ML20205D442

Insp Rept 50-416/86-20 on 860613-0714.Violation Noted: Surveillance Procedure Inadequate Due to Isolation Valves Not Required to Be Restored to Locked Open Position & Failure to Follow Temporary Alteration Procedures

ML20205D442
Person / Time
Site:	Grand Gulf
Issue date:	07/25/1986
From:	Butcher R, Dance H, Will Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205D439	List: ML20205D437 ML20205D440 ML20205D442
References
50-416-86-20, TAC-57619, NUDOCS 8608180041
Download: ML20205D442 (11)

See also: IR 05000416/1986020

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. UNITED STATES

fgmif709'o NUCLEAR REGULATORY COMMISSION

[" n REGION ll

3 j 101 MARIETTA STREET, N.W.

• 2 ATLANTA. GEORGI A 30323

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Report No.: 50-416/86-20 -

Licensee: Mississippi Power and Light Company

Jackson, MS 39205

,_ Docket No.: 50-416 License No.: NPF-29

Facility Name: Grand Gulf Nuclear Station'(GGNS)

Inspection Conducted: June 13 - July 14,1986 -

Inspect s:

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R. C. Bdtcher, Senior Resident Inspector Date Si ned

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W.F. Smith, Resident-th'spector

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Date S'igned

Approved by: sMt , 7 2.1 b

H. C. Dance,'Section Chief Ofte Signed

Division of Reactor Projects

SUMMARY

Scope: This routine inspection was conducted by the resident inspectors at the

site in the areas of Licensee Action on Previous Enforcement Matters, Operational

Safety Verification, Maintenance Observation, Surveillance Observation, ESF

System Walkdown, Reportable Occurrences, Inspector Followup and Unresolved Items,

Information Meetings with Local:0fficials, Design Changes and Modifications, and

Spent Fuel Storage Racks.

Results: One Violation with two examples were identified: 1) Inadequate

surveillance procedure in that isolation valves were not required to be restored

to'the locked open position; and 2) Failure to follow procedures when initiating

temporary alterations.

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REPORT DETAILS

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1. Licensee Employees Contacted

J. E. Cross, GGNS Site Director

• C. R. Hutchinson, GGNS General Manager

R. F. Rogers, Manager, Unit 1 Projects

1. A. S. McCurdy, Manager, Plant Operations

• J. D.. Bailey, Compliance Superintendent

• M. J. Wright, Manager, Plant Support

• L. F. Daughtery, Compliance Superintendent

D. G. Cupstid, Start-up Supervisor

R. H. McAnuity, Electrical Superintendent

• R. V. Moomaw, Manager, Plant Maintenance

W. P. Harris, Compliance Coordinator

J. L. Robertson, Licensing Superintendent

L. G. Temple,, I & C Superintendent

J. H. Mueller, Mechanical Superintendent

1. J. L. Moore, Vice-President, Corporate Communications

1. L. F. Dale, Director, Nuclear Licensing & Safety

• L. 8. Moulder, Operations Superintendent

NRC Personnel

H.C. Dance, Chief, Projects Section 28, RII

• Attended exit interview

1. Attended local public meeting

2. Exit Interview

The inspection scope and findings were summarized on July 14, 1986, with

those persons indicated in Paragraph 1 above. The licensee did not identify

as proprietary any of the materials provided to or reviewed by the

inspectors during this inspection. The licensee had no comment on the

- following inspection findings:

a. 416/86-20-01, Inspector Followup Item. Wrong location of control rod

drive temperature recorder noted in the UFSAR. (paragraph 4)

b. 416/86-20-02, Inspector Followup Item. Discrepancies noted during

walkdown of the Division III diesel generator. (paragraph 7)

c. 416/86-20-03, Inspector Followup Item. Inability of Division III

diesel generator to accept emergency loading during ten minute shutdown

cycle. (paragraph 9)

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d. 416/86-20-04, Violation. First example: Inadequate surveillance

procedure in that isolation valves were not required to be restored to

the locked open position. (paragraph 11) Second example: Failure to

follow procedures when initiating temporary alterations. (paragraph 11)

e. 416/86-20-05, Inspector Followup Item. Review spent fuel movement

control procedure for adequacy regarding licensee commitments.

(paragraph 12)

3. Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 416/85-33-02. The General Manager issued a letter to all

Superintendents, Supervisors and the Plant Safety Review Committee emphasiz-

ing verbatim compliance with all safety-related procedures.

(Closed) Violation 416/85-22-05. The Electrical Superintendent issued a

letter to Electrical Engineers, Planners & Supervisors defining required

actions to prevent a recurrence of inadequate retest instructions. No

further action is required.

4. Operational Safety Verification (71707)

The inspectors kept themselves informed on a daily basis of the overall

plant status and any significant safety matters related to plant operations.

Daily discussions were held with plant management and various members of the

plant operating staff.

The inspectors made frequent visits to the control room such that it was

visited at least daily when an inspector was on site. Observations included

instrument readings, setpoints and recordings, status of operating systems,

tags and clearances on equipment controls and switches, annunciator alarms,

adherence to limiting conditions for operation, temporary alterations in

effect, daily journals and data sheet entries, control room manning, and

access controls. This inspection activity included numerous informal

discussions with operators and their supervisors.

Weekly, when onsite, selected ESF systems were confirmed operable. The

confirmation is made by verifying the following: Accessible valve flow path

alignment, power supply breaker and fuse status, major component leakage,

lube. cation, cooling and general condition, and instrumentation.

General plant tours were conducted on at least a biweekly basis. Portions

of the control building, turbine building, auxilf ary building and outside

areas were visited.

Observations included safety related tagout verifications shift turnover,

sampling program, housekeeping and general plant conditions, fire protection

equipment, control of activities in progress, radiation protection controls,

i physical security, problem identification systems, and containment

isolation.

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The following comments were noted: An error in the Updated Final Safety

Analysis Report (UFSAR) was noted by the inspectors. Paragraph

4.6.1.1.2.4.2.4, Cooling Water Header, states that the temperature of each

control rod drive is recorded in the control room and excessive temperatures

are annunciated. This statement is in error in that control rod drive

temperatures are recorded on a recorder located on elevation 133 in the

auxiliary building. Excessive temperatures are annunciated in the control

room on panel 680. The licensee was notified of this discrepancy. This

will be followed as inspector followup item 416/86-20-01.

No violations or deviations were identified.

5. Maintenance Observation (62703)

During the report period, the inspector observed portions of the maintenance

activities listed below. The observations included a review of the work

documents for adequacy, adherence to procedure, proper tagouts, adherence to

technical specifications, radiological controls, observation of all or part

of the actual work and/or retesting in progress, specified retest requirements,

and adherence to the appropriate quality controls.

MWO E63826, NSSS Inboard Isolation Reset Switch B21HSM6318.

MWO 163894, Troubleshoot Subloop 2 of HCU B, Operation Erratic.

MWO E64051, DG 12 Tripped During Performance of 06-0P-1P75-M-0002.

No violations or deviations were identified.

6. Surveillance Observation (61726)

The inspector observed the performance of portions of the surveillances

listed below. The observation included a review of the procedure for

technical adequacy, conformance to technical specifications, verification of

test instrument calibration, observation of all or part of the actual

surveillances, removal from service and return to service of the system or

components affected, and review of the data for acceptability based upon the

acceptance criteria.

06-ME-1M23-V-0001, Rev.25, Containment & Drywell Airlock Seal Leak Test.

06-0P-IP41-Q-0005, Rev.25, Standby Service Water System Valve & Pump

Operability Test.

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06-ME-1M61-V-0001, Rev.27, Local Leak Rate Test (M41F034 & M41F035)' .

06-EL-SP64-SA-0002, Rev.23, Diesel Generator Building Deluge System Heat

Detector Functional Test.

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06-IC-1C34-M-0001, Rev.23, Reactor Vessel Water Level High (Level 8) MT/RFPT

Trip Functional Test.

06-0P-1P75-M-001, Rev.29, Standby Diesel Generator (SDG) 11 Functional Test.

No violations or deviations were identified.

7. Engineered Safety Features System Walkdown (71710)

A complete walkdown was conducted on the accessible portions of the High

Pressure Core Spray (HPCS) Diesel Generator. The walkdown consisted of an

inspection and verification, where pessible, of the required system valve

alignment, including valve power available and valve locking, where

required; instrumentation valved in and functioning; electrical and instru-

mentation cabinets free from debris, loose materials, jumpers and evidence

of rodents, and system free from other degrading conditions.

The results of the above inspection were satisfactory; however, the

inspector identified the following minor discrepancies. Each item was

discussed with a member of the licensee's staff.

a. System Operating Instruction (SOI) 04-1-01-P81-1, High Pressure Core

Spray Diesel Generator, Rev. 26, Attachment I valve lineup checksheet

did not have a position specified for the water driven compressor

discharge drain valve, F803. In addition, the descriptions for instru-

ment root valves F036A and F039B were not correct, apparently due to a

recent equipment modification. In all three cases the valves were in

the correct position. The licensee's representative indicated that

these discrepancies would be corrected by a change to the procedure.

b. Three fuel oil day tank instrument root valves, FX001, FX002, and FX003

were on the valve lineup provided by the above SOI, but the valves did

not appear on Pipe and Instrument Diagram (P&ID) M-1093A. According to

the licensee's representative, all valves that appear on the valve

lineup checksheet should also appear on the P&ID, and the licensee

would investigate to ensure this problem does not exist on other

similar drawings.

c. There was a thermometer installed in the A HPCS diesel water jacket

outlet pipe, however it does not appear on the P&ID nor does it appear

to have instrument numbers which assures instrument calibration

tracking. The licensee's representative indicated that he would

investigate.

d. The underground fuel oil storage tank fill and drain valves are located

in a locked, connector pit below grade level. Due to the design of the

cover, the pit was full of water. Valves F009 and F014 were submerged

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and appeared to be extremely corroded. Under these conditions, water

in-leakage to the fuel tank is a possibility and thus the condition

should be corrected. This issue was raised in NRC Inspection Report

50-416/85-28 and is currently open inspector followup item 416/85-28-03.

The licensee is installing new covers on the valve pit to prevent the

entry of water.

e. The 120 volt AC breakers in panel number 12P51 that appear on attach-

ment III electrical lineup checksheet in the above S0I are not labeled

with the same number. The breakers are labelled with small stick-on

paper labels containing two-digit numbers. For example, breaker number

21 is identified on the checksheet as 51-1P25121. Of greatest concern

is the possibility of the labels falling off and someone putting them

back on the wrong breaker. The licensee's representative stated that

there is a program under way which will replace the stick-on labels

with permanent plastic nameplates containing the breaker numbers and

circuit descriptions. The inspectors verified the program to place

permanent nameplates on breakers was in progress,

f. The HPCS diesel High/ Low Jacket water temperature alarm tripped when

there did not appear to be a problem. The operators explained that

there is an overlap between the alarm setpoint and the heater controller

deadband. The licensee's representative indicated that this is under

review and will be corrected.

Resolution and/or correction of the above discrepancies shall be tracked

under inspector followup item 416/86-20-02.

Except for the flooded valve pit described in paragraph 7.d above,

discrepancies found during the previous ESF System walkdown, as identified

in NRC Inspector Report 50-416/85-28, have been corrected.

No violations or deviations were identified.

8. Reportable Occurrences (90712 & 92700)

The below listed event reports were reviewed to determine if the information

provided met the NRC reporting requirements. The determination included

adequacy of event description and corrective action taken or planned,

existence of potential generic problems and the relative safety significance

of each event. Additional inplant reviews and discussions with plant

personnel as appropriate were conducted for the reports indicated by an

asterisk. The event reports were reviewed using the guidance of the general

policy and procedure for NRC enforcement actions.

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The following License Event Reports (LERs) are closed:

LER No. Event Date Event

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• 85-041 October 31, 1985 Operability of the alter-

nate decay heat removal

not demonstrated within

required 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.85-046 December 4, 1985 Isolation valve logic

relay contacts not surveil-

lanced.85-049 December 22, 1985 Inadequate review of

surveillance of valve

isolation times.

• 86-012 April 10, 1986 Failed relay causes

isolation of shutdown

cooling.

• 86-015 August 16, 1986 Non-seismically qualified

relays installed in

control room emergency

filtration system.

• 86-017 April 30, 1986 Inadvertent actuation

of the combustible gas

control system.

LER 86-015 is discussed in Report 416/86-04 and violation 416/86-04-03.

LER 86-017 is discussed in Report 416/86-11 and violation 416/86-11-04.

No violations or deviations were identified.

9. Inspector Followup And Unresolved Items. (92701).

(Closed) Inspector Followup Item 416/85-45-12. The licensee initiated

temporary change notice 25 to System Operating Instruction 04-1-01-P75-1 to

correct the misidentified valves.

(Closed) Inspector Followup Item 416/85-09-02. The licensee revised

Surveillance Procedure 06-EL-1L21-0-0001 to require an annual capacity

discharge test if any battery has reached 85% of the expected service life

for the application or if capacity dropped more than 10% of rated capacity

from its average on "revious performance tests. The licensee revised

Surveillance Procedure 06-EL-1L11-Q-0001 to permit omitting equalizing the

battery if all cell data has been reviewed for the equalizing requirements

of 1EEE-450, 1980 by Maintenance Engineering.

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The inspectors followed up on a deficiency identified at the Watts Bar

nuclear plant which affected the capability of the standby diesel generators

to assume required loads if an emergency start signal is received during the

10 minute engine idle period during the normal shutdown cycle. This

deficiency was issued as Potential Generic Item (PGI) 86-04. The Division

III, HPCS diesel generator control system at GGNS appears to have the same

deficiency. GGNS has a General Motors diesel generator. Procedures specify

after running at the normal synchronous speed of 900 rpm, the HPCS diesel is

normally shutdown to an idle speed of 450 rpm for 10 minutes, thereby

allowing temperatures to level off, after which a timer automatically shuts

the diesel generator completely down. As the speed decreases through 150

rpm, a relay automatically resets the field flashing circuit. Thus, if a

station power failure occurs during the 10 minute cooldown period, the

control circuit will override and bring the diesel back up to 900 rpm but

the field won't flash. The licensee initiated Incident Report (IR) 86-6-10

to document the discrepancy. As immediate corrective action, Temporary

Change Notices (TCN) were issued against System Operating Instruction

04-1-01-P81-1 and Surveillance Procedure 06-0P-1P81-V-0003 directing the

operator, when shutting down the HPCS diesel generator, to manually depress

the voltage shutdown reset pushbutton on panel 1H22-P118 to enable the

generator output breaker to properly close upon receipt of a LOCA signal.

The licensee is investigating possible design changes. This will be

followed as inspector followup item 416/86-20-03.

IE Circular 77-09 discussed a potential fuse coordination problem in the

control system for the Standby Liquid Control (SLC) system. It is possible

to have smaller fuses in the control power circuit than those supplied by

General Electric for the explosive (squib) valves, thus if a squib valve

fires and short circuits, the main control power fuses could blow first and

control power for the system would be lost. The inspectors followed up to

assess the fuse configuration at GGNS, and found no problems. GGNS utilizes

5.6 ampere slow-blow fuses in the control power circuit with 2.0 ampere

slow-blow fuses on the squib valves. In addition, the circuit contains 40

ohm current limiting resistors so that if a short circuit was caused by the

squib valves, the circuit load would not exceed 3 amperes. This is

sufficient to blow the squib valve fuses, but not enough to blow the control

power fuses.

No violations or deviations were identified.

10. Information Meetings With Local Officials (94600).

On June 12, 1986 the resident inspectors and Mr. H. Dance, NRC RII Section

Chief, attended a meeting at the Claiborne County Courthouse. This meeting

was organized by Mr. A.C. Garner, Port Gibson/Claiborne County Civil Defense

Director, to answer local citizens questions regarding the recent nuclear

accident at the Chernobyl nuclear site in the Soviet Union. Other groups

represented at this meeting were the Mississippi Power and Light Company

(MP&L), Mississippi Emergency Management Agency and the Mississippi State

Department of Health. The MP&L representatives presented known differences

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in the design of the Chernobyl nuclear plaat and the Grand Gulf nuclear

plant and explained how the two technologies were different. The meeting

was then opened to questions from the public. The meeting appeared to have

satisfied the public's questions regarding the possibility of a similar

event occurring at GGNS.

11. Design, Design Changes and Modifications (37700)

The inspectors reviewed Design Change Implementation Package (DCIP) 86/4017

which moaified the control room chlorine detection sample pump piping to aid

the sample pump in drawing a sample. Material Non-Conformance Report (MNCR)

301-86 was written to document that the control room Heating, Ventilating

and Air Conditioning (HVAC) chlorine detectors could not draw an adequate

sample of air as presently designed because the HVAC duct static pressure

was lower than the sample fan was capable of pulling. The original design

of the chlorine detection system had the sample pump suction off the control

room HVAC fan inlet duct and the sample pump discharge was routed to the

safeguard switchgear & battery rooms ventilation system duct. Due to the

low static pressure in the control room HVAC duct the sample pump was not

capable of drawing an adequate sample. The DCIP incorporated isolation

valves in the inlet piping to the sample pump suction to provide for

calibration of the chlorine detectors and the outlet piping from the sample

pump was routed directly back into the control room HVAC duct downstream of

the sample pump inlet piping. The design change had been reviewed and

approved by the appropriate personnel, a safety evaluation had been'

performed and drawing changes had been incorporated. Drawing M-0049,

Control Room HVAC System had been revised to reflect the added isolation

valves Z51F079 and Z51F080 which are shown as locked open valves. The

System Operating Instruction (SOI) 04-S-01-Z51-1, Control Room HVAC System,

specifies Z51F079 and Z51F080 are to be locked open but Surveillance

Procedure 06-IC-SZ51-SA-0001, Chlorine Detector Calibration, specifies only

that valves Z51F079 and Z51F080 are to be opened. On June 30, 1986 the

inspector checked isolation valves Z51F079 and Z51F080 and found them

unlocked in the open position. Technical Specification 6.8.1 requires that

the applicable procedures recommended in Appendix A of Regulatory Guide

1.33, Revision 2, 1978 be established, implemented and maintained. Appendix A

of Regulatory Guide 1.33 states that safety-related system procedures

should include instructions for the operation of control room heating and

ventilation systems. Surveillance Procedure 06-IC-SZ51-SA-0001 was

inadequate in that it did not require locking open valves Z51F079 and

Z51F080 as specified by drawing M-0049. This is the first example of

violation 416/86-20-04. (See also paragraph below). The inspector noted

that the heat tracing on some portions of the chlorine sample piping was

pulled away from the pipe and held with tape. Also, the room with the HVAC

duct and chlorine detector ASWO40B had water on the floor, possibly from a

recent rain shower. The Itcensee was notified of the noted discrepancies

and initiated corrective action. It was noted that the test connection for

chlorine detector ASN0408 was located upstream of temperature element TE

NO388 rather than downstream of TE N0388 as shown on drawing M-0049.

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The . inspectors reviewed the licensee's temporary alteration controls.

Administrative Procedure (AP) 01-S-06-3, Control of Temporary Alterations,

requires that each temporary alteration request be screened for safety /

environmental evaluation applicability and be reviewed by the Operations

Superintendent for proper evaluation, determination for actual need, and

applicability. Paragraph 6.1.6 states the Shif t Superintendent must review

the temporary alteration request form and approve by signature. Also, he

must issue jumpers as required, make required entries in the jumper log and

enter alteration number and information in the temporary alteration log

index. The original form is to be placed in the temporary alteration log

book. The installation of all temporary alterations must be independently

verified except the ALARA committee may recommend otherwise to minimize

personnel exposure. A review of the licensee's temporary alteration logs

revealed the following discrepancies:

a. Temporary alteration 84-0016 had jumpers 14, 17 and 20 listed on the

temporary alteration request form (attachment 1 to AP 01-S-06-3). The

jumper log (attachment III to AP 01-S-06-3) did not list jumpers 14,

17 and 20 as active. A review of the installation of temporary

alteration 84-0016 revealed that jumpers 14, 17 and 20 were actually

installed. The jumper log failed to list the jumpers.

b. Temporary alteration 86-0020 lists jumpers J246 and J247. The jumper

log lists jumper J246 as installed for temporary alteration 86-0020 and

jumper J247 as installed for temporary alteration 86-0023. A review of

temporary alteration 86-0023 showed no jumpers were initiated and the

jumper log was in error.

c. The temporary alteration request form for temporary alteration 86-0017

had the Operations Assistant signature completed for the notification

of the restoration for any required procedure changes (block 25). AP

01-S-06-3, Rev.17, paragraph 6.3.6 states the Operations Assistant

will notify the Manager, Plant Maintenance and Manager, Plant Operation

of restoration of the temporary alteration and then sign block 25.

This signature should not have been completed until restoration of the

temporary alteration was complete,

d. Temporary alteration 85-0005 has entries for given tag numbers that

fail to identify the type alteration as attachment 1 to AP 01-S-06-3

calls for. Also, under the location and description columns of

attachment 1, additional attachments to the temporary alteration

request form is referenced. The attachments to the temporary

alteration request form have several entries (approximately 20)

described as " add wire" which are actually jumpers. No jumper

identification was made and there were no entries in the jumper log.

e. AP 01-S-06-3, paragraph 6.1.6 states that the Shif t Superintendent or

designee shall issue jumpers as required and make required entries in

the jumper log (attachment III). The procedure does not specify how

the Shift Superintendent is to assign numbers for jumpers. The jumper

log reflects this lack of direction by use of different types of

numbers which are derived by each individual involved in issuing the

temporary alteration.

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Technical Specification 6.8.1 requires that the written procedures

recommended in appendix A of Regulatory Guide 1.33, Revision 2,1978 be

established, implemented and maintained. RG 1.33 recommends procedures for

the bypass of safety functions and jumper control. The failure to follow

procedures as noted in discrepancies a, b, c, and d is a violation. This

will be identified as the second example of violation 416/86-20-04 (see also

paragraph above).

12. Spent Fuel Storage Racks (50095)

Three Design Change Packages (DCPs) were associated with the removal of Low

Density Fuel Storage Racks (LDFSR) and the installation of High Density Fuel

Storage Racks (HDFSR). DCP 84/4038 provided instructions for the removal of

the LDFSR,and DCP 84/4048 provided for the installation of the HDFSR in the

auxiliary building spent fuel pool. DCP 84/4049 provided for the removal of

the existing LDFSR and the installation of the HDFSR in the upper containment

pool. The HDFSR were designed and manufactured by the Joseph Oat Corporation.

The HDFSR installed in the upper containment pool will hold 800 spent fuel

assemblies and the HDFSR installed in the auxiliary spent fuel pool will

hold 4348 spent fuel assemblies. The review of procurement documents,

receipt inspection procedures and findings was satisfactory. The removal

and installation instructions were complete and thorough. During the Fall

1985 outage, the inspectors witnessed portions of the installation of the

HDFSR in the upper containment pool and the auxiliary building, discussed

the installation with licensee personnel and observed that approved

procedures and drawings were available and utilized. The poison plates

were examined and confirmed to be properly identified. Quality assurance

personnel closely followed the modification. A review of several nonconfor-

mance reports indicate proper review and dispositioning. The dummy fuel

element test for adequate clearances indicated that several cells were

not adequate for fuel storage and these cells will be controlled adminis-

tratively. When the adequacy of the marking of the poison specimen coupons

was questioned, a change notice was issued requiring the coupon identification

number be ','ibra Etched to ensure durable identification of each coupon.

This change notice also identified cell number Z-29 in rack A5 as the

acceptable location for the poison specimen assembly. Although the HDFSR

have been installed, there have been several meetings and correspondence

between the licensee and NRR regarding the adequacy of the existing spent

fuel pool cooling systems, the level of radiation adjacent to spent fuel

pool walls, spent fuel storage pool maximum temperature and other issues.

The licensee has proposed TS changes to define these limits and adminis-

trative controls, which are not yet released, will be contained in Procedure

09-S-02-300, SNM Movement Control. The inspectors will review this procedure

for adequacy when available. This will be identified as inspector followup

item 416/86-20-05.

No violations or deviations were identified.

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