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Insp Repts 50-348/86-29 & 50-364/86-29 on 861211-870110. Violations Noted:Procedural & Tech Spec Errors Resulted in Disabled RHR Sys Isolation Circuitry
	ML20210C524
Person / Time
Site:	Farley
Issue date:	01/30/1987
From:	Brian Bonser, Bradford W, Dance H; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20210C462	List: IR 05000348/1986029; ML20210C458; ML20210C524;
References
	50-348-86-29, 50-364-86-29, NUDOCS 8702090406
	Download: ML20210C524 (7)
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Report Nos.: 50-348/86-29 and 50-364/86-29

Licensee: Alabama Power Company

600 North 18th Street

Birmingham, AL 35291

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8

Facility Name: Farley 1 and 2

Inspection Condu ted: December 11, 1986 - January 10, 1987

Inspectors: ht / ?a [87

O' ate Signed

W.~ H. BradfoFd [

B'. R .

(nser' W / 30 Y

D' ate Signed

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Approved by: [W

H. C. Dance, Sec' tion Chief

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Da'te~ Signed

Division of Reactor Projects

SUMMARY

Scope: This routine, unannounced inspection included: monthly surveillance

observation, monthly maintenance observation, operational safety verification,

followup of plant events, engineered safety system inspection,- and RHR system

isolation capability.

Results: Two violations were identified as a result of procedural and technical

specification errors that resulted in disabling of the residual heat removal

system isolation circuitry (Paragraph 9).

8702090406 8702O2,

PDR ADOCK 05000348

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

J. D. Woodard, General Plant Manager

D. N. Morey, Assistant General Plant Manager

W. D. Shipman, Assistant General Plant Manager

R. D. Hill, Operations Manager

C. D. Nesbitt, Technical Manager

R. G. Berryhill, Systems Performance and Planning Manager

L. A. Ward, Maintenance Manager

B. Moore, Operations Supervisor

J. E. Odom, Operations Unit Supervisor

B. W. Vanlandingham, Operations Unit Supervisor

T. H. Esteve, Planning Supervisor

J. B. Hudspeth, Document Control Supervisor

L. K. Jones, Material Supervisor

R. H. Marlow, Technical Supervisor

L. M. Stinson, Plant Modification Manager

J. K. Osterholtz, Supervisor, Safety audit Engineering Review

Other licensee employees contacted included technicians, operations

personnel, maintenance and I&C personnel, security force members, and office

personnel.

2. Exit Interview

The inspection scope and findings were summarized during management

l interviews throughout the report period and on January 12, 1987, with the

general plant manager and selected members of his staff. The inspection

findings were discussed in detail. The licensee did not identify as

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

during this inspection. Two violations identified in paragraph 9 will be

! discussed further in an Enforcement Conference on February 10, 1987.

3. Licensee Action on Previous Enforcement Matters (92702)

Not inspected.

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l 4. Monthly Surveillance Observation (61726)

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l The inspectors observed and reviewed Technical Specification required

l surveillance testing and verified that testing was performed in accordance

l with adequate procedures; that test instrumentation was calibrated; that

limiting conditions were met; that test results met acceptance criteria and

were reviewed by personnel other than the individual directing the test;

that any deficiencies identified during the testing were properly reviewed

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and resolved by appropriate management personnel; and that personnel

conducting the tests were qualified. The inspector witnessed / reviewed

portions of the following test activities.

FNP-2-STP-33.0B -

Solid State Protection System Train B Operability

Test

FNP-1-STP-41.3 -

Power Range Functional Test N-43

FNP-2-STP-23.9 -

CCW Pump 2A Monthly Operability Check

FNP-2-STP-22.16 -

TDAFW Pump In Service Test (TAVG 547 F)

No violations or deviations were identified.

5. Monthly Maintenance Observation (62703)

Station maintenance activities of safety-related systems and components were

observed / reviewed to ascertain that they were conducted in accordance with

approved procedures, regulatory guides, industry codes and standards, and

were in conformance with technical specifications.

The following items were considered during the review: limiting conditions

for operations were met while components or systems were removed from

service; approvals were obtained prior to initiating the work; activities

were accomplished using approved procedures and were inspected as

applicable; functional testing and/or calibrations were performed prior to

returning components or systems to service; quality control records were

maintained; activities were accomplished by qualified personne!. parts and

materials were properly certified; radiological controls were implemented;

and fire prevention controls were implemented. Work requests were reviewed

to determine the status of outstanding jobs to assure that priority was

assigned to safety-related equipment maintenance which may affect system

performance.

Calibration of various instrumentation was observed in the control room and

throughout the plant during the inspection period.

No violations or deviations were identified.

6. Operational Safety Verification (71707)

< The inspectors observed control room operations, reviewed applicable logs

and conducted discussions with control room operations during the report

period. The inspectors verified the operability of selected emergency

systems, reviewed tagout records, and verified proper return to service of

affected components. Tours of the auxiliary building, diesel building,

turbine building and service water structure were conducted to observe plant

equipment conditions, including fluid leaks and excessive vibrations. The

inspector verified compliance with selected Limiting Conditions for

Operations (LCO) and results of selected surveillance tests. The

verifications were accomplished by direct observation of monitoring

instrumentation, valve positions, switch positions, accessible hydraulic

inubbers, and review of completed logs, records, and chemistry results. The

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licensee's compliance with LC0 action statements were reviewed as events

occurred.

The inspectors routinely attended meetings with certain licensee management

and observed various shift turnovers between shift supervisor, shift

foreman, and licensed operators. These meetings and discussions provided a

daily status of plant operations, maintenance, and testing activities in

progress, as well as discussions of significant problems.

The inspector verified by observation and interviews with security force

members that measures taken to assure the physical protection of the

facility met current requirements. Areas inspected included the

organization of the security force; the establishment and maintenance of

gates, doors, and isolation zones; that access control and badging were

proper; and procedures were followed.

No violations or deviations were identified.

7. Followup of Plant Events (93702)

On January 8, 1987, at 6:35 a.m., Unit 1 tripped from 100% power. The

reactor operator observed indication on the control board that Main Steam

Isolation Valve (MSIV) 3370A had moved off of its full open position. A

quick local investigation by the Unit 1 Shift Foreman revealed an air leak

on the fitting to the valve operator. The operator tripped the turbine

manually which automatically tripped the reactor. All systems functioned as

designed. The air line fitting was repaired and all MSIVs were inspected.

The reactor was brought critical at 1:30 p.m., this same date.

On January 9,1987, at 9:34 a.m. , Unit 1 tripped from 27% power due to low

, steam generator level trip. The low steam generator level trip was preceded

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by automatic tripping of "A" and "B" main turbine driven feed wager pumps on

low suction pressure. All systems functioned as designed.

No violations or deviations were identified.

8. Engineered Safety Systems Inspection (71710)

The inspectors performed various system inspections during the inspection

period. Overall plant conditions were assessed with particular attention to

equipment condition, radiological controls, security, safety, adherence to

technical specification requirements, systems valve alignment, and locked

valve verification. Major components were checked for leakage and any

general conditions that would degrade performance or prevent fulfillment of

functional requirements. The inspectors verified that approved procedures

and up-to-date drawings were used.

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Portions of the following systems were observed for proper operation, valve

alignment and valve verification:

Auxiliary feedwater system

Chemical volume control systems

Service water systems

Boric acid transfer systems

Containment spray system including chemical additive systems

Residual heat removal system

No violations or deviations were identified.

9. RHR System Isolation Capability

During the Unit I refueling outage beginning October 3,1986, Plant Change

Notice (PCN) B-84-1-2753 was completed on RCS wide range pressure

transmitters (PT) 402 and PT-403. This design change provided adequate

physical separation to satisfy the requirements of Reg. Guide 1.97.

On October 13, 1986, Maintenance Work Requests (MWR) were released to carry

out the change to the transmitters. MWR 141322 and 141323 were assigned to

the Electrical Craft and the PCN was to be completed under these MWRs.

MWR 141324 was assigned to I&C and was to accomplish the testing and

restoration of the pressure transmitters. MWRs originally assigned to

Electrical Maintenance (EM) for completion were reassigned to I&C due to

work load. Prior to beginning the change, and as a precautionary measure,

I&C technicians installed jumpers on PT 402 and 403 to prevent the

inadvertent closing of the RHR loop suction valves. These jumpers were

installed using the initial steps of STP 201.16 and STP 201.17 which was

attached to MWR 141324. These jumpers effectively caused the RHR automatic

isolation capability to be inoperable.

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The jumpers were not removed when the PCN was completed. MWR 141322 and

i 141323 were sent to the I&C foreman for review. During his review of

! STP 201.16 and STP 201.17 he failed to observe the documentation that the

jumpers were installed. The STPs were voided on the cover sheet and the

l body of the procedures was discarded. The jumpers remained in place because

no formal mechanism remained to ensure that the jumpers would be removed.

On October 30, 1986, MWR 141324 was initiated to perform test and

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restoration of PT 402 and 403. This required the use of STP 201.16 and

201.17. When the I&C craftsman started to install the required jumpers in

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the Solid State Protection System, he found the jumpers already installed.

i He consulted the I&C foreman and was directed to proceed with the work in

accordance with the specified procedures. There was no investigation as to

why jumpers were already installed. The test and restoration STPs were

performed successfully and the jumpers placed by these STPs were removed,

leaving the first set of jumpers installed. Operations personnel were not

informed that these jumpers were still in place and that the operation of

the RHR system was impaired.

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On November 16, 1986, at 9:42 a.m., during RCS heatup, the RHR loop suction

h valves ~were re-energized as required by procedure. On November 17, 1986, at

- 4:40 p.m., the unit entered operational mode 4 with the loop suction valve -

' automatic i solation capability of both RHR trains inoperable. On-

November 18,1986, at 11:14, the RHR system was secured in accordance with

normal startup procedure and the loop suction isolation valves.were closed.

The unit entered mode 3 at 11:44 p.m., on November 18, 1986, and remained in

this Mode until November 20, 1986, at 3:42 a.m., when Mode 4 was entered.

Mode 5 was entered on 9:42 a.m., on the same day.

The ' RHR ' system train A and B was. rendered inoperable when the jumpers were

placed on PT 402 and PT.403 as delineated by Technical Specification 1.18.

The plant was technically in a Limiting Condition of Operation (LCO) even

though this ECCS system was capable of performing its intended function of

Icw pressure injection into the reactor coolant system if required.

The RHR loop suction isolation capability was-inoperable from 4:40 p.m., on

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November 17, 1986, until 9:42 a.m. , on November 20, 1986; a total of 65

hours and 2 minutes. The licensee issued Licensee Event Report (348/86-022)

' to describe the sequence of events.

[ There were two instances when the jumpers should have been found. In the

, first instance, an inadequate review was conducted on the MWRs (141322 and

_ 141323) and the attached STPs (201.16 and 201.17) which indicated .that -

jumpers.had been installed and not removed. The second instance occurred

when the I&C Technicians did find and report the jumpers to their foreman

and no investigation was initiated.

L Quality control measures were not met in that section 3.0 of AP-31 " Quality

Control Measures" requires that the first line supervisor (foreman) always

has the primary responsibility for controlling the quality of work performed

by those over whom he has supervisory responsibility.

I 10 CFR 50.59 requires a safety evaluation to be performed prior to making

safety system modifications. Technical Specification 6.8.1 requires

! procedures to be established and followed. Administrative Procedure

. (AP) 52, Equipment Status Control and Maintenance Authorization, implements

TS 6.8.1 and requires that work will be performed in accordance with the

l specified work sequence on the MWR. Contrary to these requirements, on

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October 13, 1986, electrical jumpers were installed on the RHR isolation

l circuitry without having the work specified on MWR 141322 and 141323 and

without performing a safety evaluation. Consequently, the electrical

jumpers were not controlled. This is a violation (348/86-29-01).

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TS 3.0.4 prohibits entry into an operational Mode unless the conditions of

the Limiting Conditions of Operation (LCO) are met without the reliance on

provisions contained in the Action requirements. TS 3.0.3 requires that

when an LCO is not met, that within one hour, action shall be initiated to

place the Unit in a Mode in which the specification does not apply by

placing it, as applicable, in: at least Hot Standby within the next 6

hours, at least Hot Shutdown within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and at least Cold

Shutdown within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . TS 3.5.3 requires one Emergency

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Core Cooling System (ECCS) subsystem to be operable in Mode 4. TS 3.5.2

requires two independent ECCS subsystems shall be operable in Mode 3.

Contrary to these requirements: 1) the Unit entered Mode 4 on November 17,

1986, at 4:40 p.m. and Mode 3 on November 18, at 11:44 p.m., with neither

ECCS subsystem operable; 2) after entering Mode 3, the unit was not placed

in Hot Shutdown within seven hours and Cold Shutdown within the subsequent

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This is a violation (348/86-29-02).

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ML20210C524

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