ML20207K403
| 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: |
| References | |
| 50-348-86-10, 50-364-86-10, IEIN-84-58, NUDOCS 8607290419 | |
| Download: ML20207K403 (15) | |
See also: IR 05000348/1986010
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION ll
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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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
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 /7
4
W. H. BradfoM
/
/Datb / Signed
$ C $++ k~
' - Y1k&
~B.' R. BonterT
~/Datd Signed
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Accompanying Inspectors: H. O. Christensen
S. D. Stadler
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7 /7 8/
Approved by:
' H. C. Dancei Section Chief
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
-
Paragraph 9.
8607290419 860717
ADOCK 05000348
G
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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
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,
.
-
-
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.
-
"A" Train LOSP Load Shed Test.
STP-40.1
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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.
-
Reactor Coolant Pump Motor 5 Year Inspection.
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Main Control Room Remote Valve Verification.
STP-71.0
-
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.
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- Unit 2 containment penetration modules modification.
Main control board modification.
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Hydraulic and mechanical snubber testing.
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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
/
f
v
1
.
,
.
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
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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
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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
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shift relief and board walk downs were performed without identifying
MOV 8811-B to be inoperable.
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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
.
design basis accident conditions.
Following a design basis LOCA, the
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.
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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.
.
.
,
.
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
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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.
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RHR Loop B suction valve 8702A failed to reopen after stroke
testing (IR 2-85-091). The subsequent investigation revealed a
series of errors:
The electricians did not complete the work request for
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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.
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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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9
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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.
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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.
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10
A total lack of numbering and/or color coding on Unit 1 and Unit 2
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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.
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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.
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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
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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.
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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.
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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.
_
1
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11
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).
,
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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.
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
)