ML20155J341

Insp Repts 50-369/88-12 & 50-370/88-12 on 880423-0520. Violations Noted.Major Areas Inspected:Operations Safety Verification,Surveillance Testing,Maint Activities & Followup on Previous Insp Findings

ML20155J341
Person / Time
Site:	Mcguire, McGuire
Issue date:	05/31/1988
From:	Croteau R, David Nelson, William Orders, Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20155J318	List: ML20155J312 ML20155J331 ML20155J336 ML20155J341
References
50-369-88-12, 50-370-88-12, NUDOCS 8806200486
Download: ML20155J341 (11)

See also: IR 05000369/1988012

Text

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'Hl[3 NUCLEAR REGULATORY COMMISSION

j\ .o REGION 11

101 M ARIETTA STRE ET, N.W.

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Report Nos. 50-369/88-12 and 59-370/88-12

Ocensee: Duke Power' Company

422 South Church Street

Charlotte,-NC .28242

Facility Name: McGuire Nuclear Station 1 and 2

Docket Nos.: 50-369 and'50-370

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License Nos.: NPF-9 and NPF-17

Inspection. Conducted: A ril 23, 1988 - May 20, 1988

Inspectors:/ ///fh/IU

'W. OrdTrs, Senior Re ident Inspector

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Approved by:

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T. A. Peeble(, S'ect'16n~ Chief

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Date Signed

Division of Reactor Projects

i SUMMARY

' Scope: This routine inspection involved the areas of operations safety

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Verification, surveillance testing, maintenance activities, and follow-up on

previous insp7ction findings.

Results: In +he ' areas inspected, three violations and one deviation were

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identified. One violation was identified which included four -examples of

inadequate procedures or failure' to follow procedures during auxiliary

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feedwater pump testing, auxiliary feedwater turbine operability determination,

! . or auxiliary feedwater equipment restoration. A second violation involves the

. inadequacy of a test program to test equipment in the as found condition. A

third violation deals with inoperable fire doors. A deviation was identified

which involves an operability determination which was made by a staff SR0

.instead of a regular shift SRO.

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PDR ADCCK 05000369

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g REPORT. DETAILS

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. 1.' Persons Contacted'

Licensee Employees

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• T.:McConnell, Plant Manager-

B.'Travis, Superintendent of Operations

J. Boyle, Superintendent of Integrated Scheduling'

.B.LHamilton, Superintendent of Technical Services

. *R.E Sharp, Compliance Engineer-

.M. Sample, Superintendent of' Maintenance

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• S. LeRoy, Licensing, General Offica

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• D. Baxter, OPS /MNS/NPD

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• R. Broome,'MNS-Integrated Scheduling-

..* R. Gill, NPD/ Licensing

• J. Snyder,' Performance Engineer

-*N. Atherton, Compliance

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• D. Ethington,' NPD/ Compliance

• R. Wagner, Design Engineering, McGuire Office

• G.' Bost, Design Engineering, McGuire Office

Other licensee employees contacted included construction craftsmen,

technicians, operators, mechanics, security force members, and office

personnel.

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• Attended exit interview

2. Exit. Interview (30703)

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The : inspection 'indings tdentified below were summarized on May 19, 1988,

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with those persons indicated in paragraph 1 above. The following items

were discussed in detail:

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(OPEN) Violation 370/88-12-01, Fire Doors found blocked open (See

Paragraph 4).

(CLO3ED) Licensee Identified Violation (LIV) 369/88-12-01, Failure to

calibrate.1A CA Pump Pressure Switch (See Paragraph 8).

.(OPEN) Deviation 369,370/88-12-02, Failure to obtain concurrence of a

! shift SR0'in an Operability Determination (See Paragraph 9.t.).

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.(OPEN) Violation 369,370/88-12-03, Failure to follow procedure / inadequate

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procedures with four examples (See Paragraphs 9, 10, and 11).

(OPEN) Violation 369,370/88-12-04, Inadequate surveillance test program

l for -turbine driven auxiliary feedwater pump testing (See Paragraph 9).

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(CLOSED) Licensee Identified Violation (LIV) 369,370/88-12-05,-Failure to

parform a,TS required channel check (See Paragraph- 8).

The licensee representatives present offered no dissenting comments, nor

did they identify as proprietary any of _ the information reviewed by the

e inspectors during the course of their inspection.

3. Unresolved Items

An unresolved item (UNR) is a matter about.which more information is

required to determine whether it is acceptable or may involve a_ violation

or deviation. There were no unresolved items identified in this report.

4. Plant Operations (71707, 71710)

The inspection staff reviewed plant operations during the report period to

verify conformance with applicable regulatory requirements. Control room

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logs, shift supervisors' logs, shift turnover records and equipment ~

removal ' and restoration records were routinely perused. Interviews were

conducted with plant operations, maintenance, chemistr.', he'alth physics,

and performance personnel.

Activities within the control room were monitored during shif ts and at

shift changes. Actions and/or activities observed were conducted as

prescribed in applicable station adainistrative directives. The-

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complement of licensed personnel on each-shift met or exceeded the minimum

required by Technical Specifications.

Plant tours taken durtn; the reporting period included, but were not

limited to, the turbine buildings, the auxiliary building, Unita 1 and 2

electrical equipment rooms, Units 1 and 2 cable spreading rooms, and the

station yard zone inside the protected area.

During the plant tours, ongoing activities, hcusekeeping, security,

equipment status and radiation control practices were observed.

During a routine tour of the auxiliary building on May 9, 1988, the

inspector noted that Techn. cal Specification Fire Ocors 601C and 6010

-[ doors to the Turbine -Driven Auxiliary Feedwater (TDCA) Pump Room] were

blocked open. Operations was unaware of the doo*s being blocked open

-therefore no fire watch was posted and no hourly fire watch patrol was

established. A performance person in the area was questioned about the

fire doors and informed the inspector the doors were not blocked open by

him. Licensee personnel promptly unblocked and closed the doors.

Personnel working in the TDCA pump room may have blocked the doors open to

cool the room down as temperature in the room was uncomfortably high.

L T.S. 3.7.11 states that all fire barrier penetrations (walls,

L floor / ceilings, cable tray enclosures and other fire barriers) separating

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safety-related fire areas _ or separating portions of redundant systems

important to safe shutdown within a fire area and. all sealing devices in-

fire rated assembly penetrations (fire doors, fire windows, fire dampers,

cable piping, and. ventilation' duct penetration seals) shall be OPERABLE.

With one or more~of the required fire barrier penetrations and/or sealing

. devices inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either establish a continuous fire watch

on at least one side of the affected assembly, or verify the OPERABILITY

of fire detectors on at least one side of the affected assembly, or verify

the OPERABILITY of- fire detectors on at least one side of the inoperable

assembly and establish an hourly fire watch patrol.

Contrary to T.S. 3.7.11 two fire doors were- blocked open making them

inoperable for an undetermined period of time without taking the required

action. This is an apparent violation (370/88-12-01). '

a. Unit 1 Operations

Unit 1 operated throughout the report period with no major

operational difficulties. On May 2,1988, however the turbine driven

auxiliary feedwater (TDCA) pump auto started when technicians dropped

a lead touching a terminal board causing a fuse to blow in the

circuitry while lif ting a lead as part of a performance test to

stroke time ' test ICA-27A, A CA pump minimum flow valve. The TOCA

pump tripped shortly af ter starting. The cause of the pump trip was

not immediately known and the licensee postulates that the latch on

the stop valve may have vibrated off to the trip condition on the

start of. the pump. The licensee stated the event would be

investigated to determine the cause of the trip. The fuse was

replaced and the TOCA pump was restarted several times to ensure

proper operation.

Also, at 6:55 p.m. on the evening of May 19, 1988, during the

performance of a diesel generator 1B load sequence test

(PT/1/A/4350-04B), licensee personnel failed to perform certain

actions required by the procedure which resulted in an inadvertent

engineered safety features (ESF) actuation. Details of this event

are entailed in paragraph'11.

b. Unit 2 Operations

Unit 2 operated throughout the report period with no major

operational disturbances with the exception of a power reduction to

approximately 10 percent power on May 13 to allow containment entry.

Containment entry was necessary to add oil to the C reactor coolant

pump motor. The unit returned to full power operation on May 16.

5. Surveillance Testing (61726)

Selected surveillance tests were analyzed and/or witnersed by the

inspector to ascertain procedural and performance adequacy and conformance

with applicable Technical Specifications.

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Selected tests were witnessed to ascertain that current written approved

procedures were available and in use, that test equipment in use was

calibrated, that test prerequisites were met, _that system restoration was

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completed and test results were adequate.

Detailed below are selected tests which were either reviewed or witnessed:

PROCEDURE EQUIPMENT / TEST

PT/2/A/4204/01B Residual Heat Removal Pump 2B Performance

Test

PT/2/A/4208/04A NS Heat Exchanger Performance. Test

PT/2/A/4350/04 4KV Unit 2 Sequence UV

PT/2/A/4403/07 RN Train 2A Flow Balance

PT/2/A/4206/01B NI' Pump 2B Performance Test

PT/2/A/4204/01A ND Pur.p 2A Performance Test

PT/2/A/4252/01 .CA Pump 2 Performance Test

PT/1/A/4208/01A NS Pump-1A Performance Test

PT/1/A/4401/01B KC Train 18 Performance Test

'PT/1/A/4252/01A Motor Driven CA Pur p 1A Performance Test

PT/1/A/4252/01 CA Pump 1 Performance Test

'See paragraph 9 for more information on PT/1/A/4252/01.

6. Maintenance Observations (62703)

Routine maintenance activities were reviewed and/or witnessed by the

resident inspection staff to ascertain procedural and performance adequacy

and conformance with. applicable Technicel Specifications.

The selected activities witnessed were examined to ascertain that, where

applicable, current written approved procedures were available and in_use,

'that prerequisites were met, that equipment restoration was completed and

maintenance results were adequate.

No violations or' deviations were identified.

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7. Follow-up on Previous Inspection Findings (92702)

The following previously identified items were reviewed to ascertain that

the licensee's responses, where applicable, and licensee actions were in

compliance with regulatory requirements and corrective actions have been

completed. Selective verification included record review, observations,

and discussions with licensee personnel.

(CLOSED) Unresolved Item 369/87-14-04, CA Pressure Switch CAL, Water Leg.

This item is identified as a licensee identified violation in section 8 of

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this report.

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[!' (CLOSED) ' Inspector Followup Item 369,370/87-02-01, Review PIR on VC/YC

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Failures (PIR-0-M87-0006). This event involved the loss of both trains of

control room ventilation / chilled water and was reported in LER 369/87-01.

The subject PIR has been reviewed and corrective actions have been taken

to prevent recurrence.

. (CLOSED) Violation 369,370/87-11-01, Failure to Perform Trending of RTB

Response Time Test Data. During regional inspection of March 16 - 20,

1987, the licensee could not show evidence that reactor trip breaker

response time was being trended. The licensee immediately reviewed

previous test data and provided plots of trend curves. Subsequently, the

licensee has established a formal trending program which requires the

review of response. time data for trends that may indicate breaker

deg radati on ~. Examination of records revealed that the licensee is

continually trending reactor trip breaker response time data. This item

is closed.

8. Licensee Event Report (LER) Followup (90712,92700)

The following LER's were reviewed to determine whether reporting

requirements have been met, the cause appears accurate, the corrective

actions-appear appropriate, generic applicability has been considered, and

whether the event is related to previous events. Selected LER's were

chosen for more detailed followuo in verifying the nature, impact, and

cause of the event as well as corrective actions taken.

(CLOSED) Licensee Event Report 369/87-08, Missed Channel Surveillance on

Unit 1 and 2 Reactor Vessel Instrumentation Due to a Defective Procedure.

Monthly channel checks on the "Dynamic Head (D/P)" on the reactor vessel

level instrumentation system (RVLIS) had not been performed since RVLIS

was installed in mid-1986 until April 10, 1987. The TS required checks

were not done due to confusion caused by a difference in what the TS

-assumed would be installed as RVLIS instrumentation and what was actually

approved and installed.

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'The original channel designations were upper plenum level, narrow range

level, and wide' range level and the TS requirements refer to narrow range

and wide range levels. The installed RVLIS channel designations are

! labeled upper level, lower level, and dynamic head. Personnel improperly

! assumed that the narrow range and wide range TS required instruments were

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the upper level and lower level installed instruments. The wide range

channel in the TS actually related to the "Dynamic Head (D/P)". This

l confusion led to a failure to per f orm a TS required channel check and is

l identified as a Licensee Identified Violation (LIV 369,370/88-12-05).

The LER stated that a TS change had beer submitted in February of 1987 to

correct the improper terminology in the TS. The TS change is still under

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review by the NRC but should be issued shortly. This issue was discussed

l avith the NRR Licensing Project Manager.

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(CLOSED) Licensee Event Report 369/87-10, Incorrect Calibration of an

Auxiliary Feedwater -(CA) System Pressure Switch. The pressure switch in

' question'(1 CAPS 5002) was discovered to be improperly set in that the water

leg pressure had not been taken into account as required by procedure.

Due to.this error the 1A CA pump would not have automatically realigned

suction to service water on low suction pressure. This made the 1A CA

pump technically inoperable from February 15,1983 to May 9, 1987. TS , 3.7.1.2 requires that with one auxiliary feedwater pump inoperable,

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restore the required CA pump to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in

at least not standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and hot shutdown within the

following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The faiiure to properly calibrate the 1A CA pump

pressure switch is identified as a Licensee Identified Violation (LIV

369/88-12-01) for exceeding TS 3.7.1.2. Other 1A pressure switches were

verified to be correctly calibrated and appropriate personnel were

retrained emphasizing inclusion of .vator legs in calibrations.

9. Turbine Driven Auxiliary Feedwater Pump Trip Followup

On May 2, 1988, the Unit 1 TDCA pump tripped for an unknown reason as

described in paragraph 4.a of this report. The licensee initiated an

Incident Investigation Report to evaluate the pump start and trip. In

following up on this occurrence the inspectors reviewed the event;

reviewed a recent Problem Investigation Report (PIR-0-M88-0089) written on

existing _ and potential deficiencies with the Unit 1 and Unit 2 TDCA

overspeed trip devices; reviewed performance test PT/1/A/4252-01,

Auxiliary Feedwater Pump Number 1 Performance Test; and observed

performance of PT/1/A/4252-01.

a. Previous Problem Investigation Report Review

Problem Investigation Report PIR-0-M88-0089 was written to document

a broken tappet on.the Unit 2 TDCA overspeed trip device and identify

a question as to the amount of contact area between the emergency

head lever and the tappet nut. Insufficient contact area may cause

an unnecessary overspeed trip of the TOCA pump. The potential

overlap problem was identified by the licensee when evaluating INPO

"Operations and Maintens,ce Reminder (0 & MR-316)" on defective head

levers. The licensee in1.iated work requests to verify the amount of

contact area during the next outages since disassembly of the

overspeed trip mechanism s required to measure the contact area and

the - licensee does not wish to undertake this job during unit

operation. An operability determination was performed which

concluded that the TDCA pumps were operable. A review of the

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operability determination revealed; however, that a regular shift SRO

I was not listed as one of the persons involved in the determination.

In a response dated May 29, 1987, to violation 87-04-01 issued on

April 29, 1987, the licensee stated that "Training and staff licensed

personnel are no longer permitted to make an operability deter-

l mination. Operability determinations by training instructors and

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staff SR0's must be made with the concurrence of a regular shift

SR0". On,y a staff SRO was listed as being involved with the

operability determination. The licensee stated that the statement in

the May 29, 1987, response was not intended to apply to all

operability determinations but only those made by training and staff

SR0's when they are performing a shift duty to maintain active

licensed status. The licensee also stated that operability

determinations done by engineering, design or othee groups do not

necessarily involve operations in the decision making. Licensee

management acknowledged the Deviation during the exit interview and

agreed to revise the committment since it was not originally intended

to apply to all situations.

The staff SRO involved with making the operability determination was

unaware-of the commitment the licensee made to obtain a regular shift

SR0 concurrence for operability determinations. The response dated

May 29, 1987, stated that the actions in this area would be completed

by March 1,1987, and the licensee had previously stated that all

corrective actions taken in response to this event had been

completed. When the licensee was asked for the documentation for

completion of this corrective action none was available. The

licensee stated that no internal corrective action or tracking

documentation is initiated when a corrective action is completed

prior to issuing the response to a violation. This practice led to a

failure to follow through with a NRC commitment and is an apparant

deviation (DEV-369,370/88-12-02).

The operability determination done to address the issues raised in

PIR-0-M88-0089 concernina the contact area between the emergency head

lever and the tappet nut did not contain a technical discussion of

why the concern raised does not prevent the component from fulfilling

its intended safety function. Station Directive 2.8.2 Attachment 1

paragraph 8 specifies the requirements for justification of

operability determinations. The coerability determination stated

that:

(1) McGuire SA Turbines require 0.030 to 0.060 inch (contact area)

with an overall minimum available contact area of 0.G78 inch to

allow for adjustment.

(2) Work Requests (non-emergency) would be written to verify the

amount of contact area that exists.

(3) There is no feasible way to accurately determine the amount of

' contact area without disassembly of the overspeed trip

mechan lsm.

(4) All affected procedures would be changed to reflect this

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( These items do not constitute a technical discussion of why the TDCA

pump is operable with questionable contact area between the emergency

head lever and the tappet nut as required by Station Directive 2.8.2.

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' 'E The failure to perform the evaluation correctly as required by-

Station Directive '2.8;.2 is an apparent violation (369,370/88-12-03)

, for failure. follow procedure.

When the inspector discussed this shortcoming with the licensee a

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revision to the operability determination was- initiated. The

revi; ion stated, in part, that monthly testing uof these components

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(TDCA pumps) . assures the operability of _the turbines and thu

l functional capacity of the overspeed trip mechanism. Also, on

July 7, 1982, operations. conducted a satisfactory overspeed trip test

on the Unit 2 turbine but documentation for the Unit 1 overspeed test

could'not be located.

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It is noted.that personnel involved with identifying the concern with

the contact area and following through with evaluating the potential

-problem' should be commended. The NRC encourages the practice of

identifying operability concerns and documenting operability

evaluations, however the operability evaluation documentation in this

case was not adequate.

'b. Review of Test Procedure PT/1/A/4252/01

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During review of the monthly performance test of the TDCA pump

-(PT-1-A-4252-01) concerns were identified by the inspector relating

'to preparations for the test and acceptance criteria. In preparation

for the test the steam lines are drained of any. condensate by cycling

valves 1SA-39 and .1SA-40 and therefore changing the as found

condition. This practice may mask a possible problem with condensate

remaining in the steam lines. This concern was brought to the

attention of the licensee and the licensee committed to re-evaluate

'the practice of blowiag down the steam lines prior to monthly

testing. IE Information Notice 86-14 described situations where

condensate in the steam lines led to overspeed trips of auxiliary

feed water pump turbines at other facilities. ,

10 CFR 50, Appendix B, Criterion XI, requires that a test program

shall be established to assure that all testing r luired to

demonstrate that systems and components will perform satisfactorily

in service is identified and performed in accordance with written

test procedures. The tesc program established to demonstrate that the i

turbine driven auxiliary feedwater pumps will perform satisfactory in

service was inadequate. The procedure used to test the pumps does

not perform the test in the as found condition in that the steam

lines to the pump turbine are drained of condensate prior to testing.

This is an apparent violation (369,370/88-12-04).

The acceptance criteria for PT/1/A/4252/01 was compared to the values

required by ASME Section XI IWP based on the baseline or reference

readings obtained in TT/1/A/9100/41, Auxiliary Feedwater Pump #1

Baseline Test. The acceptance criteria for pump bearing horizontal

vibration was incorrect based on the IWP requirements. The

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"Acceptable Range" would have been less than 1.6 Mils rather than 1.0

Mils specified. The "Alert Range" . should have specified 1.6 to 2.4

Mils rather than 2.0- to 3.0 Mils and the "Required Action Range"

should have specified greater than 2.4 Mils rather than greater than-

3.0- Mil s. It is noted that the acceptable range was more

conservative than required however the ."alert" and "required. action"

criteria was less conservative. Previous test results were reviewed

by the inspector to verify that test results and actions taken were

sa ti sf actory. The licensee initiated a change to this PT and was in

the process of reviewing other PT's to ensure that the acceptance

, criteria was properly specified. _

T.S. 6.8.1 states that written procedures shall be established,

implemented, and maintained covering the procedures recommended in

Aopendix A of Regulatory Guide 1.33, Revision 2, February 1978

including surveillance tests of the auxiliary feedwater system. T.S.

4.0.5 requires that inse.vice testing of ASME Code Class 1, 2, and 3

pumps shall Hbe performed in accordance with Section XI of the ASME

Boiler and Pressure Vessel Code as required by 10 CFR 50, Section

50.55a(g).Section XI of the ASME Boiler and Pressure Vessel Code,

1980 Edition,- Subsection IWP, Article IWP-3000, Inservice Test

Procedures, Table IWP-3100-2, Allowable Ranges of Test Quantities,

specifies vibration ranges to be used to determine if inservice test

results are acceptable or if actions are required. Procedure

PT/1/A/4252/01 was inadequate in that horizontal vibration ranges did

not meet- the requirements of ASME Section XI. This is a second

example of apparent violation (369,370/88-12-03).

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c. Observation of Test Procedure PT/1/A/4252/01 Performance

Portions of the performance of PT/1/A/4252/01 on May 9, 1988, were

witnessed by the inspector. The personnel performing the test were

not aware that the acceptance criteria for horizontal vibration was

in error although this error was brought to the attention of the

licensee of May 6, 1988. A change had been initiated at that time

however the information was not communicated to personnel performing

the test. Test results were satisfactory.

10. . Automatic Realignment of Auxiliary Feedwater Suction

On May 12, 1988, the Unit 2 Auxiliary Feedwater (CA) Pump B was being

restored to service following oil sampling and suction check valve

inspection when the CA supply valves from Nuclear Service Water (RN)

opened on low B CA pump suction pressure. The pump was not running and no

service water reached the steam generators.

RN to CA supply is the assured makeup to the steam generators. The valves

from the RN system open on low suction pressure to align the assured

supply in the event of a loss of normal CA supply from the upper surge

tank, condenser hotwell, and CA storage tank. The RN to CA valves 2CA-188

and 2RN-1628 opened on low suction pressure because the Removal and

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Restoration- (R ~and R) procedure was performed out of sequence. The-

t' section valve.to the B CA pump.was required to be opened prior to closing

tne breakers to energize 2CA-188 and 2RN-1628 but the operator did not

' follow the~R and R procedure in that'he closed the breakers before opening

the suct on valve. This -' caused. 2CA-18B and 2RN-1628 to open on low

suction p, essure.

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The licensee isolated 'the lines, drained the service water from the CA

lines, and restored the system to normal . Station Directive 3.1.19,

Safety Tags, paragraph 7.4.4, step 2 states that tag removal shall be done

in the designated. sequence. The R and R record sheet specifies the

required sequence. The failure to follow the Station Directive Procedure,

R and R, sequence is another example of apparent violation

(369/370/88-12-03).

11. Inadvertent ESF Actuation

At 6:55 p.m. on the evening of May 19, 1988, during the performance of a

diesel-~ generator 18 load sequence test (PT/1/A/4350/048), licensee

personnel failed to perform certain actions' required by the' procedure

which resulted in an inadvertent engineered safety features (ESF)

actuation.

Step 12.9 of PT/1/A/4350/048, D/G 1B Load Sequence Test, required that-the

performance technician who was physically at the local panel, have

operations reset the load sequencer. This did not occur. The technician

proceeded to perform step 12.10 which in essence took the sequencer out of

The technician then detected that a local indicator , light did not

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reflect that the sequencer had been reset. He in turn called the control

room to have operations reset the sequencer, which they did. .bince the

!- blocks ' inserted by the test switch had been removed in step 12.10,

resetting the sequencer resulted in the inadvertent actuation of train 8

of auxiliary feedwater (CA), train 8 of nuclear service water (RN) and

train-B of control room ventilation (VC). Failing to perform the

requirements as stateo in the procedure constitutes a fourth example of

apparent violation (369,370/88-12-03).

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