ML20248C859
| ML20248C859 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/31/1989 |
| From: | Aiello R, Herdt A, Rogge J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20248C853 | List: |
| References | |
| 50-424-89-19, 50-425-89-23, GL-88-17, NUDOCS 8908100170 | |
| Download: ML20248C859 (17) | |
See also: IR 05000424/1989019
Text
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REGsON 11 b~ $, 8 101 MARIETTA ST., N.W. gj A11ANTA, GEORGtA 30323 (ReportNos.:: L50-424/89-19 and 50-425/89-23: ' . ' Licensee: -Georgia Power Company- P.O. Bot 1295 . i Birmingham,'AL 35201 ' -Docket Nos.: P1.424 and 50-425' License Nos.: NPF-68 and NPF-81 - . . Facility Name: Vogtle 1 and 2 t Inspection Conducted: June 9 -' July 7, 1989 , > 1 Inspectors: 2 MJ/M - _ J. Mogge. Scnior Resident /Inspectcr .Date Signed . / b 7-1&cF1 -c R..-Fr Aiello, Resident Inspector Date Signed- Approved By: - Y5 7/d'[[ ' r A. R. Herdt, Branch Cnief 'Dat'e Signed Division of Reactor Projects SUMMARY Scope: This routire inspection entailed resident inspection in the following areas: pla.1t operations, radiological controls, maintenance, surveillance, security, and quality programs and ad.ninistrative controls affecting quality. Results: Four violations were identified, one cited and three non-cited. The cited violation was identified in the area of operations for failure , to implement Operations procedure 10001-C as required by TS 6.7.1.a m to verify proper operation of control room chart recorders (paragraph ,, 2.. a ) . One of the three nor.-cited violations was identified in the area of surveillance for failure to establish adequate diesel lube oil and analysis procedures to implement License Condition 2.C(b) -- LER 89-14 (paragraph '3.b(2)(a)), The remaining two non+ cited l ' violations were identified in the area of operations for failure' to establish an adequate procedure for transferring radwaste from the recycle holdup (3)(b')) and failure to implement Main Tt,obine Operation tank to the spent fuel pool per TS 6.7.1 - LER 89-13 (paragraph 3.b , Procedure 13800-2 open - LER 89-21 (paragraph 3. bin verifying (2)(c)).that the intercept valves No specific strengths or weaknesses of licensee programs wera ' identified based on findings and observations in the areas inspected. I PDR ADuCK 05060124 $n 890S10G170 890731 a PDC 3 _ _ - _ _ - _ _ . - - - -- ---.-- - .---__ _
_ _ _ _ _ _ _ _ _ _ _ _ _ .- . - . - , -_ -_ . .' ' , 4 , .. DETAILS 1. Persons Contacted Licensee Employees
- G. Bockhold, Jr., General Manager Nuclear Plant
C. Coursey, Maintenance Superintendent
- G. Frederick Safety Audit and Engineering Group Supervisor
- H. Handfinger, Manager Maintenance
W. Kitchens, Assistant General Manager Plant Operations R. Legrand, Manager Chemistry and Health Physics G. McCarley, ]ndependent Safety Engineering Group Supervisor A. Mosbaugh, Plant Support Manager W. Mundy, Quality Assurance Audit Supervisor
- R. Odom, Nuclear Safety and Compliance Manager / Plant Engineering
Supervisor
- J. Sitartzwelder, Manager Operati9ns
Other licensee employees contacted included technicians, supervisors, engineers, operators, maintenance personnel, quality control inspectors, and office personnel.
- Attended Exit interview
An alphabetical list of acronyms and initialisms is located in the last paragraph of the Inspection Report. 2. Operational Safety Verification - (71707)(93702) The plant began this inspection period c,1 June 9 and ended on July 7, 1989, with both units operating at 100% power. On July 6, both units experienced a loss of all meteorological monitoring channels which resulted in an NUE which was declared and terminated the same day. a. Control Room Activities Control Room tours and observations were performed to verify that facility operations were being safely conducted within regulatory , I requirements. These inspections consisted of one or more of the following attributes as appropriate at the time of the inspection. - Proper Contro'l Room staffing - Control Room access and operator behavior - Adherence to approved procedures for activities in progress - Adherence to technical specification limiting conditions for operations - Observance of instruments and recorder traces of safety-related and important-to-safety systems for abnormalities - Review of annunciators alarmed and action in progress to correct . ___ __ _ -__ __ __- _ - -
r.- o 'l I <r y . , , . . ) 2 j . 1 - Control Board walkdowns i - Safety parameter dispity and the plant safety monitoring system operability status - Discussions and intervicws with the On-Shift Operatioits Supervisor, $hift Supervisor, Reactor Operators, and the Shift Technical . I Advisor (when stationed) to determine the plant status, plans, and to assess operator knowledge - Review of the operator logs, unit logs, and shift turnover sheets It was brought to the inspectors attention that insufficient time for rest was being allocated between the conclusion of requalification training and the begit.ning of the next shift for those who work the night shift. Theretore, an inspection was conducted during the night shift on June 30/ July 1 to observe the alertness of the operators at their stations following requalification training. Based on interviews and observations, the inspector was unabl6 to find evidence to support this cor,cern. While conducting control board walkdowns end observing instrument and recorder traces on June 14, 1989, the inspector noted that the refueling water storage tank level channel II, ILR 990, and containment pressure channel IV. IPR 934, had not been inking since June 13 and June 10 respectively. In the mean time, both recorders were stemped and subsequently assumed operational. Ensuring operab'ility of these items was identified to be not in accordance with either TS 6.7.1.a or operations procedure 10001-C sections 3.3 and 5.0. Operations procedure 10001-C, section .3.3, specifies criteria when performing rounds. Paragraph 5.0 further states that the onerator on duty is responsible for all charts in his area which include ensuring operability. The procedure violation did not result in a TS LC0 violation; however, it was representative of a failure to implement a procedure required by TS 6.7.1.a to verify proper operation of the control room recorders daily and to implement corrective maintenance when required. This violation is similar to violation 50-424/88 61-01 issued on February 10, 1989. The corrective action to violation 50-424/88-61-01 was completed on January 31, 1989, per the licensee's response on March 7, with the issuance of Standing Order C-89-01; however, it has not been effective. This item is identified as violation 50-424/89-19-0)., " Failure To Implement Operations Procedure 10001-C As Required By TS 6.7.1.a To Verify Proper Operation Of Control Room Chart Recorders." b. Facility Activities facility tours and observations were performed to assess the effectiveness of the administrative controls established by direct observation of plant activities, interviews and discussions with licensee personnel, independent verification of ;efety systems status _ - _ _ _ _ _ _ - _ _ - _ _ . _ - _ _ _ _ _ _ _ _ - _ _ _ - _ - _ - _ - - - - _ _ - _ . _- -_- ._. __ _ _- _ --
_- -- - _ . _ - - - _ - . - - _ _ _ _ _ - - - n' 'L . '!' ' , - . 3 " o and LCOs, lirensee guetings, and facility records. During these I inspections, the following objectives were achieved: (1) Safety System Status (71710) (50095) (37828) - Confirmation of system operabilir was obta1ned bi verification that flowpath valve alignment, control and power supply alignments, component conditions, and support systems for the accessible portions of the ESF trains. were proper. The in?ccessible portions are confirmed as availat,ility permits. A special inspection was conducted which observed final placement of the last spent fuel rack and drag testing. The inspector questioned the licensee's testing which did not include drag testing with the fuel pool 4 wet. ' While the conservative approach would be try, there is a swelling effect which has occurred in certain casigns which leads to binding and interference. After review of the licensee's design, the inspector concluded titat their design should not be susceptible to swelling; and therefore, dry drag testing in this case is conservative. Modificat!ons were reviewed in conjunction with NRC Inspection Report A'os. 50-424/89-20 and 50-425/89-24. The inspector had no comments. f (2) Plant Housekeeping Conditions Storage of material and - components lnd cleanliness, conditions of various areas throughout the facility were observed to determire whether safety and/or fire hazards existed. ( 3.) Fire Protection - Fire protection activities, staffing, and equipment were observed to verify that fire brigade staffing was appropriate and that fire alarms, extinguishing equipment, actuating controls, fire fighting equipment, emergency equipment, and fire barriers were 60erable. l- (4) Radiation Protection Radiation protection activities, - staffing, and equipment were observed to verify proper program implementation. The inspection included review of the plant program effectiveness. Radiation work permits and personnel compliance wei u reviewed during the daily plant t0ars. Radiation Control Areas were observed to verify proper identification and implementation. (5) Security - Security controls were observed to verify that security barriers were intact, guard forces were on duty, and access to the Protected Area was controlled in accordance with the facility security plan. Persenel were sbserved to verify proper display of badges and that personnel requiring escort were properly escorted. Personnel w:tnin Vital Areas were observed to ensure proper authorization for the area. Equipment operability or proper compensatory activities were verified on a periodic basis. --- _ ___ . - _ _ - _
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. 4 .. (6) Surveillance (61726)(61700) - Surveillance tests were observed to verify that approved procedures were being used, qualified personnel were conducting the tests 5 tests were adequete to verify equipment operability, calibrated equipment was utilizec,- and technical specification requirements were followed. The inspectors observed portions of the following surveillance and/or reviewed completed data against acceptance criteria: Surveillance No. Title 14496-2 Rev. O AFW System Flow Path Verification 1A510-2 Rev. 2 Control Room Emergency Filtration ' System Operability Test 3 14553-2 Rev. 1 ESF Room Cooler And Safety Related Chiller Flou Path Verification 14980-2 Rev. 2 DG Operability Test . 14993-2 Rev. O SG Feedpump Turbine Lube Oil System Test L 14994-2 Rev. O MFP Turbine Steam Admission Valve Movement 24810-1 Rev. 10 Delta T/Tavg loop 1 Protection Channel I Analog Channel Operational Test 32144-C Rev. 3 Determination Of Boron - Auto Titration 32802-C Rev. O Flame Operation Of The . Atomic Absorption Spectrophotometer 35515-2 Rev. 0 Operation Of The Nuclear Sampling System - Liquid (7) Maintenance Activities (62703) The inspector observed - maintenance activities to verify that correct equipment clearanc.es were in effect, work requests and fire prevention work permits as required were issued and being followed, quality control personnel were available for inspection activities as required, retesting and return of systems to service was prompt and correct, and technical specification requirements were being followed. The Maintenance Work Order backlog was reviewed, and maintenance was observed and/or work packages were reviewed for the following maintenance activities: o .
. -_ -- - . _ _ _ . . _ _, . . _ _ - _ - _ . - __ _ - _ _ ' . c, . 1 E 5 .,n l: MWO No. WorkDescrjption 18901851 Repair DG "B" #8 Right Cylinder Inlet Jacket Water Leak 18902265 Reactor Coolant Pump Seal Water Injection Flows Channel Calibration (8) Multi-Plant Action Item A-15 (25593) - This inspection was to ' verify that plants utilizing diesel generators as backup power sources have complied with 10 CFR Part 50, Appendix B, require- ments regarding diesel generator fuel oil. During the review, the inspector noted that the Q-list in FSAR Sections 3.2.2-1 and 17.3 does not specifically identify diesel fuel oil or other lubricants. Upon contacting the NRR technical contact, the inspector was ir. formed that another inspection procedure would examine the proper receipt, storage, and handling of emergency diesel generator fuel oil and verify that the licensee has a quality program in place. This inspection was completed in NRC Inspection Report Nos. 50-424/89-08 and 50-425/89-11. The i 1 inspector was informed of procedure 7051E-C, " Requisition Review For Technical And Quality Requirements," and procedu're 261-C, " Fuel Oil Handling And Safety," as applicable. These procedures control both the purchase and receipt of diesel fuel oil. (9) Multi-Plant Action Item B-05 (25594) This inspection was - intended to verify that changes rude to administrative controls or plant modifications committed to by licensees in response to Information Memorandum No. 7 issued on October 4,1977, to i comply with dilution requirements were completed. The inspector verified with the NRR lead technical contact that this issue is 1 not applicable to this facility. (10) Oyerations Management Council - On June 26, 1989, the inspector attended the licensee's Operations Management Council. The agenda consisted of PRB activities, LER administration, procurement of fire protection and security equipment, and the recent unit overpower event. As a result of this meeting, the PRB membership will be upgraded by July 31 to utilize the Departnient Heads. While LER administration is still under study, proposals were made to reduce the barriers to submitting reports in a timely manner. Procurement activities, regarding Q and non-Q uses conflicting with the plant policy of ordering all parts Q, was resolved by deciding to split the systems. This council was forned as a forum to elevate and discuss issues of multi-departmental concern. The inspector determined that it apparently functions as planned. (11) Licensed Operator Requalification Program - The inspector was requested by +he NRC Region Management to review the notification system for removing operators from licensed duty. Administrative Procedure 00715-C, " Licensed Operator . __.______________..______._________.__i
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Requalification Program," was reviewed. This procedure establishes in step 4.2.6.1.3 that the Operations Superintendent Training will notify Operations of examination results. Written ! notification of p?acement in an Accelerated Requalification ! Program will be provided to the individual by the Manager j Operations. Attachment 2 of the procedure is a i fill-in-the-blanks letter to be used for notification with ) " distribution to 'the responsible supervisor. Discussions with . operations revealed that the notification is by telephonic means l with the letter to follow. Tc inspector noted that the form ) could be enhanced to document what actually occurred since the i letter does not document the who, what, and when cf the actual i notification. The inspector also suggested that they contact l V. C. Summer Nuclear Power Station for details of how an l operator assumed the controls while holding an inactive license. 1 Further program enhancements may be needed. The inspector I determined that the licensee understands the NRC requirements .l for timely removal from duty and has at; adequate procedure for j handling notification to operators of an inactive status. 1 l One violation was identified in paragraph 2.a above. ! .! 3. Review of Licensee Reports (90712)(90713)(92700) ) .) a. In-Office Review-of Periodic and Special Reports j This inspection consisted of reviewing the below listed reports to determine whether the information reported by the licensee was . technically adequate and consistent with the inspector knowledge of the material contained within the report. Selected material within 2 the report was questioned randomly to verify accuracy and to provide I a reasonable assurance that other NRC personnel have an appropriate l document for their activities. Monthly Operating Report - The reports dated June 6 and June 12, 1989, were reviewed. The June 6 report updates the test status of Unit 2 and includes information concerning PORV challenges which i occurred on April 13, 1989. The inspector had no comments. ( b. Deficiency Cards and Licensee Event Reports j Deficiency Cards and Licensee Event Reports were reviewed for potential generic impact, to detect trends, and to determine whether corrective actions appeareri appropriate. Events which were reported pursuant to 10 CFR 50.72 were reviewed as they occurred to determine if the technical specifications and other regulatory requirements l were satisfit;d. In-office review of LERs may result in further follow-up to verify that the stated corrective actions have been completed or to identify violations in addition to those described in the LER. Each LER is reviewed for enforcement action in accordance with 10 CFR Part 2, Appendix C; ar.d if the violation is not being - _ - _ _
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. . cited, the criteria specified in Section V.G of the Enforcement Policy were satisfied. Review of DCt. was performed to maintain a realtime status of deficiencies, determine regulatory compliance, follow licensee corrective actions, and assist as a basis for closure of the LER when reviewed. Due to the numerous DCs processed, only those DCs which result in enforcement action or further inspector followup with the licensee at the end of the inspectior, are listed below. The LERs and DCs denoted with an asterisk indicate that reactive' inspection occurred at the time of the event prior to receipt of the written report. (1) Deficiency Card reviews: (a) 00-1-89-1076, " Failure To Perform a Response Time Test Of a Newly Installed Reactor Trip Breater " On June 19, 1989, during the performance of the six month PM on the reactor trip breaker, a spare breaker which had not been response-time tested was installed in the reactor trip breaker cubic resulting in the inoperability of the breaker. This will be further followed up when submitted as a LER. (b) *DC-2-89-1138, " Failure To Implement The Monthly Tritium Analysis Required By Procedure 30025-C." The licensee was attempting to perform the initial technical specification surveillance for E BAR in May 1989, when it was discovered that no tritium data was available. The analysis was not implemented until May 24, 1989. It was the licensee's intention to begin implementation at fuel load. The licensee contacted NRR regarding the problem of having to perform surveillance which require a later surveillance to determine acceptability. This deficiency will be followed up wen submitted as an LER. (c) *DC-2-89-1182, " Debris Found In The Installed Temporary Feedwater Transmitters Resulting In Overpower Condition." On June 14, 1989, durin9 the performance of test Engineering 89-09, calibration of the installed temporary feedwater transmitters revealed debris in the sensing lines from the nozzles to the installed transmitters. Feedwater flow indication increased and apparent reactor power increased approximately 0.5% (18 MWt) higher than the licensed maximum power level of 3411 MWt. This condition may have existed since Unit 2 first reached 100% power on May 15,~1989. Additional evaluation is underway. The unit 2 reactor is now operating within the licensed power level. This event will be further followed up when submitted as a LER. __- - . _ - - _ _ _ - - _ - - _-_--___-______-______________-_L
_ - _ - _ _ _ _ - _ _ _ - _ _ _ _ o ' . . . 8 . , (d) *DC-1-89-1139, " Loss of Power to the meteorological monitoring channels." On July 6, 1989, both units experienced a loss of power to both meteorological monitoring - channels. An Nile was declared and terminated the same day per the emergency plan. This item will be followed up when submitted as a LER. (2) The following LERs were reviewed and are ready for closure pending verification that the lictnsee's stated corrective actions have been completed. (a) 50-424/89-14. Rev. 0, " Failure To Analyze Diesel Lube Oil Leads To License Condition Violation." On June 2, 1989, it was discovered that the plant had not complied with the Operating License paragraph 5.c because the quarterly ferrographic analysis was last performed in October 1988 for the train A diesel generator and in July 1988 for the train 3 diesel generator. Operating License NPF-68, Section 2.Ct6), requires GPC to implement diesel generator requirements as specified in Attachment 1 to the license. Attachment 1, paragraph 5.c. mandates querterly spectrographic and ferrographic analysis of engine oil to detect evidence of bearing degradation.- Additionally, spectrographic analyses have not been regularly trended to detect indication of abnormal bearing degradation. The cause of this event was the failure to adequately incorporate license commitments into plant procedures. A ferrographic analyses was performed and found acceptable based on comparison with previously taken baseline data. Corrective actions will also include revision to Procedures 54170-1, " Diesel Generator Lube Oil Analysis, Tranding, And Evaluation," to require trend evaluation of quarterly spectrographic and ferrographic analyses and Procedure 32531-C, " Diesel Generator Lube Oil Sampling And Analysis," to require engine oil samples to be taken for ferrographic analysis. These actions will be complete by July 15, 1989. This item represents a violation of NRC requirements which meet the criteria for non-citation. In order to track this item, the following is established. NCV 50-424/89-19-02, " Failure To Establish Adequate Diesel Lube Oil And Analysis Procedures To Implement License i Condition 2.C(b) - LER 89-14." i l _ . . .Am_..__.. __m._.___ __ ___m__..m___m__ _ ___.__.m_______ __..__..__.m..--_-_m_mm_ _ _ _ - _ _ _ _ __. mum _ _-__--_a_.---.m.m____.-_-_m ..._a___----- _ _ _ . _ _ _ . _-______m.-a _m_._.___m________ _m_ u.____.___
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.. . 9 ,, , i (b) *50-425/89-20 Rev. O, " Loss Of Power To Ni Channel Causes Reactor Trip During Surveillance Test." On May 12, 1989, while personnel were . performing surveillance of nuclear instrument channel N44, a 2 out of 4 Hi Finx rate trip coincidence signal was received causing an automatic reactor trip. Power range channel N43 experienced a momentary loss of power, which tripped the Rate Trip bistable on N43. The control room operator acknowledged the alann for the tripped bistable but failed to notice that the wrong bistable had tripped for the work being performed. A step of the surveillance procedure, which was being performed for N44, requires the fuses to be pulled. This tripped the Rate Trip bistable for N44. The N43 and N44 bistables satisfied the 2 out of 4 Logic for a power range trip. The reactor trip breakers opened tripping the reactor. All automatic systems functioned as designed. The control room operators brought the plant to stable conditions in Mode 3 (Hot Standby). The causes of this event were the loss of power to channel N43 and the failure of control room operators to notice that the wrong bistable had tripped. Extensive troubleshooting of N43 was performed. The cause for the power loss could not be determined. The opera tions requalification training program will be revised to increase emphasis on recognizing the cause of the alarm being acknowledged. Nuclear instrument calibration procedures will be revised b August 1,1989 to require reactor operator signoff (yin addition to instrument technician signoff presently required) prior to manually tripping bistables or removing instrument power. The inspector aiscussed with the licensee why the loss of power to N43 had not been determined. Since N43 was not operating properly, the licensee suspects that improper cleaning of the high l voltage power supply leads may have caused the prthlem. The licensee now requires the connectors to be cleaned whenever reinsta11ation occurs. (c) *50-425/89-21, Rev. O, " Failure Of Intercept Valves To Open Results In Reactor Trip On SG Lolo Level." On M9y 22, 1989, with the unit at 12% power, preparations were underway to start up the main turbine. Indications of a steam / feed mismatch problem were seen on SG #2. Operators checked various parameters but could not determine the cause of the problem. At approximately the same time, the Reactor Operator observed a decrease in primary temperature that was greater than expected. Because SG 1evels and pressures were decreasing, the Balance-of-Plant operator tripped the turbine. Feed to the steam generators was increased and the steam dumps were manually closed. An automatic reactor trip occurred on
- , . ._ . - _ __ - - - . -- e a . . ' ' ' . . 10 , , ! Lolo level in SG #2. The cause of the event was the failure of.the intercept valves to open when the turbine speed was increased and the failure of .the operator to follow the main turbine operations procedure in verifying that the valves opened. The LER incorrectly states that the B Main Steam Reactor relief lifted creating an increased steam load, which resulted in the lowering of the SG water icvel and reactor trip. In fact, the steam flow had been increasing for five minutes prior to the relief .ifting; and as a result of the lifting, steam flow stabilized. At this point, operators noticed a drop jn primary temperature, steam generator levels, and steam generator pressures and subsequently. tripped the main turbine. Due to the long period of high steam flow with limited feedflow, the SG inventory had been reduced and this resulted in a Lolo SG reactor trip. The intercept valves have been corrected and personnel counseled. ~ Since the enly action which can preclude a failed intercept valve from becoming a more serious transient is attention to detail during turbine startup. The proper corrective action should be to counsel the operators and utilize this event as an example in training on attention to detail. This item represents a violation of NRC requirements which meets the criteria for non-citation. Ir order to track this item, the following is established. i NCV 50-425/89-23-01, " Failure To implement Main Turbine ' . Operation Procedure 13800-2 in Verifying That The Intercept Valves Properly Open - LER 89-21." (3) The foll] wing LERs were reviewed and closed. (a) *50-424/89-12, Rev. O, " Failed Vibration Monitoring Card Causes Main Feed Pump Trip And Reactor Trip." , l ,0n May 9,1989, the unit began experiencing MFP 'B' high l vibration alarms (6 aiarms in 15 seconds), which would I, immediately clear. The Turbine Building Operator reported no unusual noise at the pump. The Advanced Turbine Supervisory Instrumentation was checked, and readings were found to be below alarm levels. At this time it was thought that pa* inters working in the area had moved cables causing the alarm. Alarms were again received, and a check of the Advanced Turbine Supervisory Instrumentation and a . report from the Turbine Building Operator did not indicate . . . . anything abnormal. Bearing metal and lube oil temperatures l were checked on the main computer, and the readings were j acceptable. Assistance was requested from Maintenance and ' Engineering. The individuals investigating the problem did not detect any unusual vibration of the MFP. The MFP , tripped on high vibration. Control Reoa operatora ] attempted recovery from the pump trip but were not able to prevent a reactor trip due to SG #4 Lolo level. The cause i \\ l .
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l: I , ! o e , , . . 11 i { l l 1 of the MFP trip was a broken solder connection on a test j jack in the Advanced Turbir.e Supervisory Instrumentation { vibration . card for the low pressure bearing. A l contributing cause to the reactor trip was a failed l bistable in the Control Rod Driva Circuitry which resulted 1 in the failure of the rods to insert when placed in auto. Corrective actions included repair of the broken solder connection and rep'lacement of the affected rod control' system circuit card. (b) *50-424/89-13, Rev. O, " Procedure Inadequacy leads To Fuel Handling Building Isolation." On May 30, 1989, with the unit at 86% power, filling of the spent fuel pool transfer canal from the Recycle Holdup Tank was in progress. Reactor Coolant System letdown was diverted from the Volume Control Tank to the RHT. However, because of the evolution in progress to fill the spent fuel pool . trai sfer canal, the letdown was inadvertently sent to the spent fuel pool transfer canal. Dissolved gases-came out of solution and actuated a high radiation signal, and a Fuel Handling Building Isolation occurred. This event was caused by an inadequate procedure which allowed both the j filling for the spent fuel pool tran;far canal and the I letdown diversion to occur simultaneously. The appropriate' procedure has been changed to prevent recurrence. Procedures 13719-1,13719-2 (Spent Fuel Pocl Cooling and - Purification System), and 13703-C (Boron Recycle System), have been revised and were reviewed by the inspector. The changes remove direction from 13719 procedures ar.d establish 13703-C as the overall procedure. During the review of 13703-C, the inspector noted that typographical errors had been made which reflected poor proofing prior to approval. These errors were discussed with the Operations Manager and Operations Radwaste Supervisor, and the inspector was informed that these would be corrected. In addition, the revision would include an enhancement to ensure that the tank to be transferred is removed from service. The inspector noted that the procedure in general has operators closing and opening valves which are already in the correct position. The inspector was i.oncerned that the operator direction should be to " check close6" or " check open" these components. 1his methodology would serve to identify components that are not in the assumed position and lend itself to better plant control. A review of the operations procedure writers guide noted definitions for action verbs " check," "open," and "close" but does not indicate combined usage as a requirement when a component is already in the correct position. The inspector could only recall one i. vent (LER 50-424/87-59) where an operator was directed to open a valve in which he failed to report ____ --__ _ ____ _______--- _ -
W., y ,y' .. e 4 . 1 y v , , , . Z .; ' ., 12. m g -A ' ' g the valve as already open. This. failure to report resulted m" .in the failure of~the plant to' recognize that this was the wrong ' valve. . The operator- raisedino concern because, as illustrated above, it.is routine to position stems which' are already in position., The procedure werkness was ,, 'l referred to Operations. Management for consideration. The event described in this-LER represents a violation'of NkC ' requirements which meet the criteria for ron-citation." In order to track this item, the follow 1.ng'is-established.
NCY 50-424/89-19-03, " Failure To Establish An Adequite : Procedure For Transferring Radwaste From The Recycle holdup Tank To The Spent Fuel' Pool'Per TS 6.7,1. - LER 89-13." (c) *50-425/89-18, Rev. 0, " Loss Of Stator. Cooling. Water Leads' ' To Feedwater Isolation." 'On' April 22, 1989, a plant operator, performing the weekly transfer - of the generator stator cooling water pumps, attempted to start pump "A" but found that both dumps had ~ shut.'down. A turbine trip occurred, as designed, from the~ loss of stator cooling water. The steam dumps opened, and reactor power was reduced from 36% to 8% due to autofuatic > rod control motion. Control room operators manually _ controlled- steam generator water levels during the power descent by manipulating the Main 'Feedwater Regulating Valves. A Feedwater Isolation occurred when SG #3 reached its high-high level setpoint. - Placing control red i operation .in automatic, per proc'edure 18011-C, allowed reactor power to rapidly drop to a level at which SG 1evel control was difficult. This requirement was the cause of the Feedwater Isolation 'and AFW actuation Procedure 18011-C was revised and reviewed. NRC enforcement action is documented in NRC Inspection Report No. 50-425/E9-18. Three non-cited violations were identified. 4. ' Loss of Decay Heat Removal (Generic Letter No. 88-17), TI 2515/101-(255101) - Units 1 and 2 This inspection consisted of a redew of the licensee response to Generic Letter '88-17 (Loss of Decay Heat Removal) dated October 17, 1988. The inspector verified that the licensee has completed or is in the process of' completing its response to the expeditious actions by verification of the ' following: Training - Lesson plan RQ-LP-61991-00-C (Case Study On Loss Of RHR At - Mid-Loop), covered loss of RHR during mid-loop operations. Included was a discussion of the consequences and possible mitigating actions for a loss of.RHR during various mid-loop lineups. The lesson plan , also ' discusses Vogtle's response to Westinghouse Owners Group letters , _--.___--._.____..__-__--____---.__--___l-
, __ - _ _ _ __ - ._ ._ _ _ _ _ - _ - ' - ,. . , - .,- , 13- g .. 88-21 and 88-078. The lesson plan also references the licensee's l response to Generic Letter 88-12, Lesson plan RQ-LP-61992-00-C (Case Study On RHR Valve Closure Events) covers the chain of events described in NRC Information Notice 87-01 (RHR valve misalignment causes degradation of ECCS in PWRs) and LER 50-424/87-55 (closure of the RHR system valves causes loss of availability of one RHR pump). The Westinghouse P.HR vortex video tape was presented. The effects of varying loop water level and RHR flow rate on vortex formation vere emphasized. Operations procedure 12007-C, Rev. 11, Containment Closure - - , Refueling Entry, Step 4.1.lb(1), requires the operators to ensure that the containment hatch is capable of being closed within 2 hours { or ensure the equipment hatch is closed prior to reducing RCS level three feet below the reactor vessol flange. Operations procedure 18019-C, Rev. 6. Loss Of RHR, had a chution prior to Step A1. It states: , "During mid-loop operation with hot leg dams installed and inadequate RCS venting, a loss of RHR cooling will result in saturated RCS conditions vithin 10 minutes subsequently resulting in core uncovery and requiring containment closure initiation." RCS Inventory - The licensee plans to purstfe a change to the - technical specifications which will allow the SI pamps to be availbble during operation in a reduced inventory condition without having to invoke 10 CFR 50.54x. There are three options availeble as a means of water addition: charging flow to a closed cold leg, gravity fill via the RWST, and the SI/RHR pmps (operations procedure 18019-C ' Rev. 6, Loss Of RH3, Steps A6b, A6c, and A6e, respectively). Procedure 18019-C contains a graph (Figure 3), which graphs time to core uncovery in seconds versus time after shutdown in hours. This procedure addresses flow rate suffit.ient to prevent uncovering the core. This is illu:,trated by operations procedure 18019-C, figure 1, which graphs .CCS flow rate in GPM verses time in hours. A vent path r is provided on the RHR suction to vent unwanted steam or water as a result of a nump loss or cavitation. Hot Leg Flow Paths - The inspector verified that the licensee has - Eijilemented procedures and administrative controls that reasonably assure that all hot legs are not blocked simultaneously by nozzle ! dams unless a vent path is provided that is large enough to prevent pressurization of the upper plenun of the reactor vessel. The s1ze of the openings specified in procedures 12006-C, Rev.13, (Unit Cooldown to Cold Shutdown) and 12007-C, Rev. 11, (Refueling Entry) is sufficient per Westinghouse Owners Group generic analysis. This inspection also included a review of temperature indications, RCS water level indication and RCS perturbations which have been addressed in GPC Response to Ganeric Letter 88-17 dated February 2,1989, to the 1 l ,
_ _ _ _ .- c' ,; , 3 e,.- ! l 14 . . ' inspectors satisfaction. The NRC staff reviewed the GPC response to Generic Letter 88-17 dated December 29, 1988, and found the licensee's response to appear to be incomplete in three areas. The inspector _ examined these areas. The result of the inspection are as follows: _ racking of Containment Penetrations - The licensee only addressed T - containment penetrations that have been opened by " Manual means," t The auto closure items are covered by a caution statement (see above) l prior to Step Al in operations procedure 18019-C. The licensee stated that initiating containment closure means to also initiate containment isolation " phase A" and containment ventilation isolation as well as initiating closure of the containment hatch. -- Containment Closure Within Allowable Times - The licensee has two options with respect to closure status of the containment equipment hatch when the reactor vessel is drained down to mid loop (3 feet below the reactor vessel flange). In accordance with operations procedure 12007-C, Rev.11 (Refueling Entry), paragraph 4.1.1.b.(1), they must either ensure the hatch is capable of being closed within 2 hours or ensure the hatch is closed prior to reaching a mid loop status. Penetrations other than the equipment hatch are tracked by information LCOs. Containment Cooling Fans / Feasibility of Continued Work Within - A request for engineering Containment Once Boiling Initiates - assistance has been submitted to examine the feasibility of continued work inside containment once boiling initiates within the reactor vessel and creates a steam environment within containment. Additionally, the licensee has been asked to identify what reasonable assurance is available that containment fans will also be available under the same conditions. Resolution of these items is considered' an IFI and is identified as: IFI 50-424/89-19-04 and 50-425/89-23-02, " Review Resolution Of Engineering Evaluation On The Feasibility Of Continued Work Inside Containment And Identify What Reasonable Assurance Is Availabh That Containment fans Will Be Available Once Boiling Initiatts Within The Reactot Vessel." 5. Actions on Previous Inspection Findings - (S2701)(92702) (a) (Closed) VIO 50-424/89-10-01, " Failure To Follow Procedure 35301-C For The Establishment Of Quality Control Hold Points. The inspector reviewed the licensee's response dated May 18, 1989, to the Notice dated April 19, 1989. Full compliance wat achieved , ! subsequent to the assignment of hold points for the mechanical portion of the repairs on March 7,1989. The inspector concluded that this issue har been resolved properly. - - . _ _ _ - _ _ _ - _ - - - _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ - _ - _ - - - _ _ _ _ - - _ _ _ _ - - - _ _ - _ _ _ _ _ _ _ _ _ -
_ _ _ e . 4 . 6 . - . . . 15 - m I '
- (b)
(Closed) VIO 50-425/89-12-01, " Failure To Maintain Two independent Core Cooling Subsystems Operable As Required By TS 3.5.2." l The inspector reviewed the licensee's response dated May 18, 1989, to the Notice dated April 19, 1989. Full compliance was achieved on March 9,1989, upon closure of valves 2-1205-U4-027 and 226. To preclude recurrence, an enhanced locked valve program which included more clearly defined Support Shift Supervisor responsibilities has [ been implemented and reviewed by the inspector. Enhanced sensitivity 1 to system status has been included in the lessons learned portion of i requalification training. The inspector concluded that this issue ! has been resolved properly. 6. Exit Interviews - (30703) l The inspection scope and findings were summarized on July 7,1989, with tNse persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection results. No- dissenting comments were received from the licensee. The licensee did 'not identify as proprietary any of the materials provided to or reviewed by the inspector -during this inspection. Region based NRC exit interviews were attended during the inspection period by a resident inspector. This inspection closed two violations (paragraph 5(a) and 5(b)) e.n! three Licensee Event Reports (paragraph 3.b(3)(a), 3.b(3)(b), and ' 3)(c)). The items identified during this inspection were: VIO 50-424/89-19-01, " Failure To Implement Operations Proceo.:re - 10001-C As Required By TS 6.7.1.a To Verify Proper Operation Of Control Room Chart Recorders" - paragraph 2.a. NCY 50-424/89-19-02, " Failure To Establish Adequate Diesel tube Oil- - And Analysis Procedures To Implement License Condition 2.C(b) - LER 89-14" - paragraph 3.b(2)(a). NCV 50-424/89-19-03, " Failure To Establish An Adequate Procedure For - , Transferring Radwaste From The Recycle Holdup Tank To The Spent Fuel
Pool Per TS 6.7.1. - LER 89-13" - paragraph 3.b(3)(b), 1 NCV 50-425/89-23-01, " Failure To Implement Main Turbine Operation - Procedure 13800-2 In Verifying That The Intercept Valves Properly Open - LER 89-21" - paragraph 3.b(2)(c). IFI 50-424/89-19-04 and 50-425/89-23-02, " Review Resolution Of - Engineering Evaluation On The Feasibility Of Contineed Work Inside Containment And Identify What Reasonable Assurance Is Available That Containment Fans Will Be Available Once Boiling Initiates Within The I Reactor Vessel" - paragraph 4. The licensee committed at the exit to submit a corrected LER 50 425/89-21 discussed in paragraph 3.b(2)(c). _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ - _ - - . . - _ - - _ - _ _ _ _ _ _ - _ - . - _ - - - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
_ _ . , , ' = - , 16 l:
- -.
7. Acronyms And Initialisms AFW Auxiliary Feedwater System CDT Central Daylight Time CFR Code of Federal Regulations DC Deficiency Cards DG Diesel Generator ECCS Emergency Core Cooling System ESF Engineered Safety Features FSAR Final Safety Analysis Report GPC Georgia Power Company GPM Gallons per Minute IFI Inspector Followup Item ILR Instrument Level Recorder IPR Instrument Pressure Recorder LCO timiting Conditions for Operations LER Licensee Event Reports LP Low Pressure ! MFP Main Feed Pump
MWO Maintenance Work Order l MWt Megawatt thermal NCV Non-cited Violation NI- Nuclear Instrument NPF' Nuclear Power Facility i NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation NUE Notice of Unusual Event PM Planned Maintenance PORV Power Operated Relief Valve PRB Plant Review Beard PWR Pressurized Water Reactor RCS Reactor Coolant System Rev. Revision CriR Residual Heat Removal System RHT Recycle Holdup Tank RWST Refueling Water Storage Tank SG Steam Generator SI Safety Injection System TI Temporary Instruction TS Technical Specification VIO Violation i ! - - - _ _ - _ _ _ _ _ - _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ - - _ _ _ - _ _ _ _ _ - - - - - _ _ _ - i }}