IR 05000416/1988011

Insp Rept 50-416/88-11 on 880606-10.No Violations or Deviations Noted.Unresolved Item Noted:Instrumentation for Drywell Pressure.Major Areas Inspected:Instrumentation Per Reg Guide 1.97 & Open Items Re Electrical Equipment

ML20150F997
Person / Time
Site:	Grand Gulf
Issue date:	06/30/1988
From:	Conlon T, Hunt M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20150F987	List: IR 05000416/1988011 ML20150F983
References
RTR-REGGD-01.097 50-416-88-11, NUDOCS 8807190169
Download: ML20150F997 (8)

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UNITED STATES

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Report No.: 50-416/88-11 Licensee: System Energy Resources, In Jackson, MS 39205 Docket No.: 50-416 License No.: NPF-29 Facility Name: Grand Gulf Inspection Conducted- June 6-10, 1988 Inspector- MW M i

d ' 382-Date Signed THunt , Team Gader Team Members:

P. Fillion M. Miller /

Approved b '6d M ~

d ' 30 - N T. C6nion, Chief, Plant Systenis Section Date Signed Engineering Branch Division of Reactor Safety SUMMARY Scope: This routine, announced inspection was conducted in the areas of engineering design, plant modifications, and calibration for instru-mentation systems to comply with Regulatory Guide 1.97. Follow-up of open items from previous inspections involved engineering, operations and maintenance of electrical equipmen Results: In the areas inspected, violations or deviations were not identifie ,

However, an unresolved matter was identified involving instrumentation for the drywell pressure (Paragraph 2). In general, the licensee's organization performed quite effectively in carrying out analysis and implementing modifications to comply with the comprehensive set of requirements contained in Regulatory Guide 1.9 .

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le i REPORT DETAILS

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i Persons Contacted Licensee Employees

• Cesare, Site Director (Acting)

• S. Bennett,-Supervisor, Nuclear Licensing

• D. Berryhill, Instrumentation and Control Engineer

• Withrow, Supervisor, Instrumentation and Control Engineers Other licensee employees contacted during this inspection included engineers, operators, and administrative personne ~NRC Resident Inspectors

• R. Butcher, Senior Resident Inspector

'*J. Mathis, Resident I.,spector

-* Attended exit interview Inspection of Licensee's Implementation of Mu'tiplant Action A-17:

Instrumentation for Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident (Regulatory Guide 1.97)

(25587)

Criterion 13, . "Instrumentation and Control", of Appendix A to 10 CFR Part 50 includes a requirement that instrumentation be provided to monitor variables and systems over their anticipated ranges for accident conditions as appropriate to ensure adequate safety. Regulatory Guide 1.97 (RG 1.97)

describes a method acceptable to the NRC staff for complying with the Commissions regulations to provide. instrumentation to monitor plant variables and systems during and following an acciden Conformance to RG 1.97 Revision 2 is required by the Grand Gulf Nuclear Station Operating License (condition 2.C.(36)). Instrumentation covered by RG 1.97 is classified into three categories of design and qualification criteri Also, instruments are classified as belonging to one or more of five types according to functio Following the NRC guidance for conducting this inspection, the inspectors selected an audit sample of parameters from RG 1.9 Table A itemizes the parameters selected for this inspection and the corresponding plant specific identificatio _

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2-TABLE A

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Parameter Cat-Typ Transmitter N Reactor Pressure; I-A&B B21-LT-N091A&B*

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Vessel' Level B21-LT-N044C&D*

.821-LT-N027A&B*

Reactor Pressure -I-A,B&C B21-PT-N062A&B*

Vessel Pressure Drywell Pressure I-A,B,C,&D M71-PDT-N001-A&B*

Drywell . Temperature I-A,0 M71-TE-N008A,B,C&D M71-TE-N013A,B,C&D Primary Containment I-A,B,C M71-PDT-N002A&B*

Pressure M71-PDT-N027A&B*

Primary Containment I-A' M71-TE-N007A,B,C,&D*

Temperature-Suppression Pool I-A,C&D E30-TE-N003A,B,C,&D*

Level Containment I-A,C E61-AITS-K002A&B*

H2 Concentration Drywell I-A,C E61-AITS-K001A&B*

H2 Concentration-Group I Isolation I-A,B- B21-ZS-N101A1,81,C1&D1 B21-ZS-N102A1,B1,C1&D1 B21-ZS-N104A1,B1,C1&D1 821-ZS-N116&N117-Primary Containment I-A,8 Listed in submittal Isolation Valve Position Containment Spray II-D E12-FT-N015A&B*

Flow plus valve lineup RHR System Flow II-D E12-FT-N015A&B plus valve lineup l * Indicates at le- one of the transmitters was visually inspected.

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Parameter Cat-Type Transmitter N (Continued)

RHR Heat Exchanger II-D E12-TE-N027A&B*

Outlet Temperature Cooling Water .II-D P41-TE-N011A&B*

Temperature Cooling Water Flow II-D P41-FT-N016A,B,&C*

AC Power Status II-D Listed in FSA DC Power Status II-D Listed in FSAh

• Indicates at least one of the transmitters wa3 visually inspecte Each of the transmitters listed in Table A and assuciated display devices in the control room were inspected for attributes corresponding to the design and qualification criteria specified in the regulatory guid Equipment qualification was verified by confirming that the equipment was on the licensee's Equipment Qualification Haster List and Quality Lis Seismic qualification was verified by checking the Seismic Qualification Central File Index. Redundancy, when required for a particular parameter, was verified to exists by checung P&ID drawings, schematics and loop diagrams. Proper ranges and appropriate identification were verified by visual inspection in the control roo Instrument and loop calibration procedures and data sheets were reviewe In cases where plant modifica-tions were proposed in the licensee's submittal te meet RG 1.97, the field devices were visually inspecte Three questions were raised by the inspectors during the inspectien which were answered in a formal manner by the licer see. First, the NRC pointed out that the licensee's submittal did not iaentify by . unique identifica-tion'the instruments which fulfill the RG 1.97 requirements. The submittal indicated an instrument identification number for each parameter which represented a family of instrument loops. To only specify a family of loops is ambiguous because, in some cases, all the loops within the designated f amily did not apply to RG 1.9 The licensee submitted a definitive list during the inspection, and committed to remove any

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ambiguities in identification numbers from Table 7.5-2, "Post-Accident Monitoring Instrumentation," in the UFSAR as part of their December 1988 UFSAR update submitta Second, the NRC inspector pointed out that RG 1.97 indicates that drywell pressure narrow range is a Type D, Category II parameter. However, the licensee's submittal, dated February 28, 1985, referenced the wide range instrument for this function, but they did not note this exception to the R . _ - - , . , . - - __ _

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.The NRC's rationale for including the drywell pressure narrow range parameter in RG 1.97 is monitoring of the: Post-LOCA vacuum breakers and the Drywell _. Purge System. - The plant does, in fact, have drywell/contain-ment differential pressure instrumentation .to control the Drywell Purge

. Syste The differential pressure is available 'for call up on the plant computer.. Following a LOCA, the ECCS will operate to condense the steam in the drywell and thus reduce the drywell pressure. As.soon as the

. . .drywell pressure drops below the containment pressure, the drywell vacuum breakers open and noncondensible gases from the containment flow back into the drywell. This flow of containment gases to the drywell continues by means of - the drywell purge compressors. When the drywell has been sufficiently pressurized, the noncondensibles (including hydrogen) will be forced into the containment through vents and the suppression poo Hydrogen recombiners in containment control hydrogen concentration to less than four volume percen It is desirable that the operator has the ability to confirm the operation of the Drywell Purge System and the Post-LOCA Vacuum Relief Syste Display of the drywell/ containment differential pressure (1E61-PDT-N013A-G and associated computer input) could provide this con fi rma tion. The licensee is reviewing this equipment against the quality standards and other criteria in RG 1.97. This matter is identified es Unresolved Item 88-11-01, Review Adequacy of Drywell/ Containment Differential Pressure Instrumentatio Third, during inspection of the control room the NRC inspectors noted that the RG 1.97 instruments do not have unique labels. They have labels that read "Post-Accident Monitoring", but these labels are not considered unique because they are the same type, size and color as those used for non-RG 1.97 instrument Discussions on this matter with the cognizant engineers disclosed the folicwiag information. In letter AECM-85/0059, dated February 28, 1985, the licensee committed to develop a philosophy regarding instrument channel identification as part of the overall

' Emergency Response Capability program, and it will be implemented as part of the GGNS Detailed Control Room Design Review. This action has been documented in Human Engineering Discrepancy (HED) No.1122 which is

designated as a Priority 2 action item. Priority 2 HEDs are scheduled for resolution before the end of the third refueling outag Documenta-tion for this previous commitment was reviewe The commitment was acceptable to the NRC as resolving the matter of labelling of RG 1.97 instrument Except for the three areas described above, each parameter in the audit sample was found to be monitored by devices which meet the requirements of the regulatory guide , The inspectors therefore concluded that Grand Gulf Nuclear Station is in compliance with Regulatory Guide 1.97. Instrumenta-tion has been insta!1ed which should provide the operator with complete l and reliable information during and following any postulated acciden The operator will be able to identify degraded conditions and their

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magnitude. The licensee's organization performed effectively in carrying out the RG 1.97 task. Human Engineering considerations are being addressed, iThe licensee was responsive to the NRC's identification of an unresolved item, and it is expected that this matter will be resolved in a timely manner, Documents Review 3d Letter from MP&L to NRC, dated February 28,-1985, on Regulatory Guide 1.97 (Rev. 2) Position Report on Accident Monitoring Instrumentation

[AECM-85/0059]

Safety Evaluation Repor,, Conformance to Regulatory Guide 1.97, Revision 2, transmitted January 12, 1587 UFSAR Table 7.5-2, Post-Accident Monitoring Instrumentation; and proposed changes Surveillance Procedure - Calibration 06-IC-1821-R-0008 Rev. 26 Reactor Vessel Water Level 06-IC-iB21-R-0014 Rev. 22 Reactor Vessel Pressure (PAM)

06-IC-1821-R-0044 Rev. 20 Reactor Vessel Water Level (PAM)-

06-IC-1E30-R-0001 Rev. 23 Suppression Pool Level Wide Range 06-IC-1E61-M-1004 Rev. 26 Containment and Drywell Hydrogen Analyzer (PAM)

06-IC-1M71-R-0001 Rev. 23 Containment Pressure (PAM) and Drywel Pressure 06-IC-1M/1-R-0003 Rev. 24 Suppiession Pool Temperature Monitoring Instrums ,tation 06-IC-1M71-R-0004 Rev. 25 Containman, and Drywell Temperature Calibration - Instruction 07-5-53-E12-8 Rev. 5 Residual Heat Removal System Water Temperatura 07-5-53-38 Rev. 5 Rosemount 1151, 1152, and 1153 Pressure Transmitters 07-S-53-43 Rev. 2 General Electric Company 180 Series Indicators Action on Previous Inspection Findings (92701)

Report 87-27, transmitted January 11, 1988, contains insp2ctor Followup Item 87-27-03, PRA inspection hardware availability observations followu This item consists of a set of recommendations developed during the PRA based inspection. Licensee action on recommendations in the electrical area were addressed during this inspectio Each of these items is discussed belo NRC RECOMMENDATION: During inspection tours, it was noted that the 4100 volt grounding switch was stored adjacent to the sequencer panel. This is not consistent with seismic desig _ _ _ _ _ _ _ _ _ _ _ _ _ .

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l LICENSEE ACTI0'N: The licensee stated that. the grounding switch will be stored'outside the Unit 1 area until an appropriate location can be foun NRC RECOMMENDATION: Since the licensee did not have a study that docu-E mented the proper application of the surge arresters in the switchyard and .the misapplication of surge arresters could be a possible source of common mode failure, ' the application of the surge arresters in the switchyard should be reviewe LICENSEE ACTION: The licensee stated that they intended to carry eat a general review of the surge protection in the switchyard. The NRC intends to review any documents generated by this stud NRC RECOMMENDATION: Serious consideration should be given to mairta ning the switchyard batteries according to all the recommendations of IEEE Std. 450, "IEEE Recommended Practice for Maintenance, Testing, an Replacement of Large Lead Storage Batteries for Generating St ations and Substations."

LICENSEE ACTION: Mississippi Power and Light Company (MP&L) has developed a procedure for test and surveillance of the switchyard batteries. This

- procedure is written to address IEEE-450 requirements. The first quarterly test using the new procedure was conducted in May 1988. MP&L and the plant staff are working out problems associated with providing a redundant power supply to allow performance of a load discharge tes NRC. RECOMMENDATION: Consideration should be given to factoring temperature differential into the 18-month battery service test in order to obtain the maximum trending information. Such information will be more important later in' battery life, especially since the discharge capacity tests were parformed using dif ferent procedures (i.e. , acceptance test vs five-year test vs ten-year test).

LICENSEE ACTION: The licensee re-evaluated their position on this matter, but concluded that temperactre correction for the 18-month battery service

- test was not beneficial oecause neitner the IEEE standard nor the manu-facturer provide guidance for this. The NRC later learned that the IEEE committee for Std. 450 deliberately omitted temperature correction for the

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! service tes For the above reasons, the licensee does not plan to i implement this recommendatio NRC RECOMMENDATION: The balance-of-d.nt batteries are maintained according to all the recommendations in IEEE Std. 450. However, in light of the PRA results, the licensee may wish to consider using the saf tey-related surveillance procedures for any batteries that power the annunci-ators in the main control room or equipment important to dominant PRA sequences, j l

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7 LICENSEE. ACTION: The licensee's position on this matte is that the cost associated with performing seven-day surveillance on balance-of plant battery pilot cells could not be justified, because it .ns not shown what-benefit would resul NRC RECOMMENDATION: Power for ESF transformer No.11 X-winding to Div I buses flows through breaker 152-1901 in the normal alignment (used prior to the inspection). Since breaker 152-1901 is in the Div II room, it appears that alternative breaker alignments would provide better separation between Div I and II for normal operatio LICENSEE ACTION: The licensee stated that they agree with the validity of'

this comment. Actual breaker lineups were not confirmed by the NRC inspector during this inspectio Of the six items related to IFI-87-27-03 discussed in this section, five are considered closed by the NRC. The item related to surge protection in the switchyard remains open since the NRC intends to review any documents generated by the proposed stud . Exit Interview The inspection scope and results were summarized on June 10, 1988, with those persons indicated in paragraph 1. The inspectort described the areas inspected and discussed in detail the inspection results listed belo Proprietary information is not contained in this rep >r Dissenting comments were not received from the license Item Number Description and Reference 416/88-11-01 URI - Review Adequacy of Drywell/ Containment Differential Pressure Instrumentation The licensee's management was informed as to which IFIs are considered closed.

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