI for being

exempt from the IST Program.

(Closed) Survey Of Licensee's Response To Selected Safety Issues (TI

2515/77). The inspector reviewed a selected sample of Safety issues. These

issues have been identified in IE bulletins, circulars, and information

notices and in the Institute of Nuclear Power Operations (INP0s) Significant

Operating Event Reports (SOERs). Two safety events were reviewed, the

reliability of Reactor Core Isolation Cooling (RCIC) and befouling of

cooling water heat exchanges.

The following documents and licensee responses were reviewed for the

reliability of the RCIC system.

IE Information Notice 81-36, 82-16,82-26 and 84-64.

NUREG - 0737

INP0 SOERs 81-13 and 82-14

The licensee had responded and had taken actions to improve the reliability

of the RCIC, however one item of concern was identified. There was no

formal maintenance trending conducted on the RCIC system and management

could not track and measure the effectiveness of the measures taken on a

routine basis.

Biofouling was addressed in IE bulletin 81-03 and the bulletin was closed in

IE Inspection Report 416/81-17. The significant operating event reports

addressed by INPO detit with open cycle service water systems. Grand Gulf

has a closed cooling water system which receives makeup from a series of

radial wells, therefore the information received from the industry

was not applicable to Grand Gulf.

No violations or deviations were identified.

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11. IE Bulletin, Confirmatory Action Letter and Generic Letter Followup (92703)

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IE Bulletin 86-01, Minimum Flow Logic Problems That Could Disable RHR Pumps.

The licensee reviewed the subject bulletin and determined that the noted

j problem does not exist at this facility. No further action is required.

This Bulletin is closed.

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