IR 05000369/1992028

Insp Repts 50-369/92-28 & 50-370/92-28 on 921115-1219. Violations Noted.Major Areas Inspected:Plant Operations, Surveillance Testing & Maint Observations

ML20127P759
Person / Time
Site:	Mcguire, McGuire
Issue date:	01/12/1993
From:	Belisle G, Cooper T, Vandoorn P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127P706	List: IR 05000369/1992028 ML20127P702 ML20127P733
References
50-369-92-28, 50-370-92-28, NUDOCS 9302020067
Download: ML20127P759 (11)

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4 hy UfolTto STATE S J,, tdUcLEAH HEGULATORY COMMISSION

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Report Nos, 50-369/92-28 and 50-370/92-28 Licensee: Dulce Power Company 422 South Church Street Charlotte, NC 28201-1007 '

facility Game: McGuire Nuclear Station 1 and 2 Cacket Nos, 50-369 and 50-370 License Nos. NPF-9 and NPF-17 *

Inspection Conducted: November 15, "92 - December 19, 1992

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Inspectar: g / %/ $,.

Gc // , jP. K, 'Tanf corn, nt jdlor spector- Re[k) e signcd  ;

Inspector:

T~E fo'[eWTe~sT, insp2ctoHeng- 2/f!r

'h[te signed Approvod by:

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t NGE 9../fu{' ( /hd. 73 CDe~lnlo, SFH6 C(liie? -

~Date Sighed i Division _of Reactor Projects

i SUMMARY-Scope: This routine, resident inspection was conducted in the areas.of  ;

plant operatio_ns, surveillance testing, maintenance obervations, Licensee Event Report followup, followup on prov.Ious' inspection-findings, preparation for. cold weather, connerciall grade material dedication, and evaluation of licensee self-assessment capability.

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Results: In -tha areas _ inspected, one: cited violation and one.non-cited violation- were identified. The cited violation involved the ]

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failure to adequately perform a root cause analysis andidevelop necessary corrective actions for a Problem Investigation.' Report as required by a station directive.(paragraph 7,b). lThe non-cited violation involved failure to consider instrument' error in the 2 design of the auxiliary feedwater suction supply valve pressure

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switches (paragraph 6).

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REPORT DETAILS- Person _$_Contac ted .

licenseAJ,mployees  !

[ D. Baxter A. Beaver Support Operations Manager Operations Manage .

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J. Boyle Work Control Superintendent R. Branch Maintenance General Supervisor 0.~ Bumgardner Unit 1 Operations Managf.,r-  :

• B. Caldwell Training Manager T. Curtis System Engineering Manage J. Foster Station Health Physicist F. Fowler Human Resources Manager- '

• Gilbert Sa.foty Assurance Manager p. Guill Compliance Engineer ..

a B. Hamilton Superintendent of 0perations -

B. Hast Emergency Planner ~ '

M. Hatley Component Engineering. Supervisor

• P. Herran Engineering Manager

, L. Kunka Compliance Engineer E. Geddie Station Manager- 3

. T..McHeokin Site Vice President R. Michael Station' Chemist ,

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• T. Pederson Safety Revi% Supervisor N. Pope Instrument '& Electrical Superintendent

. *R. Sharpe Regulatory Compliance Manager B. Travis Component Engineering Manager

'. *R. White Mechanicel Maintenance; Superintendent 4

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Other licensee employees contacted included craft'smen,1 technicians, operators, mechanics,. security force members, and office personne NRC' Resident Inspectorr

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• P. VanDoorn, SRI ',.

• T. Cooper, RI-g * Attended exit interview

.'2., Plant L0perations (71707)) '

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a.- -Observations-

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The inspection' staff reviewed plant < operations.during the report i '

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period to verify confornnce with.aaplicable regulatory.' '.. .

requirements. Control rnom logs,-siift-supervisors' Slogs, shift'

F- turnover records and equipment removal 'and restoration' records ,

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were routinely reviewed. Interviews -were condu' cted with plant operations, maintenance chemistry, health physics, and performance pcrsonne t Activities within the control root (were monitored durihg shifts and at shift enanges. Actions and/or activities observed were .

conducted as prescribed in applicable; station administrative ;

directives. -The complement of licensed' personnel on each shift met or exceeded the minimum required by Technical Specifications (TS). The inspectors also reviewed Problem Investigation Reports (PIRs) to determine whether the Itcensee was' appropriatel documenting problems and imelementing corrective actions. The *

inspectors identified a problem in the PIR are This is discussed in paragraph ,

Plant tours taken during the reporting period included, but were i.et limited to, the turbine buildings,-the auxiliery building, electrical equipment rooms, cable spreading rooms, and.the ' station yard zone inside the protected are During the plant tours, or. going activities, housekeeping, f're protection, security, equipment status and radiation contro practices were observe +

, Unit 1 Operations-The unit begaa the inspection period at 100 percent power and continued to operate at that level except for brief times at reduced power to perform routine testing. At the end of the inspection period, the unit had been nn line for 144 days, a uni recor *

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The unit began the inspection period at 100 percent power and- .

continued to operate at that level:throughout the inspection period.

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No violations or deviations were identified.- m 3. Surveillunce Testing (61726)

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Selected surveillance tests were analyzed .and/or witnessed by the l L resident. inspection staff-to ascertain procedural and performance

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adequacy- and conformance with the applicable TS. -  ;

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Selected tests were witnessed to ascertain that approved procedures wer H a*/allable and in use, that test equipment in use was calibrated, that-test prerequisites were met, that system restotation was complcted and acceptance criteria were me ,

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The selected tests listed below were reviewed or witnessed in detail: PROCM M LOyIPMEtq/TESI PT/0/A/4601/08A Solid State Protection System Train A Periodic Test (Unit 1)

PT/0/A/4457/01A Chilled Water Pump 1A Performance Test PT/1/A/4355/01B Diesel Gencrator IB Sump Pump Performance Test PT/2/A/4204/01A Residual Heat Removal Pump 2A Performance Test PT/1/A/4252/02B Au::iliary Feedwater Valve Stroke Timing -

Quarterly IB Motor Driven Pump Flow Path i'T/2/A/4403/n2A Nuclear Service Water Train A Valve Stroke Timing - Quarterly Unit 2

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PT/0/A/4400/15 Fire Protection Annunciator Functional Test PT/1/A/4250/04A Turbine Valve Movement Test PT/1/A/4600/01 RCCA Movement Test s The inspector noted that the Diesel Generator sump pump failed on h mh flow but upon subsequent re-test, without any other actions, the pump passed. The inspector questioned why this occurred. The licensee indicated that performance may vary slightly due to back-pressure conditions. The test is a cimple flow verification. The licensee ,

indicated that they would consider procedurally requiring throttling the discharge valves to regain flow margi No viohtions or deviations wera identifie . Maintenance Observations (62703)

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! Observalit;n Rcutine maintenance aci.ivities were reviewed and/or witnessed by the resident inspection staff to ascertain procedural and performance adequacy and conformance with the applicable T The selected activities witnessed wem examined to ascertain that, where applicable, current written approved procedures were available and in use, that prerequisites were met, that equipment restoration was comrleted and maintenance results were adequat __ _

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The selected mairitenance activities listed below were reviewed or "

witnessed:in~dothil:

WORK REOKST/_ WORK ORKil MJHH1 92088082 Performante Test on Steam Generator

'0" Steam Line Pressure Transmitter 2HSMt.P5180 ,

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02089508 Perforrr Performance lest f unctional-Test on Intermediate Range Neutron Monitor H36-92095464 Take As-Found Data and Calibrate '1'

Auxiliary-feedwater Suction. Pressure-Switch IMCAP55381 s 92095463- -Take As-Found Data and Calibrate Auxiliary feedwater Suction Pressure Switch 2MCAtP5380 No violations or deviations were identifie ,

,. Use of Commercial Grade Materials in Safety Related Applications The inspector continued tha review of the commercial grade:

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dedication' program. Five commercial _ grade evaluat' ions were

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reviewed to assure that they met.the requirements of licensee's procedores CGP.1-1, Design Engineering. commercial: Grade Technical-

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Evaluation Procedure, and NPP-220, Commercinl Grade items. The'

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evaluations included three lubricating oils or greases, one;on

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several mechanical components,=and one on' an electrical power '

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- A11 ~of the evaluations included the deterinination:that the component was used in-a safaty related application and'could not-be procured other than commercial grade. With this determination, was the development of the critical, characteristics of each'

component and the' required acceptance criteria-for dedication.-

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The . inspector verified, for the lubricating oils and greases, that:

the acceptance tests were being ,nerfortaed prior lto the materials being reieased for use-in'the' plant. 011 samples werf taken froin, each container of oil received and the -oil was: segregated untill the test ' results. were completed - For the oils, the identified criticalicharacteristics were appearance, kinenatic' viscosity, fIashpoint,.andl additives'(por ASTM 0974 or. ASTM D664). These H characteristics are in line with the licensee's program and the

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standard' developed by EPRI, NP-5652,: Guidelice for the Utilization of Commercial Grade Items in Nuclear Safety fielated Appilcations.

No violationc or:dkviations were identifie \

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c' y Licensee Event Report (LLR) followuu 490712,02700)1 )a

.The LER listed below was reviewed to determine if the information provided mot NRC requirement The _ determination included: adequacy of'

description, verification of compliance with Technical Specificatior.s <

and regulatory requirements, corrective action taken,' existence of f potential generic problems,_ if reporting requirements were satisfied, and the relative safety significance-of each even (Closed) LER 369/92-10: Unit 1 Containment Integrity Technical--

Specification Violated l

No violations or deviations were identified - j Followup on Previous Inspection Findings (92701,92702)

The following previously identified item was raviued to_ ascertain -that; the' licensee's responses, where applicable, and licensee actions wereiln complianca with regulatory requirements and corrective actions have-baen implemented.. Selective verification included record review,-

observations, and discussions with licensee personnel.

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(Closed) Unresolved item 369,370/92-26-01: iieview of Auxiliary ;

Feedwater System Design The Auxiliary Feedwater System (CA) is'

. p,ovided with three pumps, two motor driven and one turbine. drive E

,Three prefarred non-safety related suction-sources are'.providad-from the 7

. Condensate Storage Tank, the Upper Surge Tank and the llotwcll ' A'commun pipe from these three sources is connected to the CA suction' header for all thr:ee pumps. A portion of this pipe'is located in the Service Building And was not designed for seismic loads. -In addition,- a' seismic-

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. suction source is provided by thn Nuclear Service Water System (RN);

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Suction valves to the kN system are actuated by CA pressure switches -

l when low pressure _ is sensed in the suction header.HThe actuation is-delayed by three-seconds.

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Or October 27, 1992, during an instrument setpoint verification -

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associated with the Design Basis Documentation _(DBD) program,;the licensee questioned whether failure of this non-seismic portion of-piping ns a problem. _ The _ licensee' postulated a. failure of the non-seismic p_lpe that results. in a loss of the normal CA suctien sources.and; a partial--drairdown of the CA suction header. The licensee questioned i

whether the setpoints of the pressure switches would allow the RN .

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suction. source to be available in sufficient time to prevent air binding:

of the pump A PIR (0 M92-0406) was written,' calculations were '

started, a modification to raise-the:setpcints was: started and the *

licensee began to ovaluate the non-seismic pipe' against Seismic

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qualification Utility Group (SQUG) seismic guidanc q on October 29,.the licensee completed modifications to raise.the switch

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setpoints by one psi. The licensee also determined that' portions of the L piping met the SQUG criteria and iorther determined that the new

.setpoints. along with the portion of pipe which met the SQUG criteria

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assured CA operabilit ~

On November 24, 1997, the licensee declared that the CA System had been inoperable for the following specific scenarin:

• Safe Shutdown Earthquake w Loss of normal feedwater

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o 8.nss of nermal CA suction source, e.g., loss of the non-seismic portion of suction piping

• No loss of offstte pnwer (turbine driven pump does not auto start)

• A motor driven CA pump fails e pressure switches were in error below 2 pSIG In this event RN swapover would not occur in time per the c lculations to prevent air entering the suction header and possibly resulting in damage to the CA pump The inspector reviewed the licensee's probabilistic analysis of this event, it appears that the probability of this event cr.usIng loss of CA has a frequency of 4E-7/ year. This coupled with a failure of operators to properly perform feed and bleed cooling leads to a coro damage frequency of 4E-9/ year. It is also noted that the switchyard' insulator have a lower seismic capability than the normal CA suction piping (nean value of 0.2g versus 0.49 ). Because of this lower seismic capability, a switchguard failure is more. probable than a CA suction piping failur The licensee determined that the original design failed to ' consider the-maximum possible error (1.7 P515) of the pressure switches. The -

licensee has completed approximately 30 system setpoint verificationt

• ithout finding a similar problem and intends to continue the

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verification process with.each DBD syste The licensee was unable to iduntify exa::tly why the original design did-not fully consider the Linstrument error, At the end of the inspection period, the licensee was still evaluating the boct way to-upgrade the suction piping, i0 CFR 50, Appendix B, Criterion 111 and the licensee's accepted Quality:

Assurance program (Duke Topical Report, Duke 1-A) require that measures be established to assure that applicable regulatcry requirements and the design basis for structures, systems, and components are correctly translated into specifications drawirgs, procedares, and instruction Contrary to the above, measures were not adequate to assure tha applicable regulatory requirements and the design baser for structures, .

systems', and components were correctly translated into specifications,. rawings, procedures, and instructions, in that the licensee failed to consider instrument error in designing suction pressure switch settings for the CA system. This resulted in the possibility of air entrainment

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into CA pumps prior to swap over to the assured suction source if the normal non-seismic /non-safety related suction- piping thould _ fail.- Ynis is a licensee identified issue and the licensee appears to be taking - >

appropriate correctiva cction. Therefore, this violt.tien will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specifie6.in Section VII.B. of the Enforcemeat Folicy. This is Non-Cited Niolation 369,370/92-28-01: Failure to Adequately Consider lastrument Error in Design of the Auxiliary feedwater Syster.,

following the increase of the setpoint on the pressure switches, at_the end of Octcber, the licensee resumed tne normal preventive maintenance schedale for the switches, On December 10, 1992, some of the switches- .

came due for normal proventive maintenance. While calibrating four of- !

the switches, it was noted that some of the switches had drifted outside of the operational tolerances.-- All of the switches were.recalibrcte'l as-a result. Ctabt of the switches had drifted outs!de 'of the calibrnion tolerances and four of these had drifted outside of the operational toleranccs. The original thought was that the calibratinn methodol_ogy: <

and switch design had lead to thn problem.. The calibration methods were

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revised and all of the switches recalibrate On December D,1992, four of the switches were checked to vcrify setpoints. Two of these switches were or.as that had been found -

inoperable during the previous calioration. At this time, three of the -

four switches had drifted out of the calibration tolerances;-one had drif ted out of the operational tolerances 2.nd one had drif ted a- i significant amount in the conservative direction. Conclusions wer drawn that-the switches had a tendency to. drift, but it_ could not be: '

predicted if the drift would be in the conservative ur non-conservative direction. On December-18 and 19,1992, tne four-worst drifting switchcs were replaced, all_ other switches were calibrated,- and all- switch setpoints wera raised 2 psig. In all, prior _to the higher: '

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setpoints, 11 switches had drifted out of the calibration tolerances and:

2 switches had drif teri out of the mperational. taleranr.es.-- The higher setpoint would allow for;a larger drift prior to the switch being inoperable, allowing enough time to evaluate long term corrective actions for the drifting switch problem. Plans being evaluated include

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the replacement of the switches with a different type of switch.- The residents will follow the resolution of this issue durfrg future inspection One non-cited violation was identified as-described abov . Evaluaticn of Licensee Self-Assessment Capability (40500) Joint Utility Management Audit (JUMA) ,

The inspector revitwed a report to the licensoe regarding the results of i JUMA review of the quality assurance program. The-sudit team consirted of tnres individuals from three-other utilities, we audit supervisors and a quality verification

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general manager, fhe licensee requested this audit.to provide aaditional assurance that the quality assurance (QA) program had been effectively irnplemented under the new organization which had been in place for approximately one year. The audit was cor. ducted on Octet er 19-23, 199 The audit covered the arear of supplier activities, internal audits, Nuclear Safety Reviu Board (NSRB) activities, Safety Asterance activities, engineering and maintenanc the audit team rnade the following conclusion:

" Based on reviews and interviews cenducted, it appears the reorganization and the resulting Topical Report revision have not aciversely effected day to day work activitie Howcver, procedural changes to reflect the organizational structure and associated responsibilitics cre still in nrogres Even though the development schedule is apparent, it does not appear it will have an adverse effect."

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The team noted 15 observations / recommendation The most ,

significaat included:

• A misinterpretation of requirements may exist regarding the level of review by the NSRB for unreviewea safety question * The site Safety Review Group (SRG) has not fully defined its role in self-assessmen e The SRG inplant reviews and surveillances have decreased in 199 * SRG has not reviewed modification activities or instrumentation inspection activitie * A number of procedures are yet to oe revised and the scheduie appears to be. slipping. Most are scheduled for completion by vanuary, 199 e Additional training should be conducted such as Q

' Philosophy / Awareness and Q Procedure Skill Training. For-example, several SRG personnel were not aware of their "stop .

work authority" Also the philosophy behind incorporating-inspectors into the maintenance group was not'well understood in some case The audit _ appeared.to cover the key areas of the Q program and appropriately identified areas for improvement. The licensee informed the inspector that appropriate corrective actions would be developed and that the inspector would be informed of these action . . . - . . - . - - - .- . . -

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i 9 Review of Problem Investigation Reports The inspector reviewed selected Problem Investigation Reports-(PIRs) to determine if the licensee was thoroughly evaluating Droblems and developing appropriate Corrective actions. PlR N M92-0140 documented a problem with effluent monitor (EMF) 53 which functions to shutdown the exhaust fan for the waste' storage building ventilation system upon reaching the setpeint. On September 17,19S2, the EMF did not shutdown the exhaust fan ,

during a test. The licensee discovered two loose wires and a

,iumper in the electrical termination cabinet for the EM The root cause documented on the PIR was simply a restatement of the problem and consequently no preventive corrective actions were developea relative to the root cause of the problem. The inspector questioned the licensee as to the adequacy cf the evaluation and corrective actions and the licensee immediately reopened the PIR for further revie '

Licensee Station Directive 2.8.1, Preblem Investigation Process, -

paragraph 5.2.5.2.2 requires that the PIR resolution be

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sufficiently detailed to clearly identify the root cause, when

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possible, and identify actions necessary to prevent recurrenc This failure to adhere to procedural requirements is a violation of 10 CFR 50, Appendix .B, Criterion V, which requires activities affecting quality to be accomplished in accordance with

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established pocedures. This is Violation 369,370/92-28-02:

Failure to follow Procedure for the Problem Investigation Proces One violation was identified as described abov . Cold Weather Preparations (71714)

The inspector performed an inspection-of the. licensee preparation to protect safety related systema against cold weather. The inspector reviewed licensee procedurc, PT/0/B/4700/38? Verificatior of Freeze _ -

Protection Equipment and Systems, which w&s being implemented during the inspection. All required steps of_ the pro (edure had beer completed, _

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with the exception of the evaluation of the functional test on the hot water system (YH).

The inspector verified that the YH system was in operation, the ovaluation was continuing as the licensee proceda s was being performe The inspector verified that preventive maintenance was completed on the heat tracing in the plant, prior to the completion of the check-list _ -

The doghouse lower steam vent-louvers have been closed and top steam vent curtains have been installed. The doghouse heaters are energized- ,

and functioning when the temperature is below 55 degrees The licensee operations staff have successfully verified that -the operater aid computer points that monitor dcghouse temperatures are in service and functionin , , _

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The Auxiliary Building ventilation system preparation;for cold weather 1ha- been completed,: cooling: water has been -isolated and all moisture has been drained from the syste No-violations or deviations were identifie . Exit Interview (30703). _

f The inspection scope and findings identified below were summarized on December 21, 1992, with those persons indicated in paragraph 1 abov ihe following items were discussed in detail:

Non-Cited Violation 369,370/92-28-01: Failure to Adecuately- _

t Consider Instrutaent Error in Design of the Auxiliary Feedwater System (paragraph 6).

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Violation 369,370/92-28-02:- Failure'to Follow Procedure for the Proolem Investigation Process (par agraph 7.b.).

The licensee representatives prescat offered no' dissenting comments, nor did they identify as proprietary any of the information reviewed'by. the inspectors _during the course of their inspectic .

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