ML20248C859
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| 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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, y . . UNITED STATES -
1 ar* -)*' NUCLEAR REGUDTORY COMMISSION .
REGsON 11
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gj A11ANTA, GEORGtA 30323
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(ReportNos.:: L50-424/89-19 and 50-425/89-23:
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' Licensee: -Georgia Power Company-
P.O. Bot 1295 .
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Birmingham,'AL 35201 '
-Docket Nos.: P1.424 and 50-425' License Nos.: NPF-68 and NPF-81
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. Facility Name: Vogtle 1 and 2
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Inspection Conducted: June 9 -' July 7, 1989 ,
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Inspectors: - _
J. Mogge. Scnior Resident /Inspectcr
2 MJ/M
.Date Signed
. / -c
R..-Fr Aiello, Resident Inspector
b 7-1&cF1
Date Signed-
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Approved By:
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A. R. Herdt, Branch Cnief
7/d'[[
'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
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cited violation was identified in the area of operations for failure
m to implement Operations procedure 10001-C as required by TS 6.7.1.a
,, 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) --
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LER 89-14 (paragraph '3.b(2)(a)), The remaining two non+ cited
violations were identified in the area of operations for failure' to
establish an adequate procedure for transferring radwaste from the
tank to the spent fuel pool per TS 6.7.1 - LER 89-13
,
recycle
(paragraph holdup
3.b (3)(b')) and failure to implement Main Tt,obine Operation
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
890S10G170 890731 $n
PDR ADuCK 05060124
a PDC 3
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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
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- 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 .
Advisor (when stationed) to determine the plant status, plans, and I
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
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and LCOs, lirensee guetings, and facility records. During these
inspections, the following objectives were achieved: I
(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
wet. ' While the conservative approach would be try, there is a 4
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.
(2) Plant Housekeeping Conditions - Storage of material and f
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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(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
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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
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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:
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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
inspector was informed of procedure 7051E-C, " Requisition Review 1
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
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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
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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
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One violation was identified in paragraph 2.a above. !
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3. Review of Licensee Reports (90712)(90713)(92700) )
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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.
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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
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if the technical specifications and other regulatory requirements
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.
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(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."
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(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
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! 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
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this item, the following is established.
NCV 50-425/89-23-01, " Failure To implement Main Turbine
Operation Procedure 13800-2 in Verifying That The Intercept
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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." ,
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,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 .
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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
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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
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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
bistable in the Control Rod Driva Circuitry which resulted l 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
letdown diversion to occur simultaneously. The appropriate' I
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
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the valve as already open. This. failure to report resulted
.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
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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
,
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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.
,
- Containment Closure - Operations procedure 12007-C, Rev. 11,
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 graphsr.CCS flow rate in GPM verses time in hours. A vent path
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
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' 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:
- _
T racking of Containment Penetrations - The licensee only addressed
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
Containment Once Boiling Initiates - A request for engineering
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.
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:(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
Reactor Vessel" - paragraph 4. I
The licensee committed at the exit to submit a corrected LER 50 425/89-21
discussed in paragraph 3.b(2)(c).
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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
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