ML20244C381

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Insp Repts 50-498/89-11 & 50-499/89-11 on 890401-30. Violations Noted.Major Areas Inspected:Plant Status,Followup of Events,Operational Safety Verification,Monthly Maint Observation & Surveillance Observation
ML20244C381
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 05/26/1989
From: Holler E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20244C372 List:
References
50-498-89-11, 50-499-89-11, NUDOCS 8906140240
Download: ML20244C381 (14)


See also: IR 05000498/1989011

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

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REGION IV

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.NRC Inspection Rcport:

50-498/89-11

Operating Licenses:

NPF-76

50-499/89-11

NPF-80.

Dockets:

50-498

50-499

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Licensee:

Houston Lighting & Power Company (HL&P)

P.O. Box 1700

Houston, Texas 77001

Facility Name:

South Texas Project (STP), Units 1 and 2

Inspection At:

STP, Natagorda County, Texas

Inspection Conducted:' April 1-30, 1989

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Inspectors:

J. E. Bess, Senior Resident Inspector, Unit.1

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Project Section D, Division of Reactor

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Projects

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J. I. Tapia, Senior Resident Inspector

Unit 2, Project Section D, Division of Reactor

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R. J. Evans, Resident Inspector, Unit 1

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Project Section D, Division of. Reactor

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D. L. Garrison, Resident Inspector, Unit 2

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Project Section D, Division of Reactor

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R. V. Azua, Reactor Inspector, Test Program

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Section, Division of Reactor Safety

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Approved:

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E. J. Holler, Chief, Project Section D

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Division of Reactor Projects

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890614o240 890607

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ADOCK 05000498

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Inspection Summary

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Inspection Conducted April 1-30, 1989 (Report 50-498/89-11; 50-499/89-11)

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Areas Inspected: Routine, unannounced inspection of plant status, followup of

events, operational safety verification, monthly maintenance observation, and

monthly surveillance observation.

Results: Within the areas inspected, one violation of NRC requirements was

identified regarding failure to establish environmental qualification of

certain auxiliary feedwater system valves with installed space heaters. Also,

paragraph 4)y of the space heaters did not meet the guidance of RG 1.75 (see

the circuitr

A weakness was noted in the controlling of instruction manuals,

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spare parts, history files, and housekeeping. A violation was noted but not

cited regarding maintenance activities (see paragraph 5). Discrepancies were

noted between the same procedures used in Unit I and in Unit 2 regarding

accumulator surveillance (see paragraph 6). Discrepancies regarding proper

maintenance of oil level in the essential chillers was also noted (see

paragraph 7).

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DETAILS

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1.

. Persons Contacted

  • P. L. Walker, Senior Licensing Engineer
  • J. E.. Geiger, General Manager, Nuclear Assurance
  • A. W. Harrison, Supervising Licensing Engineer
  • V. A. Simonis, Plant Operations Support Manager
  • S. M. Head, Supervising Licensing Engineer
  • M. R. Wisenburg, Plant Superintendent
  • J. R. Lovell Technical Services Manager
  • W. H. Kinsey, Plant Manager
  • M. A. McBurnett, Licensing Manager

In addition to the above, the NRC inspectors also held discussions

with various licensee, architect engineer (AE), maintenance, and other

contractor personnel during this inspection.

  • Denotes those individuals attending the exit interview conducted on

May 4, 1989.

2.

Plant Status

Unit 1 operated at full licensed thermal power for the duration of this

inspection period. The annual emergency preparedness graded exercise was

conducted on April 26, 1989. The results of the exercise are documented

in NRC Inspection Report 50-498/89-12; 50-499/89-12.

Unit 2 began this inspection period at 8 percent reactor power. After an

initial unsuccessful attempt to synchronize the Unit 2 main generator to

the offsite electrical distribution system, the licensee successfully

synchronized the generator on April 11, 1989. Toward the end of the

inspection period, the licensee shut down Unit 2 to find and correct a

noise essociated with the main turbine.

3.

Followup of Events - Units 1 and 2

(93702)

On April 6,1989, at 5:54 a.m. , with the Unit 1 emergency safety

features (ESF) Diesel Generator (DG) No.11 out of service for scheduled

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maintenance, ESF DG No.12 failed to start during an operability test

required by Technical Specification (TS) 3.8.1.1.

With two inoperable

DGs, Unit 1 entered a 2-hour limiting condition for operation (LCO) as

required by TS 3.8.1.1(f). Unable to return DG Nos.11 or 12 to

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operability status by 7:54 a.m., the licensee began a controlled shutdown

of Unit 1 as requireo by TS 3.8.1.1(f).

The problem with the DG No.12 was determined to be a failed resistor in

the governor assembly. The licensee had received information from the

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Palo Verde Nuclear Generating Station (PVNGS) that similar problems had

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existed with their DGs. Both the STP and the PVNGS DGs were manufactured

by Cooper Energy Services. The licensee contacted the manufacturer to

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discuss the problem and to pursue possible corrective measures that should

preclude recurrence of this event.

At 11:46 a.m., on April 6,1989, DG No.11 was returned to service. The

NRC inspector witnessed the performance of Procedure 1 PSP 03-DG-0001,

" Standby (S/B) Diesel Generator No.11 Operability Test." Following the

replacement of the failed resistor in the governor assembly and after

successfully completing the required operability test, the licensee

declared DG No.12 operable at 7:50 p.m. and exited TS 3.8.1.1.

On April 5,1989, Unit 2 tripped from 11 percent reactor power while

attempting to synchrntize the main generator to the offsite electrical

distribution system. The licensee determined the cause of the reactor

trip to be an electrical relay problem associated with the main generator

circuit breaker. The licensee determined that improper implementation of

changes to the wiring of the generator backup distance relay and negative

phase sequence relay by startup technicians, prior to turnover of the

generator system to plant operations, caused the Main Generator Circuit

Breaker to trip. The problem relsys were rewired and tested on April 7,

1989.

The loss of power to 13.8kV auxiliary buses, after the generator circuit

breaker tripped, resulted in a loss of power to Reactor Coolant Pumps 2A,

2B, 2C, and 2D. The undervoltage coils on the pump breakers actuated to

trip the breakers and generate a low flow reactor trip signal through the

Solid State Protection System, which tripped the reactor. All rods

inserted normally. The loss of power to ESF bus E2A caused Standby Diesel

Generator No. 21 to start.

ESF loads sequenced onto the bus as required.

After verifying stable conditions, the operators reenergized the auxiliary

buses from their respective standby buses which were supplied from the

Unit 2 Standby Transformer. When bus 2J was reenergized, RCP 2D restarted

because its breaker had failed to trip open on the loss of voltage. The

additional flow caused a drop in steam generator water level resulting in

an actuation of the Auxiliary Feedwater system. Average coolant

temperature continued to decrease due to lack of decay heat, lack of

coolant pump heat, and secondary steam loads. A main steam isolation was

manually initiated to prevent overcooling of the RCS.

Troubleshooting of the RCP 2D breaker revealed a broken lug on a cable

from the undervoltage coil to the breaker trip circuit. The wita

connected to the lug had caught on the breaker enclosure, apparently when

the breaker was racked in, because of the wire falling out of its harness.

The undervoltage coil functioned properly and sent a trip signal to the

Solid State Protection System to initiate a reactor trip; however, the RCP

breaker did not trip because of the broken lug. The broken lug on the

RCP 2D breaker was replaced and the other Unit 2 RCP breakers were checked

for other wires which may have fallen from their harnesses.

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. Plant restart was delayed by a packing leak on _a feedwater isolation

bypass valve. Mode I was achieved on April 11, 1989. On the same day, at

1:26 p.m., initial generator synchronization to the offsf te electrical

distribution system was achieved.

On April 15,1989, a Unit 2 reactor trip occurred when the Train S reactor

trip breaker opened without receiving a reactor trip signal from the solid

state protection system. All systems functioned normally after the trip.

The faulty breaker was subsequently replaced but reactor restart was again

delayed by necessary repairs to a worsening packing leak on the feedwater

isolation bypass valve. Mode 1 was again achieved on April 20, 1989.

On April 21, 1989, a metallic noise was discovered in the area near the

No. 8 main turbine generator bearing. HL&P commenced a reactor shutdown

to disassemble and inspect the low pressure turbine and bearings. On

April 27,1989, the licensee determined that a bore plug in the main

turbine generator jack shaft had backed out and fallen into the hollow

bull gear, causing a noise as it tumbled within the bull gear when the

turbine was rolled. The inspection period ended with reassembly of the

main turbine ongoing.

4.

Operational Safety. Verification - Units 1 & 2 (71707)

The objectives of this portion of the inspection were to ensure that the

facility was being operated safely and in conformance with regulatory

requirements, to er.sure that the licensee's management controls were

effective in discharging the licensee's responsibility for continued safe

operation, and te assure that selected activities of the licensee's

radiological protection program were implemented in conformance with plant

policies and procedures and were in compliance with the approved physical

security plan.

The NRC inspectors visited the control rooms on a daily basis when onsite

and verified that control room staffing, operator behavior, shift

turnover, adherence to TS LCOs, and overall control room decorum were

being conducted in accordance with NRC requirements.

Tours were conducted throughout various locations of the plant to observe

work and operations in progress.

Radiological work practices, posting of

barriers, ard proper use of personnel dosimetry were observed.

The NRC inspectors verified, on a sampling basis, that the licensee's

security force was functioning in compliance with the approved physical

security plan. Search equipment such as X-ray machines, metal detectors,

and explosive detectors were observed to be operational. The NRC

inspectors noted that the protected area was well maintained and not

compromised by erosion or unauthorized openings in the area barrier.

General housekeeping, cleanliness, and physical condition of

safety-related equipment were inspected with particular emphasis on

engineered safety feature (ESF) systems.

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During the inspection period, the NRC inspectors questioned the licensee

about the use of space heaters in safety-related motor operated valves.

The licensee identified seven safety-related valves per unit with space

heaters.. Three valves were associated with the Essential Cooling

Water (ECW) system and four were associated with Train D of the Auxiliary

Feedwater(AFW) system. Space heaters for the valves were provided by the

vendor for use during reinstallation storage and were not considered

safety related. After questioning by the NRC inspectors on the safety

classification of the motor space heaters, the licensee perfonned an

indepth review of the application of space heaters in the seven valves.

The licensee determined that the space heaters were incorrectly wired into

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the circuitry of the eight (four per unit) AFW valves but were correctly

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wired into the circuitry of the six (three per unit) ECW valves. The six

ECW valve space heaters were wired with dual circuit breakers, with one-

breaker designed to shunt trip open on an ESF signal. However, the eight

AFW valves had nonsafety-related space heaters wired in parallel to the

criteria established by Regulatory Guide (guration apparently did not meet

Class IE 125V DC motors. The wiring confi

RG).1.75,"Ph

The four AFW valves (per unit)ysical Independence

are: AF-MOV0143,

of Electrical Systems."

AFW turbine steam inlet valve; AF-MOV0514, AFW Pump 14 turbine trip and

throttle valve; AF-FV7526, AFW to steam generator ID regulating valve; and

AF-M0V0019, AF turbine Pump 14 isolation valve.

The eight AFW valves were located in the Unit 1 and Unit 2 isolation valve

cubicle (IVC) buildings. The area would be subjected to a harsh

environment if a design basis accident occurred. The eight AFW valves

were environmentally qualified because of their location. Vendor supplied

documents (Wyle Laboratories Report No. 47644-05) indicated that the motor

operated valves were tested for environmental qualification (EQ) without

the space heaters being energized. The licensee operated the eight EQ AFW

valves for several months with space heaters wired into the valve

circuits, even though the space heaters had not been shown to have been EQ

tested.

Paragraph (f) of 10 CFR 50.49 requires that qualification of each

component must be based on testing or experience with identical equipment,

or with similar equipment with a supporting analysis, to show that the

equipment to be qualified is acceptable. Paragraph (k) of 10 CFR 50.49

states that equipment previously required by the Commission to be

qualified to NUREG-0588, " Interim Staff Position on Environmental

Qualification of Safety Related Electrical Equipment," need not be

requalified. Section5(1)ofNUREG-0588, Revision 1,statesthatthe

qualification documentation shall verify that each type of electrical

equipment is qualified for its application and meets its 'specified

performance requirements. The basis of qualification shall be explained

to show the relationship of all facets of proof needed to support adequacy

of the complete equipment. Data used to demonstrate the qualification of

the equipment shall be pertinent to the application and organized in an

auditable form.

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The equipment qualification file (Wyle Laboratories Report No. 47664-05)

for the eight AFW valves did not adequately support the actual application

of the valves with the space' heaters installed and energized. The EQ

documentation' failed to adequately analyze for all possible effects of

energized space heaters used within the valve assemblies. Specifically,

the areas not analyzed included effect of premature aging of the valve

com)onents due' to: the additional heat supplied by the heater. .the effect-

of leater failure on the valve, and the effect of burn damage on.

electrical components due to close proximity to the heater elements.

Failure to properly qualify the eight AFW valves-with regard to their

~ application.in the field is an apparent violation of 10 CFR 50.49

requirements (50-498/8911-01;50-499/8911-01)._

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Train B of the Safety Injection (SI) system for Unit 2 was inspected to

ensure the system valves, control switches, and electrical power supplies

were in their correct positions, as required by the system operating

. procedure and plant drawings. The SI system Train B was compared to

Procedure 2 POP 02-SI-0002, Revision 2, " Safety Injection System Initial

Lineup," and the Piping and Instrument Diagram (P&ID) 5N129F05014 No. 2,

Revision.10 " Safety Injection System." All valves, power supplies, and-

control switches were found to be in the correct ' position for the mode of

operation on the day of inspection.

Items observed during the inspection

included:

Labelling discrepancies were observed throughout the system lineups.

.For example, in the Control Board Lineup 2 POP 02-SI-0002-5,

Valve 2-SI-FV-3957 was labelled "HHSI Tc Upstream" on the panel, but

was called "HHSI Pump Cold Leg Test Line Isolation Valv,

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procedure.

In the electrical lineup, the field label for

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Device E2B1-WIL was " Backup Breaker For Compt. C1," but E2B1-WIL was

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called 2-SI-M0V-0006B in the procedure.

In Train B Initial Lineup Procedure 2P0P02-SI-0002-5, the location of

Device 2-SI-0070B was missing the room number (fuel handling

building (FHB) RM-5).

During the review of SI System Vent Lineup 2 POP 02-SI-0002-16, two

Train B valves were noted to be missing from the lineup. The two

valves were the Test Vent Valves 2-SI-0138 and 2-S1-01018.

The SI System Vent Lineup 2P0P02-SI-0002-16 listed Valve 2-SI-0231,

which e s previously deleted. The valve was not shown on the system

P&ID, neither was the valve listed in the system initial lineup. A

review of documentation was perfomed to detemine if the valve was

shown to be deleted when operations performed the SI system vent

lineup. The licensee could not locate documentation to verify that

Train B of the SI system was vented per 2 POP 02-SI-0002-16. However,

Train B of the SI system was vented per 2 PSP 03-SI-0014, Revision 1,

"ECCS Valve Checklist " on February 13, 1989.

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During the inspection of the mechanical auxiliary building (MAB) in

Unit 2, Boric Acid Tank Room 076 was visited. The NRC inspectors observed

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local Sample Connection Valve 2-CV-0322 leaking excessively. This valve

was slowly draining boric acid from Boric Acid Tank 2B onto the floor of

the room. The Unit 2 shift supervisor was immediately notified. The

licensee fully shut the valve and generated a problem report.

The NRC inspectors observed control room operations, reviewed applicable

logs, and conducted discussions with control room operators. The NRC

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inspectors verified the operability of selected emergency systems,

reviewed tag-out records and verified proper return to service of affected

components, and ensured that maintenance requests had been initiated for

equipment in need of maintenance.

One apparent violation and no deviations were identified in this area of

the inspection.

5.

Monthly Maintenance Observations - Unit 1 (62703)

Portions of selected Unit 1 maintenance activities were observed to

ascertain whether the activities were conducted in accordance with

approved procedures. The activities included:

Maintenance Work Request (liWR) SY46861, Seismic Monitoring System

Preventive Maintenance (PM) IC-0-EM86007175, Revision 9A,

Meteorological Monitoring System Inspection

The NRC inspectors tried to determine through observations whether

approved procedures were being used, replacement parts were properly

certified, and housekeeping was being maintained. Specific items noted

during the observation of PM IC-0-EM-86007175 included:

Both the Primary and Backup Meteorological (Met) towers had

instruction manuals and drawings that were uncontrolled and out of

date. Having manuals available for use by the technicians in remote

locations, such as the Met towers, can be beneficial. However,

having uncontrolled or out-of-date copies of manuals for

troubleshooting or maintenance purposes may lead to problems. The

manuals and drawings have since been recalled for updating or

disposal by the licensee.

A box inside the primary Met tower contained what appeared to be

spare parts. The spare parts were inside zip-lock bags that provided

some identification as to what the parts were, however, there were no

material issue forms included in the box that identified the date or

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source of issue. The spare parts have since been returned to the

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Instrumentation and Control (I&C) shop for dispositioning.

An uncontrolled history file was being maintained at both Met towers.

The information that was gathered as part of the PM was being

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transferred to copies of out-of-date data sheets. These data sheets

were then being added to the history files. The history files have

since been returned to the I&C shop for review to determine their

usefulness.

The primary and backup Met tower electric generator batteries were

observed to have standing water on top of them. The potential

existed where the water could have shorted out the batteries. The

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batteries were cleaned by the licensee on the day of inspection.

The primary Met tower was noted to be in need of cleaning.

Housekeeping was not being maintained in an acceptable manner. Loose

paper, dirt, dead insects, and other items were noted throughout the

room. Prior to the end of this inspection period, the room was

cleaned by the licensee.

Observations noted during the review of MWR SY-46861 included:

Technicians were noted to be troubleshooting the circuitry of Seismic

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Monitor Channel Sensor XT0002A. Troubleshooting activities included

removing the. sensor for testing, lifting leads for a wire check and

meggering, and reterminating the lifted leads. All troubleshooting

activities were performed using verbal instructions provided by the

foreman of the task. A review of the MWR was performed.

Authorization to troubleshoot the circuitry was not a part of the MWR.

Instructions on troubleshooting activitim were provided in

OPGP03-ZM-0021, Revision 1, " Control of Configuration Changes During

Maintenance or Troubleshooting." Section 6.2.1 of the procedure

requires, in part, that troubleshooting is to be performed using

approved work instructions and as part of an MWR. The technicians,

following the instructions of their foreman, appeared to exceed the

authorization allowed for troubleshooting per OPGP03-ZM-0021 without

revising MWR SY-46861.

TS 6.8.1 requires written procedures to be established, implemented,

and maintained, including applicable procedures recommended in

Appendix A of Regulatory Guide 1.33, Revision 2, " Quality Assurance

Program Requirements (Operation)." Written procedures required per

Appendix A of RG 1.33 included procedure adherence and performing

maintenance.

Contrary to the above, on April 27-28, 1989, technicians apparently

violated TS 6.8.1 by performing maintenance activities that did not

adhere to requirements established by 0PGP03-ZM-0021. Although the

seismic monitoring system is considered nonsafety related, their

operability is required by TS 3.3.3.3.

Thisapparentviolation(498/8911-02;499/8911-02)ofTS6.8.1will

not be cited because the criteria specified in Section V. A. of the

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enforcement policy were satisfied. Corrective actions taken by the

licensee subsequent to the apparent violation included personnel

training and perfonning a teview of current procedures to detemine

and clarify the scope of troubleshooting activities.

During the performance of MWR SY-46861, an inspection ot the Unit 1

tendon gallery was performed. Housekeeping was not being maintained,

as indicated by grease on the floor of the tendon gallery.

Approximately 2-3 gallons of grease was located in the center of the

floor. A tendon in the tendon gallery was leaking grease

significantly. The sheathing filler grease cap was leaking grease on

Tendon V222. After the condition was reported to the licensee, a

second tendon (V209) in Unit 2 was noted by the licensee to be

leaking grease. Nonconformance reports were written for the two

tendons. The licensee advised that each unit has 96 vertical tendons

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and all will be inspected at least every 6 weeks for signs of

additional leakage. Containment structural integrity is required by

TS 3.6.1.6.

The licensee stated that the leakage of grease from the

two tendons did not affect the structural integrities of the two

reactor containment buildings.

The ladder area leading to the Unit 1 tendon gallery was inadequately

illuminated. The area from the top of the first ladder to the second

ladder was observed not to be illuminated, and was considered to be

an obvious safety hazard. The tendon gallery is an area of the plant

that is not traversed by plant personnel on a regular basis.

One apparent violation and no deviations were identified in this area of

the inspection.

6.

Monthly Surveillance Observations - Units 1 and 2 (61726)

An inspection of Unit 1 licensee surveillance activities was performed to

ascertain whether the surveillance of systems and components was being

conducted in accordance with TS and other requirements. The following

surveillance tests were cbserved and reviewed:

IPSP02-SI-0953, Revision 1, " Accumulator 1B Level Group 2 ACOT

(L-0953)"

IPSP02-SI-0963, Revision 1, " Accumulator IB Pressure Group 2 ACOT

(P-0963)"

The NRC inspector verified that testing was performed using approved

procedures, final test data was within acceptance criteria limits, and

test equipment was within required calibration cycles. A technical review

of the procedures was also performed.

During the review of IPSP02-SI-0963, Section 7.5 was noted to be

misnumbered. Section 7.5 had two steps numbered as 7.5.3.

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instructed the technician to go to Step 7.5.4 if a computer point was

unavailable.

Due to the misnumbered steps, the potential existed of

referring a technician to, the wrong step (7.5.4). Verbatim compliance

with S'.ep 7.5.2 would have sent the technician to the wrong step.

Step 7.6.3 of IPSP02-SI-0953, instructed the technician to verify that an

annunciator alarmed when a comparator tripped. The comparator was reset

in the next step. Step 7.6.7 verified the same alarm energized when a

second circuit was tripped.

There were no steps between 7.6.3 and 7.6.7

that verified that the annunciator alarm cleared. The same procedure for

Unit 2 (2 PSP 02-SI-0953) included Step 7.6.6, which verified that the alarm

was clear. The same observation also applied to Procedure 1 PSP 02-SI-0963.

An inspection of Unit 2 licensee surveillance activities was performed to

ascertain whether the surveillance of systems and components _ were being

conducted in accordance with TS and other requirements. The following

surveillance tests were observed and reviewed:

2 PSP 02-SI-0931, Revision 0, "RWST Level Set 2 ACOT (L-0931)"

2 PSP 02-SI-0952, Revision 0, " Accumulator 2B Level Group 4 ACOT

(L-0952)"

During the review of 2 PSP 02-SI-0952, the procedure was compared to the

same procedure for Unit 1 (1 PSP 02-SI-0952, Revision 1). Differences were

noted between the two procedures. The differences inclutad:

The Unit 1 procedure additionally had Step 6.1 which referred the

technician to TS action statements for LC0 requirements. The Unit 2

procedure did not have a similar step.

The Unit 2 procedure had three additional steps in Section 7.6 to

verify that an annunciator was clear before, during, and after

testing. The Unit 1 procedure did not perform these steps.

Steps 7.7.1 (remove all test equipment) and 7.7.3 (ensure annunciator

deenergized) were double signoff steps for independent verification

of actions in the Unit 1 procedure. The same steps in the Unit 2

procedure were single signoff steps, with no independent verification

of the steps required.

Additionally, the NRC inspector noted the tenninal strips in the Unit 1

Relay Cabinet ZRR-012 had protective covers, but the terminal strips in

the Unit 2 Relay Cabinet ZRR-010 did not have protective covers.

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terminal strips were noted to be nonsafety related, however.

In conclusion, testing was performed using approved procedures, final test

data was within acceptance criteria limits, and test equipment was within

required calibration cycles. None of the observations were considered

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safety significant concerns. The discrepancies were referred to the

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licensee for resolution. No violations or deviations were identified in

this area of the inspection.

)

7.

Monthly Maintenance Observations - Unit 2 (62703)

The NRC inspectors observed portions of selected Unit 2 maintenance

activities to ascertain whether the activities were conducted in

accordance with approved procedures. The activities included Work

Request CH-78095, " Add Oil to Essential Chiller 218." The essential

chillers provide cooling to selected safety-related equipment during upset

and faulted conditions.

The problem description on the work request was, " Essential Chiller 21B

upper oil sightglass is empty when chiller is running, add oil as

required." The work observed included postmaintenance testing of

Chiller 21B following maintenance. The following items were noted during

the inspection:

Procedure OPMP05-CH-0001, Revision 1. " York Chiller Inspection and

Maintenance," Section 6.5.5, provided instructions on how to check

the oil level with the chillers either operating or shut down. With

low oil level (as written on Work Request CH-78095), Addendum 4 was

required to be performed. Addendum 4 provided instructions to start

the chiller (Step 1), install a jumper to energize a solenoid

(Step 2), allow the solenoid to remain energized for approximately

5 days (Step 3), and monitor oil level every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (Step 4).

Step 3 was not completed in its entirety before Step 4 was performed.

The chiller did not run for 5 days prior to maintenance performing

Step 4 and postmaintenance testing. Steps 3 and 4 of Addendum 4

should be adhered to or revised by the licensee to clarify how long

the chiller is required to operate prior to performing oil level

. hecks.

Discrepancies were noted to exist between the essential chilled

water (CH) system operating procedures, maintenance procedures, and

the vendor manual with respect to proper chiller oil level.

Step 8.1.1 of Operating Procedure 2 POP 02-CH-0001, Revision 1,

" Essential Chilled Water System," stated " Verify the operating oil

level is above the top of the lower sight glass to the middle of the

upper sight glass for (Chillers) 22A, 22B, and 22C. The oil level is

visible in the sightglass for (Chillers) 2!A, 21B, and 21C.

If oil

level is out of range contact maintenance for correction."

Step 6.5.5.1 of OPMP05-CH-0001 stated " Verify operating oil level is

from the top of the lower sightglass to the middle of the upper

sightglass." Step 6.5.5.2 stated " Verify shutdown oil level to be at

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least at the top of bottom sight glass to the middle of upper sight

glass." Both steps applied to both sizes of essential chillers, the

300-ton units (22A-C) and the 150-ton units (21A-C).

The vendor manual for Chillers 21A-C indicates proper operating oil

level is from the lower sight glass to the middle of the upper sight

glass.

A vendor representative informed the NRC inspector that proper oil level

for all chillers exists when oil is visible in the upper sight glass with

the unit operating, and oil level can be reliably checked only during

chiller operation.

Discrepancies noted with the above statements included:

Step 8.1.1 of 2 POP 02-CH-0001 implied that Chillers 21A-C have only

one sightglass to verify oil level, but the chillers actually have

two sightglasses, an upper and lower one.

Vendor instructions were not located by the NRC inspector or licensee

personnel for proper oil level for the "open drive" type chillers,

22A-C. The oil reservoir is physically different between the "open

drive" and "hcrmetic" chillers. Vendor instructions were provided

only for hermetic chillers.

Step 6.5.5.2 of OPMP05-CH-0001 indicated shutdown oil level should be

no higher than the middle of the upper sight glass. Actual shutdown

level will vary, depending on purge drum (removes noncondensable

gasses from chiller) level at shutdown, length of shutdown and

chiller temperature. Also, actual shutdown oil levels for the open

drive chillers (22A-C) were noted to be above the top of the upper

sightglass (disagrees with requirements of Step 6.5.5.2).

Additionally, Step)6.5.5.2 disagrees with vendor instructions

(providedverbally that oil level could only be reliably checked

during chiller operation.

MWR CH-78095 was written to add oil to Chiller 218. Per wording of

the vendor manual, the chiller had sufficient oil, therefore, the MWR

was an unnecessary but conservative action.

Step 8.1.1 of 2 POP 02-CH-0001 instructed the operator to verify

operating oil le' vel of a chiller, but the chillers are not started

until Step 8.1.8 of the procedure.

Step 8.1.1 should be revised to

verify the oil level of a shutdown chiller is above a certain level,

or Step 8.1.1 should be placed after Step 8.1.8.

This subject area will be tracked as an open item (499/8911-03) until all

procedures in question have been revised to agree on how to check

essential chiller oil level, and operations personnel are trained on the

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proper way to check operating and shutdown oil levels.

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No violations or deviations were identified in this area of the

inspection.

8.

Preparation for Refueling Observations - Unit 1 (60705)

The NRC inspectors observed the testing of a carbon arc cutting device and

the generation of the basic requirements for a procedure to which it is

qualified and used. The device was tested on a mockup of the bottom half

shell of a steam generator; the shell included one primary loop nozzle and

the manway cover and flange.

The purpose of the equipment is to extract a broken bolt / stud in the

manway flange if that event' occurs during the first Unit I refueling

outage.

(The center of the bolt is cut out and the sides are collapsed.)

The overall unit encompasses: a fixture which can be bolted 'to the manway

flange, a positioner which will align the cutting head to the bolt hole, a

cooling unit, power control, and the graphite electrode cutting tool. The

unit is operated by positioning the device in the hole with the broken

bolt / stud, starting the cooling system (the system providns coolant to the

electrode and washes away the residue), end energizing the power unit to

the cutting electrode. When the cut has been made, the electrode is

withdrawn and the resultant "shell" of the bolt can be collapsed inwardly

and removed from the flange. Once set up, the operation can be performed

remotely, thereby reducing or keeping personnel exposure to penetrating

radiation to a minimum. The NRC inspectors did not have any concerns in

the development of the process.

No violations or deviations were identified in this area of the

inspection.

9.

Exit Interview

The NRC inspector met with licensee representatives (denoted in

paragraph 1) on May 4,1989. The NRC inspectors summarized the scope and

findings of the inspection. The licensee did not identify as proprietary

any of the information provided to, or reviewed by, the NRC inspectors.

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