ML20207K403

Insp Repts 50-348/86-10 & 50-364/86-10 on 860411-0510 & 0603.Violations Noted:Electrical Breaker Open & Valve Remain Open & Fire Door Not Functional as Fire Barrier While Blocked in Open Position

ML20207K403
Person / Time
Site:	Farley
Issue date:	07/17/1986
From:	Brian Bonser, Bradford W, Dance H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207K319	List: ML20207K314 ML20207K382 ML20207K403
References
50-348-86-10, 50-364-86-10, IEIN-84-58, NUDOCS 8607290419
Download: ML20207K403 (15)

See also: IR 05000348/1986010

Text

UNITED STATES

.

[p tfit '

o NUCLEAR REGULATORY COMMISSION

[" n REGION ll

g'

,j 101 MARIETTA STREET, N.W.

ATLANTA, GEORGI A 30323

't

\,

.....

/

Report Nos.: 50-348/86-10 and 50-364/86-10

Licensee: Alabama Power Company

600 North 18th Street

Birmingham, AL 35291

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8

Facility name: Farley 1 and 2

Inspection Conducted: April 11 - May 10 and June 3, 1986

,

Inspection at Farley site near Dothan Alabama

Inspectors: ( A+ E 1 /Datb

/7/ Signed

4

W. H. BradfoM /

$ C $++ k~

~B.' R. BonterT '

' -

Y1k&

~/Datd Signed

Accompanying Inspectors: H. O. Christensen

S. D. Stadler

Approved by: -( A-4u

' H. C. Dancei Section Chief

7 /7 8/

Oate Signed

Division of Reactor Projects

SUMMARY

Scope: This routine and reactive inspection and enforcement conference included

onsite inspection in the areas of monthly surveillance observation, monthly

maintenance observation, operational safety verification, inoperable ECCS

subsystem, inoperable fire door, engineered safety system inspection, part 21

reports, and refueling activities.

Results: Two violations were identified: (1) Violation of Technical

Specification 3.5.2.d - exceeding limiting condition for operation. Paragraph 7.

(2) Violation of Technical Specification 3.7.12 -

inoperable fire barrier.

Paragraph 9.

8607290419 860717

PDR ADOCK 05000348

G PDR

-

-

.

REPORT DETAILS

1. Licensee Employees Contacted: -

J. D. Woodard, General Plant Manager

D. N. Morey, Assistant General Plant Manager

W. D. Shipman, Assistant General Plant Manager

R. D. Hill, Operations Superintendent

C. D. Nesbitt, Technical Superintendent

R. G. Berryhill, Systems Performance and Planning Superintendent

L. A. Ward, Maintenance Superintendent

L. W. Enfinger, Administrative Superintendent

J. E. Odom,. Operations Sector Supervisor

B. W. Vanlandingham, Operations Sector Supervisor

T. H. Esteve, Planning Supervisor

J. B. Hudspeth, Document Control Supervisor

L. K. Jones, Material Supervisor

R. H. Marlow, Technical Supervisor

L. M. Stinson, Plant Modification Supervisor

J. K. Osterholtz, Supervisor, Safety Audit Engineering Review

Other licensee employees contacted included technicians, operations

personnel, maintenance and I&C personnel, security force members, and office

personnel.

2. Exit Interview

The inspection scope and findings were summarized during management

interviews throughout the report period and on May 9, 1986, with the general

plant manager and selected members of his staff. The inspection findings

were discussed in detail. The licensee did not identify as proprietary any

material reviewed by the inspector during this inspection. Additionally the

violation for exceeding of a limiting condition of operations was the

subject of an enforcement conference on June 3,1986; refer to paragraph 14.

3. Licensee Action on Previous Enforcement Matters (92702)

This area was not inspected.

4. Monthly Surveillance Observation (61726)

The inspectors observed and reviewed Technical Specification (TS) required

surveillance testing and verified that testing was performed in accordance

with adequate procedures; that test instrumentation was calibrated; that

limiting conditions were met; that test results met acceptance criteria and

were reviewed by personnel other than the individual directing the test;

that any deficiencies identified during the testing were properly reviewed

and resolved by appropriate management personnel; and that personnel

conducting the tests were qualified. The inspector witnessed / reviewed

portions of the following test activities:

A

-

- -

.

,

2

STP-40.0 - Safety Injection with LOSP.

FNP-0-FHP -

Controlling Procedure for Unit 2 Refueling.

FP-ARP-R-4 -

J. M. Farley Nuclear Plant Unit 2 Cycle IV - V Refueling

Procedure.

STP-256.11 -

Reactor Trip Breaker Response Time Test.

STP-40.1 -

"A" Train LOSP Load Shed Test.

STP-9.0 -

RCS Leakage.

STP-7.0 - Quadrant Power Tilt Ratio.

STP-4.8 -

1 B Charging Pump Monthly Test.

STP-213.16 -

High Energy Line Break Sensor Test.

ETP-1014 -

Steam Generator Support Plate Flushing Procedure.

STP-80.2 - 1 C Diesel Generator Operability Test.

STP-7.0 -

Section 4.7 - Lowering the Refueling Cavity Level Using

RHR System.

SOP-1.3 - Reactor Coolant System Filling and Venting.

ETP-4193 - Reactor Vessel Head Modification.

STP-605.2 -

2 A Battery Test.

Unit 2 Local Leak Rate Testing.

STP-151.5 -

Main Turbine Overspeed Test.

MP-61.2 -

Reactor Coolant Pump Motor 5 Year Inspection.

STP-71.0 -

Main Control Room Remote Valve Verification.

STP-80.16 - Degraded Grid and Loss of Voltage Relay Operational

Test.

No violations or deviations were identified.

5. Monthly Maintenance Observation (62703)

Station maintenance activities of safety-related systems and components were

observed / reviewed to ascertain that they were conducted in accordance with

approved procedures, regulatory guides, industry codes and standards, and

were in conformance with Technical specifications.

The following items were considered during the review: limiting conditions

for operations were met while components or systems were removed from

service; approvals were obtained prior to initiating the work; activities

were accomplished using approved procedures and were inspected as appli-

cable; functional testing and/or calibrations were performed prior to

returning components or systems to service; quality control records were

maintained; activities were accomplished by qualified personnel; parts and

materials were properly certified; radiological controls were implemented;

c

..

.

3

and fire prevention controls were implemented. Work requests were reviewed

to determine the status of outstanding jobs to assure that priority was

assigned to safety-related equipment maintenance which may affect system

performance. The following maintenance activities were observed / reviewed:

- Unit 2 containment valves pipe plug change out (Part 21).

-

Unit 2 main steam isolation valves modification.

- Unit 2 A auxiliary feed pump inspection.

- Unit 2 FCV-122. ,

-

MP 28.173 - motor starters verification.

-

Unit 2 refueling.

- Unit 2 steam generator AVB modification.

- Unit 2 reactor vessel level measuring system.

- Unit 2 reactor coolant pump inspection and maintenance.

-

Steam generator eddy current testing.

- Unit 2 containment penetration modules modification.

-

Main control board modification.

-

Hydraulic and mechanical snubber testing.

No violation or deviations were identified.

6. Operational Safety Verification (71707)

The inspectors observed control room operations, reviewed applicable logs

and conducted discussions with control room operations during the report

period. The inspectors verified the operability of selected emergency

systems, reviewed tagout records, and verified proper return to service of

affected components. Tours of the auxiliary building, diesel building,

turbine building and service water structure were conducted to observe plant

equipment conditions, including fluid leaks and excessive vibrations. The

inspector verified compliance with selected Limiting Conditions for

Operations (LCO) and results of selected surveillance tests. The veri-

fications were accomplished by direct observation of monitoring

instrumentation, valve positions, switch positions, accessible hydraulic

snubbers, and review of completed logs, records, and chemistry results. The

licensee's compliance with LCO action statements were reviewed as events

occurred.

The inspectors routinely attended meetings with certain licensee management

and observed various shift turnovers between shift supervisor, shift foremen

and licensed operators. These meetings and discussions provided a daily

status of plant operations, maintenance, and testing activities in progress,

as well as discussions of significant problems.

The inspector verified by observation and interviews with security force

members that measures taken to assure the physical protection of the

.

.

4

facility met current requirements. Areas inspected included the organiza-

tion of the security force; the establishment and maintenance of gates,

doors, and isolation zones; that access control and badging were proper; and

procedures were followed. -

No violations or deviations were identified.

7. Inoperable ECCS Subsystem, Unit 1

On April 25, 1986 two electricians found a hold order tag on the Unit 2

electrical penetration room floor. The tag was taken to the Shift Foreman's

Office by the electricians and given to the Unit 1 Shift Foreman Inspecting

(SFI) who was assisting the Unit 2 SFI. Information was given to the SFI on

where the tag was found. A search of the tagging records determined that the

tag was from Unit 2 MOV 8811-B electrical breaker FV-85, (Unit 2 containment

sump suction valve to RHR pump 2B) and that the tagging order was still in

effect.

An extra SFI assigned to the shift to help carry out the Unit 2 refueling

outage work load took the hold tag and stated he would take care of getting

the tag replaced. He mistakenly went to breaker FV-85 in the Unit 1

electrical penetration room and noted that the breaker was closed instead of

open as required on the tagging order. He returned to the control room and

observed no indicating lights on Unit 2 8811-B hand switch on the control

board. The SFI returned to the Unit 1 electrical penetration room and,

assuming there was a problem with the Unit 2 MCB indicating light circuit,

opened the Unit 1 FV-B5 breaker and hung the hold tag. He did not recognize

that he had gone to the wrong unit. The Unit 2 SFI was then informed that

the breaker was open and the tag had been hung. The Shift Supervisor was not

notified and was not aware of the tagging problem.

This rendered the "B" train containment sump suction to IB residual heat

removal (RHR) pump inoperable at approximately 10:00 a.m. on April 25, 1986.

This condition was not found and corrected until 9:45 a.m. on April 29,

1986; a period of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. The limiting condition for operation of 72

hours as defined in TS 3.5.2 was exceeded by approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.

MOV 8811-8 is controlled from the main control board and aligns the "B"

train RHR system suction to the containment sump for long term cooling of

the RCS after a LOCA. The valves will automatically open on a lo-lo level

in the RWST if a safety injection signal is present. This valve is a

encapsulate valve located in the RHR pump room and cannot be operated

manually at the valve. The electrical power supply to MOV 8811-B is fed from

electrical breaker FV-85 in the electrical penetration room. During certain

accident conditions the electrical penetration room is inaccessible due to

extremely high radiation. Therefore, with the electrical breaker open, the

valve would remain inoperable. This is a violation (348/86-10-01).

The resident inspectors verified that train "A" of the RHR recirculation

flow path from the containment sump to RHR pump 1 A was operable during this

period. Emergency electrical power was available at all times and MOV

8811-A was capable of performing its intended function.

1

/

v

f

. 1

,

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5

The violation above was perpetuated by various procedure violations of

Administrative Procedures (AP). These procedural violations are

incorporated as part of violation 348/86-10-01 as follows:

-

AP-14 " Safety Clearance and Tagging" Section 6.1.3.2 of AP-14 was not

followed in that the SFI is not authorized to execute' tagging orders.

-

Section 6.1.2.3 of AP-14 requires that the Unit Shif t Supervisor review

the tagging order and signify his review and approval . He will

determine if verification is necessary in accordance with Appendix 3 of

AP-52. The Shift Supervisor was not notified and was not aware of the

tagging problem.

-

The same degree of review, approval and verification as required in

AP-14 for new and additional tagging orders on systems important to

~

safety and requiring verification of line up was not carried out to

retag a breaker / component after the original tag had fallen off.

-

AP-16, " Conduct of Operations - Operations Group", Section 4.2 - Shift

Relief states that shift relief is to be a formal turnover. A Shift

Supervisor, Shift Foreman, Plant Operator, Systems ' Operator, or

Switchboard Operator is considered to be properly relieved when the

individual assigned to relieve him has been informed of the' status of

the plant, operations in progress, and any special instruction. It is

the responsibility of the relieving individual to adequately inform

himself of these items by reviewing logs and data sheets, discussing

operations with on-duty personnel, reading special' instructions and for

the Shift Supervisor and Plant Operator to walk dow, the area of

responsibility with the off going individual. ,

-

Appendix B of AP-16 requires that annunciators, indicators, switch

positions, position indicator lamps shall be observed for correctness

and off normal conditions and shall be discussed with .the off going

operator.

-

The shift relief control board walk down was not adequate in that 12

shift relief and board walk downs were performed without identifying

MOV 8811-B to be inoperable.

-

Sections 3.2.9.1 and 3.2.9.2 of AP-16 requires that all licensed

personnel on shift must be aware. of and responsible for the plant

status at all times and be particularly attentive to the instrumen-

tation and controls located within these areas at all times.

Surveillance of the control room operating board controls, switch indicating

lights and maintaining awareness of plant status by licensed personnel on

shif t was not adequate in that there was a failure to identify that MOV

8811-B was inoperable from 10:00 a.m. on April 25 to 9:45 a.m. until

April 29, 1986.

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6

8. A supplementary reactive inspection relating to the wrong unit event

detailed above was conducted by Regional personnel on May 5-7, 1986. The

primary objectives of this additional inspection effort were to ascertain

whether this was an isolated or repetitive event and to determine the

contributing causes. In the course of this inspection, the inspectors

reviewed applicable tagging orders, maintenance work requests, job

descriptions, radiati'on zone maps, plant equipment labeling, and Farley

Licensee Event Reports (LERs) and incident reports for 1985 and 1986. The

inspectors also interviewed staff personnel, reactor operator (RO) and

senior reactor operator (SRO) licensed operators and supervisors, and STAS,

and conducted a detailed walkthrough of the event with the Shift Foreman

Inspecting (SFI) who was primarily responsible for the error. The results

of this additional inspection effort indicated that the event was safety

significant, and that it was not totally isolated.

a. Safety Significance

A review of the applicable post-LOCA radiation zone map (EL.139'O

Revision 2) indicated that the electrical penetration room in which the

breaker for MOV 8811-B is located is designated a post-LOCA radiation

zone VIII (greater than 50,000 R/hr) and would be inaccessible under

Following a design basis LOCA, the

.

design basis accident conditions.

,

reactor water storage tank (RWST) inventory would be depleted in

approximately one-half hour, and the operators would be procedurally

required to manually transfer RHR suction to the recirculation mode

with RHR suction from the containment sump. Since the Unit 1B RHR

containment suction valve's MOV breaker was erroneously tagged in the

open position, the Motor Control Center (MCC) that contains the breaker

and the MOV would both be inaccessible during the accident. Therefore,

train 8 of RHR would be incapable of taking a suction from the

containment sump (recirculation mode) in the event of a design basis

LOCA on Unit 1. If a coincident single failure of the redundant RHR

train or its associated EDG is assumed, no RHR, safety injection or

containment spray system flow would have been available to mitigate the

accident after the RWST emptied.

b. Event Background

The STAS at Farley are co-titled SFIs and are utilized during non-event

conditions as protective tagging planners. They are not authorized by

procedures to actually place protective tags, nor to manipulate valves

or breakers for tagging purposes. In addition, plant procedures

require that the Shif t Supervisor (SS) review all tagging orders

involving equipment under the control of Operations prior to

implementation. The SFI involved in this event violated these

procedural controls in placing a tag, operating a breaker, and in not

obtaining SS review and approval. An interview and detailed event

.

7

walkthrough with this individual indicated that he was unsure of why he

deviated from these procedures, or why he twice went to the wrong unit,

Unit 1, while attempting to replace a tag associated with Unit 2, which

was shutdown. The indications were, however, that he believed

something was wrong at the time, but was reluctant to consult the SS.

At one point during the event, he and another SFI involved contacted

the R0 on Unit 2 to change the control room indicating lights for this

MOV 8811-B. Since he had observed the breaker to be closed, he did not

understand the absence of an indicating light (the breaker observed was

on Unit I which was operating). Apparently, the Unit 2 R0 did not

question why the SFI expected an indicating light on a tagged-out and

deenergized position indication.

The other SFI involved indicated that he was aware that this SFI had

opened a breaker and placed a tag and also believed something was

wrong. He too was reluctant to consult the SRO and decided instead, to

rely on the more senior SFI's judgement. This sequence of events

indicates a reluctance on the part of three individuals to communicate

or to seek SR0 advice even when a problem is suspected.

c. Similar Events

A review of the Farley LERs and incident reports for 1985 and 1986

indicated a significant number of events involving work on the wrong

unit or wrong train, or safety related tagging or work order errors.

Several examples included the following:

-

Both trains of the control room emergency air cleanup system

inoperable due to I&C technicians working on the wrong train (LER

85-11/IR 85-129). The contributing causes listed included that

the I&C technicians were not familiar with the system, the

maintenance work request was not properly completed by operations

and the equipment labeling was not adequate. The technicians

involved were counseled.

-

On three separate occasions, health physics (HP) technicians

valved out the wrong containment radiation monitors for

maintenance orders (IR's 1-85-016 and 86-013 and 86-050). On one

of these occasions, the operators failed to investigate or report

a substantial decrease (6000 CPM to 1500 CPM) in readings they

logged on the monitors which were supposed to be in service. Each

of these valving / tagging errors by HP technicians was treated as

an isolated event and only the individuals involved were

counseled.

-

An operator removing tags to restore a system to service misread a

breaker label and thus could not locate a tag to be removed

(IR 2-85-074). He did not report the missing tag, and initialed

the work order that he had removed the tag. On discovery of the

tag inadvertently left hanging on the correct breaker, the SFI/STA

removed the tag which is not authorized by procedures.

. .

,

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8

-

On other occasions, tagging or work order errors by operators

and/or technicians resulted in potential or actual radiation

releases to the environment (IR's 1-85-007, 1-86-011, 2-86-054).

Twice in one day, these errors resulted in inadvertent release of

5000 mrem of gas with technicians in the immediate area.

-

On at least four occasions, errors by electricians resulted in the

deenergization of, or work on, the wrong equipment (IR's 1-85-098,

1-85-13, 1-85-504, 2-85-226). In one case, the electrician

inadvertently tripped the IB battery charger output breaker which

causes a IB battery fault alarm. Operator followup of the alarm-

included several deficiencies:

-

Apparently, the operator who acknowledged the alarm did not

investigate or report it.

-

The operators did not walk down this section of the control

,

board during shift turnover and did not notice the alarm.

-

The operator did not investigate a 45 amp drop in the battery

readings logged.

-

On at least three occasions EDG support system isolation valves

were found out of the required position necessary to support EDG

operation (IR's85-492, 85-417, and 2-85-244). In one of these

events the operations group had apparently failed to conduct the

return to service checklist following a five year outage inspection

on an EDG.

-

RHR Loop B suction valve 8702A failed to reopen after stroke

testing (IR 2-85-091). The subsequent investigation revealed a

series of errors:

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The electricians did not complete the work request for

PCN 2663 in reterminating all wiring and signed the work

request complete.

-

The electrical foreman signed the work request complete but

did not verify the work.

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An engineer inspected the work but did not remove the wiring

cover plate to actually check the wiring as indicated by his

signature on the work request.

-

The SFI and the Shif t Supervisor functionally accepted the

work request based on a plant operator indicating that the MOV

had been satisfactorily stroke tested.

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,

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-

The operator was in error in indicating that the MOV had been

satisfactorily stroke tested in that the stroke timing he was

utilizing, had been performed the day before the work was

completed. -

The above reports included items that were treated as licensee identified

violations and consistent with the NRC enforcement guidance in 10 CFR

Part 2 Appendix C, no violations will be issued. However, it appears

that there is inadequate trending of these incident reports involving

wrong unit / wrong train events, wrong equipment or tagging errors. Most

of the reports reviewed in this area indicated that the licensee

focused narrowly on each event, treating each as an isolated case and

counseling only the individuals involved. Increased trending of these

incident reports could identify repetitive and programmatic problems.

These internal reports are periodically audited and evaluated by the

resident inspectors.

d. Response to IE Notice 84-58, Inadvertent Defeat of Safety Function

Covered by Human Error Involving Wrong Unit / Wrong Train Events

The licensee's internal response to IE Notice 84-58 has not been

completed after two years. The draft response, however, indicates that

no action is required and that adequate controls are already in

existence to prevent wrong unit / wrong train events at Farley. One of

the controls cited as an example is that separate keys are utilized for

access doors to each of the two units which should prevent personnel

from entering the wrong unit. Since a large number of people including

Shift Supervisors, SFIs, and licensed and non-licensed operators carry

" master" keys which provide access to either unit, the separate key

concept does not appear to be effective in controlling wrong unit / wrong

train events. In addition, the numerous wrong unit / wrong train and

wrong equipment errors committed by HP, I&C, and electrical technicians

raised a concern whether this key control is effective at all, and more

importantly, whether the licensee's response to IE Notice 84-58

requires reconsideration.

e. Contributing Causes

The following appeared to be contributing causes to the recent RHR

wrong unit tagging error, as well as other wrong unit / wrong train,

wrong equipment and tagging, and work order errors that have occurred

at Farley in 1985 and 1986:

-

A lack of unit specific labeling on breaker cabinets supplying

safety related equipment. Most breaker labels are identical for

both units, with the exception of those associated with pumps

which may contain the pump designation such as 1A or 28.

Administrative procedures require that all plant valves contain a

tag with a unique identifying number that includes the unit

number, but this requirement is not applied to breakers.

.

10

-

A total lack of numbering and/or color coding on Unit 1 and Unit 2

access doors including the main entrance to each unit. The two

units are not in separate buildings, and individuals interviewed

indicated that they had, on several previous occasions, found

themselves in the wrong unit while performing evaluations or

tagging. The yellow and green color coding associated with Unit 1

and Unit 2 work orders and procedures, or a numerical designation,

or a combination of these could reduce the potential for full time

employees or contractors to enter the wrong unit.

-

Protective tagging performed by " designated operators" such as

health physics technicians and electricians without adequate

training and familiarity with systems and tagging procedures.

Multiple and repetitive tagging errors involving wrong train by HP

technicians were attributed to a lack of familiarity with the

systems and to being new on the job. On numerous occasions,

electricians and I&C technicians made tagging errors or began work

on the wrong equipment resulting in both trains out of service or

inadvertent trips or ESF initiations.

-

A lack of specific information on protective tags. The plastic

protective tags contain only a serial number and are used,

repeatidly, on different work orders. The tags are selected

randomly from a drawer with no requirement to assign a block of

consecutive serial numbers to a single work order. Many utilities

utilize a protective tag only one time, destroying it after the

work is complete, and including specific information on each tag

including:

-

The work order number - This information uniquely relates a

given tag to a work order. This can expedite the restoration

of protective tags which fall off or the removal of

out-of-date tags left hanging which can interfere with

operations or testing evaluations.

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The specific component tagged - The name and number of a

component tagged can help ensure that the correct component

on the right unit and train is tagged. This information can

also greatly expedite the restoration of a protective tag

that falls off.

-

The date the tag was placed - This information can help

ensure that a tag which has been erroneously left hanging

following restoration of the equipment is found and removed

on a timely basis through routine plant inspections or

audits.

-

The name/ signature of the person hanging the tag - Signing

each protective tag tends to impart an added sense of

responsibility for each tag placed. This information can

also expedite obtaining permission to remove a tag

inadvertently left hanging to support emergency operations or

test.

_

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l

11  ;

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Adequate reference to work requests - A number of the incident

reports reviewed indicated that inadequate information on the

maintenance work requests (MWRs) was a contributing cause.

Examples involved failing to designate the train to be worked on

or the status of the unit. For one event, the MWR for a job in

progress could not be located and the electricians wanted to

remove an ' installed jumper. This jumper was on the "A"

containment sump pump. Instead of locating the correct MWR, the

operators reviewed the tagging book and determined that the "B"

sump pump had been tagged out and assumed this was the correct

work order. When the electricians proceeded to remove the jumper

from the "A" pump, which was energized, an individual received an

electric shock requiring a trip to the hospital. If the correct

MWR had been utilized, this injury and wrong train error could

have been avoided. It also could have been avoided if adequate

information regarding the MWR number and equipment tagged had been

on the tags hung on the "B" sump pump.

f. Shift and Relief Turnover Procedures

Action Item I.C.2 of NUREG-0737 required all plants to review

procedures for shift and relief turnover to ensure that the oncoming

shift is aware of critical plant status information and system

availability. In the licensee's procedure, FWP-0-AP-16, " Conduct of

Operation - Operations Group, Appendix B," instructions are provided

for shift relief. The plant Operator Shift Relief Instruction;

specifically list valves which the licensee considers are "iaportant

enough to require increased visibility and attention." The containment

sump suction valves (MOV 8811-A & B) were not listed. Thus, the ,

operators failed to notice that there were no indicating lights

illuminated for MOV 8811-B for four days through 12 shift turnovers.

FNP-0-AP-16 also requires that the control boards be walked down each

shift change and specify that the indicating lights should be checked.

Interviews with operations personnel indicated that they would probably

not have looked at these lights during shift turnover control board

walkdowns. Their walkdowns emphasized abnormal valve alignments, work

in progress, and those indicating lights associated with ECCS systems.

The open breaker for the MOV should have been detected during the first

shift change following the event. When this event is considered with

the previously noted failure to respond to a safety related battery

charger alarm on shift change, and failures to investigate and report

significant changes in logged parameters, it is indicative of a lack of

attention and a programmatic problem.

9. Inoperable Fire Door

On April 29, 1986 at 9:20 a.m., the inspector observed Fire Door 2406, " Hot

Machine Shop", located in the Unit 1 and Unit 2 auxiliary building was

unable to be closed due to a rubber hose blocking the door opening. Fire

door 2406 is located on the Unit 2 side of the Hot Machine Shop on elevation

155 ft. in the auxiliary building and is a part of the fire boundary for

-- .

- _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ -

0

12

that area. There was no fire watch posted nor was an hourly fire patrol

established as required by TS 3.7.12. Fire door 2406 was not functional as

a fire barrier while blocked in the open position. This is a violation

(50-364/10-01). ,

i

10. Engineered Safety Systems Inspection (71710)

The inspectors performed various system inspections during the inspection

period. Overall plant conditions were assessed with particular attention to

equipment condition, radiological controls, security, safety, adherence to

technical specification requirements, systems valve alignment, and locked

valve verification. Major components were checked for leakage and any

general conditions that would degrade performance or prevent fulfillment of

,

functional requirements. The inspectors verified that approved procedures

l and up-to-date drawings were used.

Portions of the following systems were observed for proper operation, valve

alignment and valve verification:

I Auxiliary Feedwater Systems

Chemical Volume Control Systems

Service Water Systems

Boric Acid Transfer System

Containment Spray System Including Chemical Additive System

Residual Heat Removal System

The inspector performed a system inspection of the diesel generators. This

inspection included the engine starting air system, engine Jacket cooling

water system, service water system alignment in the diesel generator

building, diesel generator building fire protection and detection system,

diesel generator building ventilation system, electrical switch gear

alignment, annunciator response procedures, operating procedures, operator

logs and housekeeping.

The systems were assessed to be operable in accordance with the Technical

Specifications, appropriate drawings, procedures, and the Final Safety

Analysis Report.

No violations or deviations were identified.

11. Reactor Vessel Level Monitoring System

Reactor Vessel Level Monitoring System (PCN85-3195) work was observed in

Unit 2 containment building and the final documentation package was

reviewed. As a result of the documentation review the inspector had

questions concerning the quality control of the reactor vessel head

modifications (FNP-2-ETP 4193). Important quality assurance documentation

appeared to be missing from the final PCN documentation package. The

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licensee immediately requested and promptly received the QA documentation

from the vendor (Westinghouse) and provided it to the inspector. Documen-

tation reviewed and found satisfactory, consisted of: NDE Reports, Welder

Qualifications, Quality Releases for parts installed, Calibration Records,

Personnel Qualifications, Weld Procedure Qualification, and Tool Shipping

lists.

The inspector had no further questions.

12. Part 21 Reports Evaluation

The inspectors reviewed 10 CFR 21 evaluations of the following notifications

which had been received by the licensee. These were reviewed to determine

that an adequate review had been conducted by the licensee, to determine

that the Part 21 reports were applicable to the facility, and to determine

the actions taken by the licensee were adequate.

a. Emergency Diesel Generator Fuel Injection Pump Delivery Valve Holder.

This item is dispositioned and documented by a licensee letter to file

dated January 28, 1985.

b. Diesel Generator Failure at Calvert Cliffs Nuclear Station and IE

Notice 85-08. This item is dispositioned and documented by a licensee

letter to file dated April 30, 1986.

c. Containment Building Purge Valve. This item is dispositioned and

documented by a licensee letter to file dated April 30, 1986.

d. Temperature Compensation Error: Barton Transmitter. This item is

dispositioned and documented by a licensee letter to file dated May 1,

1986.

The inspectors had no further questions.

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13. Refueling Activities (60710)

The inspectors witnessed refueling activities of Farley Unit 2. The

inspectors observed these activities from the control room, reactor building

and spent fuel pool to verify that activities were being accomplished in

accordance with TS, license conditions, and NRC requirements.

The inspectors observed the defueling and refueling to verify the following:

a. Direct communication was established between the control room and

reactor building.

b. Staffing requirements were in accordance with TS.

c. Control of personnel access to the spent fuel pool areas was

established.

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d. Changes to procedures were made in accordance with administrative

procedures.

e. The licensee maintained good housekeeping in the refueling areas.

f. Radiological controls were maintained in accordance with approved

procedures.

g. Appropriate procedure steps and QA hold points were signed off.

No violation or deviations were identified.

14. Enforcement Conference

On June 3, 1986, R. P. Mcdonald, Senior Vice President, Alabama Power

Company and members of his staff met with J. Nelson Grace, Regional

Administrator and other members of the Region II staff to discuss the

inoperability of the flow path of one train of the system from the

containment sump.

During the discussion, the licensee addressed the management and technical

issues related to the inoperability of one train of the RHR system. The

licensee acknowledged the errors made by the SFI and the shift turnover

groups. The licensee categorized this event as an isolated incident.

Additionally, it was stated that using realistic assumptions on core gap and

resultant dose rates, the RHR suction valve's MOV breaker would be accessible

following a LOCA. A realistic estimate of personnel exposure to perform

this task would be on the order of 200 mrem. The licensee discussed the

corrective actions being taken to resolve the deficiencies and prevent their

recurrence. Management Procedure No. 400-004 had been revised to establish

a formal trending program that would monitor safety systems when they .are

rendered partially or totally inoperable. Attendees at the enforcement <

conference are listed below:

Licensee Attendees

R. P. Mcdonald, Senior Vice President

W. G. Hairston III, General Manager

J. D. Woodard, General Plant Manager

R. D. Hill, Operations Manager ,

B. D. McKinney Jr., Supervisor Licensing

)