IR 05000321/1987017

Insp Repts 50-321/87-17 & 50-366/87-17 on 870727-31.No Violations or Deviations Noted.Major Areas Inspected: Licensee Practices in Programmatic Areas Re Selected Events or Failed Components

ML20238A054
Person / Time
Site:	Hatch
Issue date:	08/27/1987
From:	Bernhard R, Isom J, Lefave W, Scott Sparks, Starkey R, Szczepaniec A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20238A030	List: IR 05000321/1987017 ML20238A028
References
50-321-87-17, 50-366-87-17, NUDOCS 8709090114
Download: ML20238A054 (22)

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e p Rfou UNITED STATES l

'o NUCLEAR REGULATORY COMMISslON

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REGION il 101 MARIETTA STREET, 'g ATLANT A, GEORGI A 30323

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Report Nos.: 50-321/87-17 and 50-366/87-17 Licensee: Georgis Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5 Facility Name: Hatch I and 2 Inspection Conducted: July 27-31, 1987 Team Leader: F. Jape Inspectors: M %ww A. J. Sz$zephnide

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P)?-P7 Date Signed

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R. H. Bernh&rd '

?- 2'l- V'l Dated Signed 0$T$l R. D. Starkey c27-87 Dated Signed 6bO w~ P 27 F '7 J. A. Isonf > J ' Dated Signed Wlb Awn m S- 29-h 9

,J. T. L(favh ' Dated Signed (x TErr b 27 -F7 S. E. SparHs Dated Signed Accompanying Personnel: A. R. Herdt (07/31/87)

Approved by: Mt / <@-

F. Jape, Section Chief g/ // Date Signed Division of Reactor Safety SUMMARY Scope: This special, announced inspection was conducted in accordance with TI 2515/83 " Balance of Plant Trial Inspection Program (Feedwater System) to assess the licensee's practices in programmatic areas associated with selected events or failed component Open items were inspected and a review of licensee action regarding scram discharge volume capability was also mad Results: No violations or deviations were identifie G709090114 870902 PDR ADOCK 05000321 0 PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• J. T..Beckam, Jr., Vice President, Plant Hatch

• H. C. Nix, Pir.nt Manager

• D. S. Read, Plant Support Manager

• S. J. Bethay, Nuclear Safety and Compliance Supervisor

• P. E. Fornel, Manager of Maintenance

• T. R. Powers, Engineering Support Manager

• S. B. Tipps, Nuclear Safety and Compliance Manager

• Z. Wahab, B0P Systems Engineering Superintendent Other licensee employees contacted included engineers, technicians operators, mechanics, and office personne NRC Resident Inspectors

• P. Holmes-Ray

• R. A. Musser

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• Attended exit interview Exit Interview The inspection scope and findings were summarized on July 31, 1987, with those' persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license The licensee did make an oral commitment to perform a necessary evaluation regarding scram discharge volume capability by September 1,1987. See Items 4.3 and 4.5 of paragraph 13 of this repor The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters This subject is discussed in paragraph 1 . Unresolved Items Unresolved items were not identified during this inspection.

l Selected Components and Events - Balance-of-Plant

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In accordance with- TI' 2515/83, the inspection team selected specific-events _ and components %g which to focus its inspection. The condensate" system.andi feedwater system were inspected due to Boiling Water Reactor design.' Based on the planteperating history, post-trip reports, Licensee

' Event Reports ~(LERs),. and discussions with plant personnel, the following components and LERs;were selected for inspection

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-- ' Condensate. pumps, LERs87-008 and'85-030- f

- Moisture Separator Reheaters, LERs86-009.-85-018, and 84-026  !

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-- - Flow Control Valve, LERiB6-012

, These components and. events"were . inspected in the programmatic areas of

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operations, design and modifications, maintenance, training and quality assurance,.:and management-support. Root cause analysis was reviewed as part of the management support' area. The results' of the inspection into

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each of the programmatic areas ~are listed. separatel A summary of observed strengths and weaknesses'is listed in paragraph 1 t ' Operational Aspects 1 a; lLER revie For the events surrounding the selected LERs, the plant' operators 1 responded . as appropriat Mcne of the .resulting scrans were '

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attributed 'to operator error.1. In each case, either an electrical, i mechanical, or instrumentation malfunction in a B0P component resulted in in reactor scram. Scram recovery for each event was routine in natur To assess each event, a scram critique meeting was held following the event. A11 ; operations perscnnel on shift at the tima of the scram and all appropriate- management attended this meeting) The purpose was to determine the need for . plant modifications or changes to operating procedures. One such modification suggested a logic change in the Moisture Separator-Reheater (MSR) level trip logic. The new logic required that two out of three level switches trip rather than the previous one out of one trip logic. Turbine trips resulting from MSR level switch malfunctions had been a recurring problem with the previous trip logi Before a LER writeup is completed, the event fineings are reviewed by the Operations. Man'ager. In addition, the root cause of the event is investigated by the Superintendent of Operations Support. The result is that the ' Operations Department has opportunity for input to the final LER documen Operator Information/ Feedback The inspector toured the Control Room with an Assistant Plant Operator (APO), a licensed reactor operator. Items reviewed were the Night Order Book, the On , Shift Operations Supervisor Log Book, and

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'the Pequired Reading Notebook. The purpose of the review was to seek out specific references to B0P' operations 'and LER related events. It appeared that B0P operations were receiving adequate attention in these document s To ensure that operations personnel are briefed on the details of each sc' ram, the On Shift Operations Supervisor' (OSOS) briefs his shift on. the events surrounding the scram, and lessons learned from an operations standpoin Each licensed operator receives monthly, a copy of the Operating Experience Assessment-Re Technical Advisor'(STA)staff.port The(OEAR),

OEAR contains which is prepared recent Plant Hatch by the Shif LERs . as well as operating experiences from other nuclear power plants. Plant modifications are also described in the OERA. It should be noted that all licensed operators are bained on plant modifications following each. planned outage and irior to assuming licensed responsibilities.

g The Training Department receives copies of all LERs which are then screened to determine possible arcas of training in the Licensed Operator Requalification Training Progra Although no ' formal guidelines presently exist which coordinate operator training needs andnths formalized training program, there are informal meetings between operations and training personnel to discuss training

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requirements.3: In this regard there appeared to be a very cooperative spirit betwesa the two department Concerning operator awareness following plant events , there is presently in draf t form an administrative guideline entitled " Event Investigation and Evaluation." This guideline would require that lessons learned from the event would be formulated and sent to the This is a positive Training Department by the Event Review Tea indication that operators will receive feedback from an even The effective date of this draft guideline has not been determine The inspector concluded that the licensee has an adequate program to disseminate event related information to all licensed operator Procedures and Reference Documents The inspector reviewed the following P & ids and technical manuals to ensure that they were current and easily accessible to the control room operator. These documents were available in the control room and OSOS office, P & ID H21037 Condensate and Feedwater System-Control Copy f dated May 4, 1987  ;

P & ID H21038 Condensate and Feedwater System-Control Copy

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F dated January 24, 1987

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GEK-38435 Steam Turbine Feed Pump Drive GEK-42234 Unit No. 2 Steam Turbine - Generator - Turbine Vol. IV. Rev. 2 Moisture separator / Reheater Section Also reviewed was the most recent Condensate and Feedwater System Electrical and Valve Lineup, Procedure Number 3450-N21-007-2S Attachments 1, 2, and 83, which was performed after the last Unit 2 planned outage on December 15, 198 This performance date was consistent with the frequency guidelines as stated in the procedur The inspector reviewed six Alarm Response Procedures (ARPs), listed below, which were directly related to the events in the selected LERs. They appeared to be current and adequat AR-650-160-25, Rev. 1, dated November 30, 1986, " Moist Separator High Level Trip" 34 AR-650-001-25 Rev.1, dated January 22, 1986, "MSR OR lst and 'nd Drain Tank Trouble" 34 AR-650-037-2, Rev. O, dated August 23, 1985, "4160V Station Service Feed Breaker Tripped" 34 AR-160-051-02, Rev. O, dated August 21, 1985, " Standby Condensate or Condensate Booster Pumps Pumping" 34 AR-650-082-2, Rev. O, dated August 21, 1985, "Cond. Booster Pumps Suction Low Pressure" 34 AR-650-151-2, Rev. O, dated August 21, 1985, "RFP Trip" ARPs are presently being rewritten as part of the Procedure Upgrade '

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Program (PUP) which is scheduled to be completed by the end of 198 Under 'the revised program each alarm panel in tho control room will have attached to it those ARPs pertaining to that panel. Currently, licensed operators must use a combination of the old and new ARP This transition period of ARP revision appeared to be working wel The new ARPs and this placement in the control room should greatly enhance their utilizatio The Emergency Operating Procedures were also examine In 1986, flow charts were placed into use which direct licensed operators on a step by step basis through the appropriate actions following a reactor scram. Any scram will r.ecessitate entry into the appropriate flow chart. Once the plant is in a stable condition, the flow chart will direct the operator to the correct End Path Manual and from there to the recovery path procedur i General Observations

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Operations Engineers review- the Plant Equipmenti Ope $ators(PE0)

, deJ1y rounds tsheets, monitoring trends in p?. ant 2quipment. As the eng4eering ataff is increased, a more intense effort is planned in the krea of trendin It is envisioned by the SuperMtendent of Operations Support that this trending will later h computerized, althodgh no timetable has yet been established. This trending should aid in pre 6'.cting potential problems with plant equipmen <

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Design and Modification Aspects An eva.luation ms made of the licensee's followup investigations and i

activit(es reltt'ing to the long-term corrective acticns with regard to

') design modifications as .they . applied to the selected components and the events listed in paragraph 5.

l The design change associated with LER 86-009 involved upgrading the single logic MSR level trip system with a two out of thrte logic. This design change not only addressed the root cause .of LER 86-009, which was a leaky valve depositing moisture into the level switch housing resulting in micro switch failure, but also addrecsed the root cause of the associated LERs where trips were apparently caused by spurious trips of the level switch with no evident failures. M fact this design change was requested as a result of LER 85-018, but was not implemented until after LER 86-00 There were no design changes associated with LER 87-00 The condensate pump developed a stator short to ground which resulted in a pump tri Since one condensate pump was already out of service for preventive maintenance, a loss of feedwater and plant trip resulted because the plant was at 97 percent power. The root cause of this event appeared to be a manufacturing defect. No design changes were instigated as a result of this LE LER 86-012 involved failure of a condensate flow control valve positioner which caused the valve to close, diverting all condensate flow through the steam jet air ejector condenser. Condensate flow to the booster pumps was thereby lost causing a loss of feedwater and eventual plant trip. The cause of the air operated posit %er failure appeared to be moisture in the air line, causing crud builoup in the system, which blocked the air from one side of the positioner, causing the valve to go closed. The entire pneumatic relay assembly (positioner) was replaced and the primary air inlet orifice was cleaned, making the valve operable. Major design changes to the compressed air system are scheduled over the next two years to reduce the moisture / contamination in the air system. Meanwhile accumulator blowdowns are done on a shiftly basis w prevent moisture buildu With respect to reduction of plant trips from B0P related equipment, the design change from a one out of one logic to a two out of three logic for the MSR level switches and the design change to the air system should prove effectiv . _ _ _ _ _ _ . -_ _. _ . . _ _ _ _ _ _ _ _ _ _

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This inspector was impressed with the level of attention afforded non-safety-related B0P equipment. The BOP engineering department appeared to have every good understanding of potential problems associated with BOP systems. Specifically, scheduling of design changes are planned well into

. the future and appear to include all aspect of B0P sys':m The only possible weakness associated with design related B0P problems may come about from the root cause analyses. This was observed from one recent event, and therefore, may not indicate a generic problem. A recent LER,87-024, was generated due to dirty relay contacts in the off-gas condenser level circuit, which prevented the drain valves from operin This resulted in a high level, which caused a back pressure on the air-ejectors, resulting in loss of vacuum and a turbine / plant trip. The LER noted that a similar problem had previously occurred involving the same relay documented in a related LER regarding the MSR level switch. The MSR level switch problem resulted in a design change as discussed above. The investigation report for LER 87-024 was performed by the operations department and concluded that other than cleaning the contacts, no further actions were required. Because the LFR referenced related LERs that implicated possible design changes which should have been discussed in the investigation report, the engineering department should be involved in this review process to assure concurrence with the disposition. Even if no design change is requested, the report should indicate what actions are required to prevent recurrence (i.e., periodic cleaning of applicable components).

Overall, for the events reviewed, when design changes are requested as a result of an LER, prompt and efficient follow-up generally occurs. When the design change affects the FSAR text or drawings, a 10 CFR 50.59 evaluation has been performed as required. Design changes involving nonsafety-related B0P equipment have been accomplished by the licensee with a concerted effort to use equipment of rsuivalent or better desig This is evidenced by the major effort to verib as-built conditions in the condenser area and the generation of blanket Design Change Requests (DCRs)

to allow replacement of valves with equivalent or bett.er design. These items plus those discussed above indicate that the licensee's attention to B0P systems is well directe !

The operating and maintenance i istories of the Hatch plants show an increased interest and focus on 80P systems in general. A review of the Units 1 and 2 outages between 1984 and the present showed that, of the ,

design changes performed during the outages, approximately 1/3 were 80P l'

related, with about one half of them either nonsafety-related or not initiated by NRC. During five outages, the nonsafety-related design changes numbered between 70 to 8 The proposed schedule for upcoming outages indicates an increase in the number of B0P design modifications, '

which occaisonally approach 50 percent of the total work per outag While some of the previous design modifications were minor in nature, some required considerable effor One of these major efforts is related to erosion / corrosion problems in the steam and feedwater system Although

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no significant erosion / corrosion at single phase flow locations was found, erosion / corrosion has been found in virtually all areas of two-phase flo Significant degradation has been identified in the Hatch 2 sixth stage extraction, Hatch 1 fifth stage extraction and main steam reheater (MSR)

drains downstream of the control valves for both units. Components with excessive degradation have been replaced and baseline data has been developed to forecast the expected life for all piping that could be affected. This baseline data suggest that a small percentage of piping will have to be replaced throughout the life of the plant. Georgia Power Company is investigating the need for and feasibility of moisture pre-separators in the high pressure turbine exhaust system to reduce erosion /

corrosion problems associated with the main turbine syste Other design changes recently implemented include:

Design improvements regarding relocation of controls related to feedwater punip seal injection pressure to prevent or reduce seal leakage during startup when seal pressure may vary considerably. The original pump manufacturer design had the controls mounted on the pump, which resulted in excessive vibratio Replacement of between 50-75 condenser valves that had been previously injected for leak repair. Thermal cycles generally cause new leaks after the injection proces This effort resulted in a reduction in steam leaks, helped to improve unit efficiency, reduced loads for the chiller systems and reduced area radioactivit A thorough walkdown of the Unit I condenser bay area to update prints to as-built conditions, conducted to improve the quality of work issued by Engineering. All support documents were updated, e.g. ,

Vendor Manuals and Equipment Location Index (ELI). This enables optage-related work packages to be prepared and the ordering of specific materials without having to wait to enter the condenser bay area during a shutdow Blanket DCRs written to allow replacement of existing problem valves without an exact replacement available with an equal or better valve that was available. This allows the problems to be fixed immediately instead of being deferre " Live load packing, accomplished in many B0P valves to reduce packing leaks. This results in higher efficiency, less load on chillers, lower radioactivity, and a reduced probability of equipment malfunction due to humidity / moisture associated problem Major modifications to the main condensers, including installation of baffles and gratings to reduce the potential for erosion of condenser tubes. Modifications to the turbine bypass spargers allowed repair

o of past damage and reduced the potential for future damage at high I

stress areas. These modifications resulted in significantly reducing I condenser tube erosion problem Seven tubes were plugged last l

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outage-versus an average of over a hundred previously. The reduced erosion ~ also resulted in improved water chemistry (reduced copper),

lowering the likelihood of fuel damage caused by copper / cladding interactio ~ The above modifications show a high awareness' of the problems associated

.with B0P systems and indicate a strong willingness and determination to reduce or, eliminate them. The efforts related to the condenser walkdown and blanket DCRs on valve replacement, and a similar effort regarding electrical breaker and- cable identification indicate that the licensee appears to have a goal of fixing problems as soon as possible after a occurrence rather than later. Deferring or delaying because of replace-inent part problems or erroneous drawing problems has been. minimize Although~ the licensee's. motivation for these goals may be economic in nature, an undeniable improvement in safety has to follow because of the higher system availability and the corresponding reduction of transient ' Maintenance Aspects The inspectors performed a walkdown of the Unit 2 Feedwater Heaters, the conoe. var bav area with its condensate and feed piping, the Startup Feedwater: Regulating Valves, the Unit 1 Condensate Pumps, the Unit 1 Condensate Booster Punps, and the Feedwater Pump The walkdown occurred during Unit 2 startu Several steam leaks were observed. EHC fluid was found pooling on the floor in the vicinity of the Bypass Valve Temporary funnels and tubing were attached to the feedwater pump and turbine to catch oil leaks. Other than these items, the walkdown did not find any unusual item A review was performed on the maintenance department's predictions of maintenance program. The program consisted of several predictive main-

- tenance techniques including lube oil analysis, vibration monitoring of operating equipment, infrared radiation monitoring for abnormalities, and historical trending of equipment failure to identify problem areas for engineering improvemen Each of these areas were examine " Preventive Maintenance Program", 50-AC-MNT-007-05, provides the administrative controls for. the progra The vibration monitoring program provides for periodic vibration readings on 340 pieces of equipment. The list of effected equipment was reviewe Equipment tested is safety and nonsafety-related, ranging from the RPS MG set: to drain sample pump Procedure 53PM-MON-001-05, " Vibration Monitoring of Rotating Machinery", covers the program and method for monitoring equipmant. An examination of the Condensate Pumps and conden- sate booster pumps showed monitoring points had " buttons" attached to the equipment to mark the points for the vibration probes to insure consistent readings. Vibration spectrum analysis is performed for the equipment and the results are trended. Case histories were reviewed for equipment that was repaired based upon program recommendations prior to failure, avoiding an unexpected plant outag _ -

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The oil analysis program is performed using 53PM-MON-002-05, " Lubrication Analysis." The procedure was reviewed and a printout of the 230 pieces of equipment monitored was examined. The equipment is both safety and non-safety-related. The results of the program are used for both predicting equipment problems and for justifying continued equipment operation past a major maintenance time interval. Early detection of problems avoids unexpected outages and improves plant reliabilit Infrared analysis at the plant issued to determine hot spots on equipmen This form of preventative maintenance is primarily a one time monitoring program and is not a regularly scheduled maintenance activity, such as the oil analysis and vibration program. Potential problems identified in i

past case histories could have led to BOP related plant shutdown.

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The inspector reviewed a program for trending past failure records of equipment using the plant Management Information System (MIS) Databas After a component is identified as a frequent offender, root cause analysis and engineering improvement are performed to reduce the number of failures. This system was used by the inspector to obtain the maintenance histories for both units Condensate Pumps, Condensate Booster Pumps, and Reactor Feed Pumps. Repeat work was noted for the Unit 1 Feed Pump 'B'

for the zero speed alarm indication and automatic start of the Turbine Turning Gear. This event was written up five times in a two year period and most recently in April of 1987. The Unit 2 "A" Feed Pump had four occurrences of not being able to be reset from the control room in a fifteen month period, most recently in February 1987. The item was not yet closed out. The Unit 2 "B" Feed Pump had the same case history. The program of tracking down the trends based upon maintenance history should provide input that will reduce the unexpected plant shutdown The MIS Database was also used to trtck the Maintenance Work Orders (MW0s)

related to the LERs tracked as part of this inspection. The inspector performed a history search of the 2h21-F007 valve relating to LER 86-01 The search showed a one year histor/ of trouble with the valve. A letter requesting a trend analysis has bee.1 written by the I and C Departmen A review of the I and C Department procedures and program was conducted, concentrating on the LERs. The program treats calibration of B0P equip-ment as it would safety-related equipment. The same procedures are used for equipment calibration of B0P as for safety-related equipment. The calibration procedure 57CP-CAL-012-25, "Magnetrol Level Switch Calibration", is used for the Scram Discharge Volume Level Hi input to the Reactor Protection System ard for the Moisture Separator Reheater level switche The only differentiation between B0P and safety-related equipment is some non-essential B0P instrumentation and systems having little impact on plant operations are calibrated on an infrequent basis or only as necessary. Reviews were conducted to insure all critical BOP instrumentation was included in the regular calibration program. This program insures non-essential instrumentation calibration requirements do not create a backlog that may impact the calibration progra _ _ - _ _ _ - _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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The Predictive Maintenance Program has the elements in it required for plant availability improvement. The savings in the program have already justified its cos In the long run, the effect should be to reduce challenges to the reactor system caused by preventable equipment failure . Quality Assurance (QA) and Training The following documents, including completed and draft QA audits, were reviewed as they pertain to the effectiveness of the QA department's review of the B0P area. Because the review was limited in scope, findings may not necessarily be indicative of a programmatic weakness nor should it be construed as a comprehensive assessment of the QA department and its program Detailed Audit Breakout QA General System Surveillance

• Surveillance Program Guidelines

" QA Audit of Maintenance, March 12, 1985 QA Audit of Maintenance, February 25, 1987 Draft report of QA Audit of the Root Cause, July 29, 1987 It appeared that, in general, the B0P area received as much attention from the QA organization as other systems or areas reviewed by the QA department. The detailed audit inspection plan and the General System Surveillance procedure used for walkdown of the systems were found to be a s trengt In addition, the recently completed audit of root cause analysis at the site was reviewed and found to be very comprehensive and thorough. The root cause audit expended some 230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br /> and identified significant weakness within the organization. However, in light of reactor trips experienced by the plant in 1985 and 1986, it is felt that additional audits may be helpful in the 80P are Review of the licensee's LERs indicated that five out of the six reactor It is trips in 1986 were caused by B0P equipment failure or malfunctio felt that an audit stressing equipment maintenance and repair and system operability and reliability would be beneficial in reducing the number of reactor trip It was observed that the licensee has performed audits in the maintenance area with some significant findings; however, no audits were performed to identify potential 80P equipment problems which may cause plant trip The following material was reviewed as it applied to B0P training:

72TR-TRN-002-0S, " Licensee Requalification Training Program", Rev. 01

• DI-TRN-28-0286N, " Review and Routing of Event Reports", Rev. 0

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• 1980 - 1987 Licensee Requalification Program A strength in the training department is that it stresses B0P training as much as it does training within safety-related systems. In addition, the instructor's handbook on " Condensate and Feedwater System" and "Feedwater Heaters and Moisture Separator Reheaters" is well written and comprehensiv Another strength is that the training department informs the operational department of changes to the procedures and completed DCRs

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on a monthly basi It was found that the LERs are reviewed for

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applicability to the various lesson plans, and that many corrective L

actions and many have been already incorporated. Finally, it is strength

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that the licensee provides lecture or simulator training for all changes of a magnitude requiring detailed explanation, on a quarterly basi No weaknesses were found pertaining to B0P trainin . Management Support Management support at Hatch was found to be responsive to problems and management is actively seeking improvements in the BOP system Management has demonstrated an attitude that the problems identified should not only be corrected, but that an effort must be made to prevent future problems. Within the past three years specifically, numerous improvements have been rade in documentation, investigation and tracking of such things as trips, deficiencies or other events in the 80P system This includes such methods as the Automated Item Tracking System, Significant Occurrence Report, and new blue-card deficiency report However, an observation was made that in an effort to determine and report causes of problems, some weaknesses have develope A review of the root cause analysis for the failure of the selected components has shown an incompleteness and inconsistenc The existing requirements to include root cause and corrective actions in LERs did not allow sufficient time for completion of in-depth investigation Additionally, over the years, the methods and responsibility for making the analysis has changed. This resulted in root causes and corrective actions being specified in such different documents as LERs, post-trip reviews, significant-occurrence reports and engineering investigations, and prepared by such different groups as operations, engineering, safety and compliance and maintenance. Subsequently the final conclusions have not always been directly related back to the originating event. This does not ensure management obtains the consistent, complete analysis of the events that it needs to be able to take the appropriate action A dratt of proposed administrative guidelines, AG-MGR-27-0687N and a corrective action program 10AC-MGR-0005-0S were reviewe It was observed that these documents address the weaknesses mentioned and show a conmitment on the part of management to take action to make the necessary improvement . _ _ _ - _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ . ._ __ _ _ _ __

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Management has also introduced the " plant system engineer" structure into its organizatio This assigns specific system responsibility to an engineer for operation and reliability of a system. It was also observed that the engineering organization was divided approximately equally between the reactor systems and B0P systems. It was also observed that adequate resources in both personnel and funding were allocated to 80P systems, with BOP systems accounting for a major portion of future design change requests approva The licensee is active in numerous industry groups that address B0P problems, including INP0, NUMARC, EPRI and the BWR owners grou Based on interviews with utility personnel and observations of established programs, it is perceived that the attitudes and policies of management regarding 80P systems are understood and are being implemented through the organizations to the workers and first line supervisor Although many new programs are in effect, and many new ones are proposed or will soon be implemented, it is observed that the number of B0P asso-ciated trips have not decreased over the past three years. This may be attributable to the newness of the programs, and that the changes have not yet been able to produce a noticeable effect. The trips during this period, however, are no longer repetitive and are attributable to different root cause The inspectors have loticed that the controls and the attitudes of upper management toward BUP systems, with the exception of administrative requirements required by regulations, are not significantly different from those associated with safety related system In conclusion, management is deeply involved, and strongly interested in improving BOP systems' operations and in reducing challenges to the safety i system They are continually expending time and resources towards

! reducing the number of reactor trips and operating the plant safety and reliabl . Conclusions: Strengths and Weaknesses Reports analyzing unplanned reactor shutdowns have indicated that a majority were caused by transients from failure of B0P systems and component The NRC is concerned that these unwanted challenges to reactor safety systems may complicate the ability of operators and safety systems to control the reacto Decreasing the frequency of unwanted challenges results in a decreased risk to public health and safety. This inspection is one of several being conducted to provide insight as to how B0P equipment can be embodied into the routine inspection program of safety systems and systems important to safet _ _ - _ _ _ _ _ _ _ _ . _ _ _ _ _ _

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Because the inspection was limited-in scope, the following conclusions may not necessarily be indicative of a programmatic weakness, nor should it be l

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considered as a comprehensive assessment of the plants performance and its L programs. The strength and weaknesses are the collective views of the

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l team members based on their reviews and interviews of licensee personne Weaknesses The, number of B0P . related reactor trips have not been decreasing.-

However it was noted' that' the events are not repeats of previous problems; they appear to be of different.cause. It is concluded that the. effect of improvement ~ programs in place have not yet been -

realized in the.short ter Root cause analysis and corrective actions determination has over the past several years been. inconsistent and incomplete, with the final determination not: being directly correlated back to the~ original

. even Improvements have been made and draft guidelines have been ,

prepared to improve the method of performing the analysis, Trending of Deficiency Reports and Maintenance Work Orders may give false results since all events or problems are not in both system ~ A repeating or recurring event may therefor not appear to be as

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significant as it i Resources devoted to QA activities for B0P problems in perceived as low in light of the number of B0P related reactor trips being experience A recent review where B0P instruments were examine'd for significance was done solely by I & C personnel. Inputs from other knowledgeable personnel, such as those in Operations and Engineering may have resulted in a better revie Strengths Communications between departments has improved noticeabl Attitudes at the level of top management on through the craftsman is goo . . Training on B0P systems is good and appears to be stressed as much as safety related systems trainin The organizational structure is good in that B0P is highlighted by

, having a BOP Engineering Component utilizing the system engineers concept.

( Maintenance philcsophy for B0P is good in that the concepts and L practices utilized for safety related systcms have been embodied into the . BOP maintenance progra A predictive maintenance program has l

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been implemented to assist in reducing B0P related trip It was

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noted that maintenance has changed from a " reactive" mode to a

" planned activities " mode and B0P is getting its share of main-tenance resource Time between problem discovery and the fix appears to be shortening due to deliberate efforts. It was noted that a significant number of design changes or modifications scheduled for the next refueling

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outage are for BOP system improvements and are not NRC initiated.

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! Generally, B0P is treated equal to the rest of the plan This is i

reflected in the five year pla There is good LER event related feedback to all licensed personne This includes on-shift briefings, written event description, and Operator Requalification Training, A conscientious effort is being made by Operations to monitor and trend plant equipment. Although this program is not fully implemented, it should greatly aid in predicting potential equipment problems before they actually occu . Follow-up of Open Items List Status (92701)

In addition to the B0P system inspection that was conducted, a review was made of the status of the open items list. Results are as follows: (Closed) Violation 321/86-08-01: Failure to Document Conditions Adverse to Quality (62702)

The lhensee's response, dated August 16, 1986, was accepted by Region II. The inspector reviewed the corrective actions delineated in the licensee's violation respons The licensee committed to issuance of Deficiency Report 1-86-295, which was reviewed by the inspectors. In addition, Georgia Power Company Management Bulletin MM-MGR-002-0386 was reviewed by the inspector to verify that the licensee's steps to emphasize the importance of generating deficiency reports when applicabl (Closed) Violation 321/86-08-02: Failure to Properly Implement Existing Plant Procedures (62702)

The licensee's response, dated May 5, 1986, was considered acceptable by Region II, The inspector reviewed the corrective actions delineated in the licensee's response. The RHR Service Water Thennal Relief Valve was assigned a unique Master Parts List (MPL) number. In addition, the Equipment Location Index was reviewed and was found to contain unique MPL numbers for the following RHR Service Water Thermal Relief Valves:

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lE11-F3079A 1E11-F3079B 1 Ell-F3078A 1 Ell-F3078B Also, P-& ID #H16330 and H16329, were reviewed by the inspector and were found to contain the above-thermal relief valve (Closed) IFI 321/83-31-01: Inspector review of this item has shown appropriate licensee action to Generic letter 83-28 " Requested Action Based on Generic Implementations of Salem ATWS", dated July 8,198 No further licensee action is require (0 pen) Violation 366/86-39-01: Failure to determine the chinge in leak rate due to repairs' or adjustments to containment boundt ry prior to type- A test renders calculation of as is leak rate indeterminabl This item is still under review by the license (0 pen) IFI 321/86-13-03: Review licensee's evaluation of Ocal leak

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rate test program and any corrective action require This item was discussed with licensee personnel to determine the extent to which evaluations of the local leak rate test program were performed. . It was ascertained that the licensee has requested an offsite review from an A/E of the LLRT program, via Request for Engineering Assistance (REA) HT-6678. REA-HT-6678 is still under review by the licensee as well as by the A/E. Licensee personnel indicated that although this is an ongoing effort, some recommenda-tions as a result of REA-HT-6678 have already been implemente In addition, the licensee is evaluating REA-HT-6678 to determine if the physical accessibility exists to modify plant equipment. After the licensee has completed. the REA-HT-6678 review, additional plant modifications and procedural revisions, as necessary, will be performe (Closed) IFI 321/86-13-02: Verify air / water testing of certain valves is acceptable to NRC staf The inspector reviewed the appropriate documentation and licensee response to this item, and verified that air / water testing of certain valves (feedwater check valves) was specifically addressed in the licensee's FSAR, Section 5.2.5.1, Revision 1, dated July 1983. The FSAR revision incorporated responses which were reviewed and accepted by the NRC staf (0 pen) IFI 366,321/86-13-01: Review licensee's leak rate test report l

to determine pass / fail of as-found containment leak rate.

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Discussions with licensee personnel could not identify the five valves which were to be evaluated to determine the as-found leakage

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rate. [However, as-found leakage rate of the valves was not important because the valves terminated below the torus water level. This item is still under licensee and NRC internal revie h'. .(0 pen) IFI 366/86-39-02: Review licensee's~ action to identify and test all pressure restraining seals in the containment pressure boundar This- item is currently under licensee review. However, discussions with licensee personnel indicate that all pressure restraining seals in the containment pressure boundary willtbe identified and tested subsequent to ' licensee -final review and consideration of Request for Engineering Assistance REA-HT-667 . (Closed)-IFI 321, 366/T2500/12: Inspection of the cctions taken by the licensee and applicants of BWR facilities with Mark I and Mark II containments in response to GE SIL No. 40 (25012)

The inspector reviewed documentation on revised plant procedures, annunciator response procedures, and calibration procedures to determine to what extent the licensee has implemented actions reconinended in GE SIL 402. In addition, a verification was performed with regard to the status of work performed per the licensee respore letter to the NRC, dated April 5, 1984. The following documentation was reviewed:

3450 -T48-004-IS Rev. 3, dated 7-3-86, " Primary Containment Atmosphere Control System" (Unit 1)

3450 -T48-004-2S Rev. 3, dated 12-1-86, " Primary Containment Atmosphere Control System"-(Unit 2)

34AR -654-003-1 Rev.1. dated 11-5-85, "Drywell and Torus Inerting System Trouble" (Unit 1)

34AR -654-003-2 Rev.1, dated 11-5-85, "Drywell and Torus Inerting System Trouble" (Unit 2)

Design Change Request DCR-84-58 was reviewed to verify the incorpora-tion of a redundant temperature switch controlling the low temperature- shutoff valv Also, DCR-84-49 was reviewed to verify re-routing of the torus nitrogen inerting line (Unit 2) to preclude direct impingement to the vent header and other equipment in the torus. Discussions with plant personnel indicated licensee actions on visual inspectien and limited magnetic particle testing of all accessible welds of the Units 1 and 2 nitrogen injection lines from the containment penetrations to the inboard isolation valves have been completed.

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17 (0 pen) IFI 321/80-BU-06: Engineered Safety Feature (ESF) reset control l This item is still under licensee review, and is pending the completion of a licensee requested A/E indepth review of Bulletin 80-0 (Closed)URI 321/86-08-03: Determine actual maintenance performed on valve E11-F004 This issue was previously discussed in several management meetings between the NRC and GPC in March and April 1986 prior to the Unit I startu The actual maintenance performed was determined and value operability was confirmed. This item is close . Scram Discharge Volume Capability An inspection was performed on the scram discharge volume (SDV) capability using temporary instruction (TI) 2515/90 to determine compliance with a Generic Safety Evaluation Report on the subject issued December 1,198 Initial contact with on site personnel for preparation for this inspection was made March 31, 198 The report finding follows the format of Section 4 of TI 2515/90:

Item 4.1 Scram Discharge Header Size A review was performed of the FSAR; Section 3.4.5.3 (Unit 1) and Section 4.2.3.2.2.3 (Unit 2). Bechtel Letter B-GP-15030, dated July 20, 1987 and its Enclosure 1 were reviewed. The letter verifies compliance with General Electric (GE) Control Rod Drive Design Specifications for both Units 1 and 2. The following GE Design Specifications were reviewed:

Reactor Protection System (RPS) Design Specification (for required SDV instrument response time)

Unit 1, 22A3083AD, April 19, 1973 (S-15113RA)

Unit 2, 22A3024AB, R2, April 26, 1973 (S-25320RE)

Control Rod Drive Design Specification (for SDV size limitations)

Unit 1, 22A1342R8, January 29,1975(S-15131E)

Unit 2, 22A1342R9, January 11, 1979 (S-27540B)

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l The RPS design specification placed a one second response time limitation on SDV Itistrument Volume level instrument Item 4.2 Automatic Scram on High SDV level A review was performed on the Technical Specifications, FSAR and calibra-tion procedures for the Instrument Volume level switches and their associated trips, blocks and alarms. The following procedures were reviewed:

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57CP-C11-002-1, Rev. O and 57CP-C11-002-2, Rev. 0, " Fluid Components Inc.,

Liquid Level Controller, Model FR72-4HTRDLL" 57SV-C11-001-1, Rev. O and 575V-C11-001-2, Rev. O, "High Scram Discharge Volume Level Instrument FT and C" 57SV-C11-002-1S, Rev. I and 575V-C11-002-2, Rev. O, " Scram Discharge Volume Level (Thermal Sensors) FT and C" 3 Item 4.3 Instrument Taps Not on Connected Piping A physical inspection was conducted of the SDVs and their associated instrument volumes and instrumentation. The Unit 1 North and South bank SDV have the scram level switches located on a small volume connected directly to the SD Small bore piping then connects the volume to another instrument volume located away from the area. The second volume is instrumented for an alarm and rod block. The configuration is such that a fast fill event would initiate a scram prior to receiving alarms or a rod block. This will not effect the system's ability to perform its safety functio The Unit 2 configuration is similar in that long runs of smaller bore piping separate the water detection instrument from the float switches giving the high level scram. The safety function is not impaired by this configuration, but on fast fill events Unit 2 would probably receive a scram signal prior to the water alarm coming in on one bank, and prior to either the rod block or alarm for the other bank of control rod drive The Unit 2 configuration for the high level scram magnetrol instruments involved small bore piping running over eight feet in length to the switch volume on one bank and over fifteen feet on the other volume. Information Notice 87-17 " Response Time of Scram Instrument Volume Level Detectors" alerted BWR owners of long delay times resulting from the piping configuration of magnetrol switches used to monitor SDV water levels. The runs of small bore connected to Unit 2's magnetrol switches is longer than that at Browns Ferry. Browns Ferry had 20 second response times after a scram. Unit 2 response times have not been checked. A concern exists that tho it:ponse time is greater than the one-second time required by G In addition, the vent piping connected to the magnetrol volumes is connected to the SDV at a point where the flow discharging from the drives after a scram tees into flow from the other header. This location could be susceptible to water hanmer and has potential to cause water jets to enter the magnetrol volume through the vent lines. This may cause float damage. An evaluation of this potential problem and of the response time problem was committed to be performed prior to September 1,1987, by the licensee at the exit intervie Item 4.4 Detection of Water in the IV

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Review of the FSAR and physical configuration showed adequate diversity and redundancy to preclude a single failure resulting in a failure to detect and provide action in response to water above the scram setpoin Item 4.5 Vent and Drain Valve -System Interfaces I Physical inspection of the drains showed them'to be hard piped to radwaste

~ drains. - A. commitment to have an. evaluation prior to September 1,1987, was made by-the licensee that will address the possibility of backup of !

water through the drain syste Item 4.6 Vent Land Drain. Valves Close on Loss of Air A review was per' formed of plant drawings and Control Room indication to serify the vent and drain valves fail closed upon loss of air and their position is indicated in the Control Room. The following drawings were reviewed:

Unit 1, H-16064, R11 and H-16065,- R18 Unit 2, H-26006, R13 and H-26007, R18 Item 4.7 Operator Aid A review was made of the Control Room indication, and of the Annunciator Response Procedures associated with SDV level. Verification of proper labeling was made and procedure responses reviewed. The following

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Annunciator Response Procedures were reviewed:

" Scram Discharge' Volume Not Drained" Unit 1, 34AR-603-119-1S, R0 Unit 2,-34AR-603-119-2S, R0

" Scram Discharge Volume High Level Trip" Unit 1, 34AR-603-101-1S, R1 Unit 2, 34AR-603-101-25, R1

" Scram Discharge Volume High Level Trip Bypass" Unit 1, 34AR-603-110-15, R0 Unit 2, 34AR-603-110-2S, RO

' Scram Valve Pilot Air HDR High/ Low Pressure" {

l Unit 1, 34AR-603-131-15, RO Unit 2, 34AR-603-131-25, R0

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l Item 4.8 Active Failure in Vent and Drain Lines l

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A review of system as-built configuration drawings and an inspection of plant piping verified double vent and drain isolatio Item 4.9 Periodic Testing of Vent and Drain Valves A review was perfonned of Technical Specifications 3/4.1.6 and 4.1. In addition, procedure 34SV-C11-001-1, R0 and 34SV-C11-001-2, R0, " Scram Discharge Volume Isolation Valve FT and C" was performed. The procedure provided for position verification every month, cycling every three months, and calibration once each operating cycl Item 4.10 Periodic Testing of Level Detection Instrumentation Calibration procedures listed in Item 4.2 were reviewe In addition, procedure 57CP-CAL-012-2S, R1, "Magnetrol Level Switch Calibration" was reviewe Item 4.11 Periodic Testing Operability of the Entire System The plant procedure " Scram / Transient Reporting" performed by the Shift Technical Advisor contains steps verifying the SDV Level High Trip and the repositioning of the drain and vent valves occur. The procedure number is 42EN-ENG-011-0S, R It is run in response to all scram Summary When Items 4.3 and 4.5 are resolved, the requirements of the TI will be complete, r

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