IR 05000334/1980006
| ML19321A316 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/16/1980 |
| From: | Beckman D, Hegner J, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19321A291 | List: |
| References | |
| 50-334-80-06, 50-334-80-6, NUDOCS 8007230174 | |
| Download: ML19321A316 (23) | |
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V U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-334/80-06 Docket No. 50-334 License No. DPR-66 Priority Category C
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Licensee:
Duquesne Light Company 435 Sixth Avenue Pittsburgh, Pennsylvania Facility Name:
Beaver Valley Power Station, Unit 1
Inspection at:
Shippingport, Pennsylvania Inspection cond ted:
Fe uary 11-March 7, 1980 Inspectors:
M nocb4 m m.
f- / r-f-A IT.' f..'jd kmaf, Senior Resident Inspector date signed b
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0. D. Hegner, Resident spector date signed date signed Approved by:
f O CM.h r las leo E. C. McCabe, Chief, Reactor Projects date signed Section No. 2, RO&NS Branch Inspection Summary:
Inspection on February 11-March 7,1980 (Inspection Report No. 50-334/80-06)
Areas Inspected:
Routine inspections by the resident inspectors (100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />)
of:
licensee action on previous inspection findings; plant operations; refueling operations; licensee event review; review of physical protection / plant security; and review of a potential for containment hydrogen recombiner failures.
Resul ts: One item of noncompliance was identified (Infraction - Failure to maintain fire penetration barrier integrity, Paragraph 4).
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Region I Form 12 (Rev. April 77)
8007230/7 @
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DETAILS 1.
Persons Contacted R. Balcerek, Nuclear Engineering and Refueling Supervisor R. Burski, Senior Compliance Engineer W. Glidden, OA Engineer R. Hansen, Maintenance Supervisor J. Kosmal, Radcon Supervisor E. Kurtz, Senior QA Engineer F. Lipchick, Compliance Engineer A. Lonnet, Associate Engineer J. Maracek, Senior Engineer W. Marquardt, Office Manager - Nuclear R. Prokopovich, Reactor Engineer J. Proven, Construction Specialist
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L. Schad, Operations Supervisor E. Schnell, Radcon Foreman J. Sieber, Superintendent, Licensing and Compliance J. Werling, Station Superintendent H. Williams, Chief Engineer Other personnel were contacted also.
2.
Licensee Action on Previously Identified Inspection Findings (Closed) Infraction (79-26-01):
Logging and Issuance of Respirators.
During the period November 21-23, 1979, on three occasions respirators were issued to personnel who were not on the training list and, cn one occasion, a respirator was issued to an individual who was not on the list for that type of respirator.
Inspector review of the corrective and preventive actions specified in DLC letter of February 13, 1980 determined the licensee's action to be acceptable and as specified.
(Closed) Infraction (78-22-01):
Failure to properly barricade a high radiation area. A portion of Elevation 718 in the Reactor Containment i
in the vicinity of the Pressurizer Relief Valves had radiation intensities as high as 140 mrem per hour in the general area, but was not barricaded i
and posted as a high radiation area. TN inspectors reviewed the
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corrective and preventive actions, including the installation of a permanent barricade as specified in the DLC letter of October 16, 1978.
Inspector review determined the licensee's action was acceptable and as speciffed.
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(Closed) Inspector Follow Item (80-01-05): MCB Vertical Board House-
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cleaning.
During an inspection of the Control Room on January 16, 1980 the inspector noted that the area behind the vertical section of
the Main Control Board (MCB) was in need of general cleaning.
The licensee agreed to improve housecleaning practices in this area pending the purchase of suitable, non-conducting cleaning equipment.
Subsequent to the purchase of equipment and cleaning, NRC reinspected the area and determined it to be acceptable.
(Closed) Inspector Follow Item (80-04-01):
Review implementation of licensee actions pursuant to NRC Order Modifying License and DLC letter of January 10, 1980.
Inspector review confirmed that each specified action had been incorporated into licensee procedures and was being implemented in accordance with the commitments made in the January 10 letter. The inspector also reviewed the records, minutes, and reports which document the evaluations, reviews and actions undertaken by the station staff, the Onsite Safety Committee, and the Offsite Review Committee which were discussed in the licensee's letter.
Paragraph III.A of the licensee's letter identified ten BVPS Operating Manual (0M) procedure changes necessary as a result of the review of administrative controls.
The inspector verified that all of the changes had been incorporated into BVPS OM Chapter 1.48 by Revision 11 thereto. The inspector further verified the implementation of specific provisions of these revisions as follows:
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During each of the control room tours and other routine visits discussed in Paragraph 3 of this report, the inspector verified by direct observation that the Turnover Check Sheets, implemented by OM Section 1.48.2.B, are in use at all specified watch positions and are being used in accordance with procedural requirements.
On duty licensee personnel were interviewed to confirm their
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understanding of the authorities provided by OM Section 1.48.2.C.
That procedure requires the Shift Supervisor to stop all Control Room activity which is not immediately required for the safe operation of the plant.
These interviews involved 9 NRC licensed individuals on three shifts and confirmed their understanding of the responsibility and authority provided by the procedures.
The inspector verified that all operating personnel had acknowledged their review and understanding of the OM revisions by signature on a record sheet.
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During each of the tours noted in Paragraph 3 of this report, the
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inspector observed the implementation of the revised Equipment Clearance Procedures of OM Section 1.48.6 and System Level Status Board procedures of OM Section 1.48.5.
The inspector reviewed all active Equipment Clearance forms posted in the control room log books to verify that the Emergency Safeguards Eouipment Clearance Checklists were properly completed for each applicable clearance, that Equipment Clearance Permits for ESF equipment not subject to use of the checklists were properly annotated, and that the System Level Status Board was appropriately lighted for the equipment which was out of service or otherwise inoperable.
No discrept.ncies in the implementation of these procedures were noted. The inspector further reviewed all outstanding Equipment Clearance Permits on the dates referenced to establish that ESF equipment was returned to service on a priority basis upon completion of maintenance activities. The inspector noted no instances in which the ESF equipment required to be operable in the existing Operational Mode was not promptly returned to service.
Discussion with station management and Operations Department personnel indicated that some difficulties had been encountered during outage activities in the implementation of ESF Checksheets with regard to coordination of maintenance activities in a manner which will ensure the operability of all required equipment.
At the close of this inspection the licensee was considering a modification to the current practices associated with coordination activities which will remove some of the current encumberances from performing maintenance and modifications activities in Cold Shutdown and Refueling Modes.
Any such changes to the above procedures will be reviewed by the inspectors during future routine inspections of the licensee's equipment control program.
t (Closed) Deficiency (79-16-01):
Failure to maintain Jumper and Lifted
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Lead Log in accordance with the BVPS Operating Manual (0M), Section 1.48.D.2.B.
The inspector reviewed the licensee's preventive and corrective actions with respect to the DLC letter of October 10, 1979 and determined the actions to be consistent with the subject letter.
The inspector confirmed that the active tags had been audited by the Operations Department and all noted discrepancies had been corrected on or before October 10, 1979.
The inspector also reviewed Revision 6 to BVPS OM Section 1.48.5.D which had been issued to clarify the requirements for Jumper and Lifted Lead Log entries and included sufficient information to describe the purpose, location, and drawing references applicable to individual entries.
The inspector reviewed active entries in the log on March 6,1980 and determined that the lL entries were being made in accordance with the guidance and requirements of Revision 6.
The inspector's review included active tags associated with the Safety Injection System, Containment Depressurization System, l
Reactor Plant Sample System, Reactor Plant Component Cooling Water System, Supplementary Leak Collection and Release System, Residual Heat Removal System, Feedwater System, and the Reactor Coolant Syste *
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During this review the inspector noted several instances of missing personnel initials and dates (e.g. Feedwater System, Tag Nos. 2311-2316; Containment Depressurization System, Tag No. 2218) which were immediately field verified and corrected by the Shift Supervisor.
No discrepancies were noted in the actual installations.
Based upon these observations, the Operations Supervisor made a Night Order entry emphasizing the need for complete documentation in such logs.
The inspector had no further questions on this item.
(0 pen) Unresolved Item.(76-26-03):
Licensee to determine the number of safety injection cycles acceptable for the Unit 1 design.
This matter had previously been referred to NRC:HQ for further review and disposition.
The preliminary results of that review indicated that long term evaluation appeared appropriate by both NRC and the licensee on the basis that the total number of cycles to date did not present an immediate concern. An NRC letter, A. Schwencer (NRR:00R) to C. N.
Dunn (DLC). dated December 8, 1979 provided additional discussion of inadvertant safety injections during cool down and recommended that a plant specific analysis be completed for any facility which experienced more than twenty-five such cycles.
The inspector requested the DLC Senior Compliance Engineer provide the licensee's position and intentions with respect to complying with the recommendations of the December 8 letter. This matter will remain unresolved pending NRC receipt and review of the requested information.
(Closed) Unresolved Item (79-27-03):
Licensee to submit supplemental response to IE Bulletin 79-14, Seismic Analyses for As-built Safety-Related Piping Systems. The licensee had been requested to issue a supplemental response to the subject bulletin to clarify the intended scope of piping inspections to be completed pursuant to the bulletin.
A DLC letter issued on February 29, 1980 provided this clarification including the licensee's position for reinspection of piping inspected as part of the Show Cause Order seismic reanalysis activities, inspection of other piping inside containment and the licensee evaluations which support the licensee's positions.
The inspector had no further questions with regard to the licensee letter and will include its review in sub-sequent inspections of onsite activities.
(Closed)UnresolvedItem 80-01-07:
Licensee to incorporate rules for interruptions in refueling activities into procedures as required by ANSI N18.7-1972, Paragraph 5.3.4.5.
The inspector confirmed that the specified provisions were incorporated into Refueling Procedure No.
FP-DLW-R1 via Change Request No. 7 dated February 13, 1980.
The inspector confirmed that the change had been entered in all controlled copies of the procedures on the refueling floor and in the control room. The change requires the Nuclear Shift Supervisor and Refueling Shift Supervisor to review the nature of any interruption to refueling activities and determine whether prerequisites had been affected. If refueling prerequisites are affected, reverification is required by performance of Operating Surveillance Tests 1.47.3 or 1.49.3.
The inspector had no further questions on this matter.
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(Closed) Violation (70-30-01):
Licensed operators approved equipment control activities which rendered both high head safety injection subsystems inoperable during power operation.
The two NRC licensed operators responded to the above item of noncompliance by individual letters dated January 10 and January 18, 1980.
The inspector reviewed these letters with respect to the stated reasons for the noncompliance and the actions intended by the individuals to prevent recurrence of similar noncompliance. The inspector determined that the reasons provided by the operators for the noncompliance were consistent with
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the findings of IE Special Inspection No. 50-334/79-30 and the Duquesne Light Company investigation of the incident as discussed in the DLC letter of January 10, 1980.
Inspector review of the corrective and preventive actions provided in the operators' letters confirmed their implementation, including:
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Both individuals have completed a self-study review of procedure
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and policy changes implemented by their employer to prevent recurrence. The completion of this training is documented in plant records.
Both individuals participated in the development of the above
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procedures and policies via their involvement in plant staff and Onsite Safety Committee meetings and activities.
Both individuals conducted on-shift training of operating personnel
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under their cognizance as confirmed by inspector interview of the trained personnel.
Inspector interview of the individuals indicated an in depth
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knowledge of the new procedural controls, and awareness of their significance.
The inspector observed the implementation of the revised equipment
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control procedures by the subject operators on several occasions during the inspection and discussed the specifics of implementation with the personnel.
The inspector had no further questions on this item.
(0 pen) Unresolved Item (80-01-10):
Review completion of licensee corrective and preventive actions for LER 80-02/01T, Loss of RHR Flow.
This matter is further discussed in Paragraph 6 of this report.
(0 pen) Unresolved Item (79-27-07):
Review DLC evaluation of and action for foreign material found in Emergency Diesel Generator fuel oil tanks. This item is discussed further with respect to Licensee Event Report 79-48/03L in Paragraph 6 of this report.
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(0 pen) Unresolved Item (80-01-11):
Review circumstances and corrective actions for Emergency Diesel Generator sequencer timer problem of February 1, 1980.
This item is discussed with respect to Licensee Event Report 80-09/03L in Paragraph 6 of this report.
(0 pen) Inspector Follow Item (79-27-05):
Review licensee corrective action for LHSI pump dropped during modification activities on December 20, 1979. The circumstances surrounding the actual dropping of the pump are discussed in IE Inspection Report No. 50-334/79-27.
On February 20 and 26, 1980 the inspector met with members of the DLC Construction Department staff and reviewed the results of pump element and casing inspections and the plans for reinstallation of the pump.
Subsequent to December 20, 1979, the dropped pump internals were retrieved and residual water in the pump can (outer casing) was removed.
The inspector reviewed the results of subsequent inspections of the pump as documented in the following Engineering Memoranda (EM):
EM 40285, dated January 7, 1980.
The subject EM provided inspection
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criteria for visual inspection of the pump casing and parts intended for reuse (the suction bell, internal casing, and impellers)
and reported the inspection results. The licensee concluded, based on the detailed inspection results, that the pump dropped vertically without hitting the sides of the can. The EM stated that the bulk of any impact force is assumed to have been dampened by the water in the bottom of the can allowing the pump to come to rest upon the bottom without damage. All indications observed during the inspection were considered to be superficial in nature, identifying no conditions which would limit the operability or function of the involved parts.
The inspector reviewed the detailed inspection reports and noted that minor metal upsets were identified which could not be attributed to any impact loading. The report further noted that pump shaft sections were not inspected because they are to be replaced.
Discussion with licensee personnel indicated that the only observed shaft conditions were a slight burring on shaft threads, with no signs of damage to shaft keyways and locking collars.
Shaft straightness or runout were not checked. The EM also recorded satisfactory dimensional checks of the internal parts.
EM 40314, dated January 14, 1980. The EM forwarded additional
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inspection results for engineering review, including results of pump can visual inspection, levelness checks, and plumbness checks. The inspector noted that the inspection results of the pump can showed no indication of dropping damage, the only indications being brush marks between 20 ft. and 38 ft. from the top of the can, with essentially no penetration of the can walls. The can bottom was reported to have some surface scratches which had no measureat.. depth, there were no gouges, depressions or deformation.
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EM 40502', dated February 12, 1980. The EM forwarded copies
of levelness, concentricity, and dimensional checks of the i
pump can, flange, and internal seismic support ring. The engineering evaluation noted that the measured parameters
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i were within the range of values expected from normal operation.
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The inspector noted that levelness and concentricity (measure-ments were accepted by the Onsite Engineering Group 0EG)
and that the pump can will be realigned for plumbness as
part of the ongoing modification work in accordance with
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instructions provided by the OEG. The dimensional checks of
the internal seismic ring were identified to fall outside the tolerances permitted, apparently due to record discrepancies between as-built conditions and original design records.
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The EM noted that the 1980 as-found dimsnsions were consistent
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with dimensions taken during modification work on the pump i
during 1978. The EM requfred performance of a " Seismic Ring Clearance Check" in accordance with Corrective Maintenance Procedure No. CMP-1-11SI-P-1A-B-5M, May 25, 1978, as part of i
the scope of Design Change Package 0188 for pump modification.
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The inspector also reviewed Maintenance Work Package 188-7, Replumbing of LHSI-1A Pump Can, Revision 0, dated February 18, 1980 which provides instructions for releveling the pump can flange and determined it to i
be consistent with prior practice.
The licensee also stated that the actual concentricity of the internal seismic ring would likely be
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checked in place during pump internals reinstallation by lowering the internals into the can while an inspector measured the clearances from below the rigged load. The inspector questioned the personnel safety
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aspects of rigging such a load into the can over a man and provided
his comment to the licensee.
The inspector. also discussed general plans for preoperational and pump
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performance testing with the licensee. At the close of this inspection j
the test requirements for the equipment had not yet been promulgated but the general discussions indicated that the pump would be tested in a manner similar to that used during prior modifications in 1978 and
. at other facilities which had successfully completed the same modifications.
I The inspector requested the licensee make the test requirements and/or-procedures available to the inspector as they are issued.
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.The sub, ject pump and its redundant unit are currently being modified
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i to correct previously. identified deficiencies which resulted in poor j
pump reliability. These modifications have been the subject of previous q
correspondence between the licensee and NRC:NRR.
The basis:for acceptability
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I of the pump modifications and overhaul includes reinstallation 'and -
i testing using techniques which have proven successful in prior similar i
modifications. The inspector held informai discussions on the above
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information with an NRC:NRR reoresentative who was familiar with the
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industry experience with these' pumps and determined that the corrective i
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remain open pending review of the above mentioned test information L
. when it becomes available and further ' review of the pump reinstallation and testing during future inspections.
Pump modification and reinstallation activities were proceeding at the close-of this. inspection.
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3.
Review of Plant Operations a.
General Inspection tours of selected plant areas were conducted on the dates noted during t.'ie day shift with respect to housekeeping and cleanliness, fire protection, radiation control, physical security and plant protection, operation and maintenance administrative controls, and Technical Specification compliance.
Acceptance criteria for the above areas included the following:
BVPS FSAR Appendix A, Tecanical Specifications
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BVPS Operations Manual, Chapter 48, Conduct of Operations
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OM 1.48.5, Section D, Jumpers and Lifted Leads
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OM 1.48.6, Clearance Procedures
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OM 1.48.8, Records
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OM 1.48.9, Rules of Practice
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BVPS Operations Man"al, Chapter 55A, Periodic Checks -
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Operating Surveillance Tests BVPS Operations Manual, Chapter 54, Station Logs
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BVPS Maintenance Manual, Chapter 1, Conduct of Maintenance
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Section J, Housekeeping
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BVPS Radcon Manual, various sections
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SAD 25, Housekeeping and Cleanliness Procedure
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10 CFR 50.54 (k), Control Room Manning Requirement
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Inspector Judgment
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BVPS Physical Security Plan
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b.
Areas Toured Control Room (February 19 and 22; March 3 and 6)
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Primary. Auxiliary Building, except High Radiation Areas and
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Loose Surface Contamination Areas (February 14, 27, and 28)
Main Steam Valve Room (February 14)
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Vital Switchgear Rooms (February 27)
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Purge Duct Room (February 14)
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East / West Cable Vaults (February 27)
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Main Plant CO2 10 Ton Storage Unit Room (February 27)
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Emergency Diesel Generator Rooms (February 27; 28)
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Containment Building, excluding High Radiation Areas (February 20)
"C" Steam Generator and RCP Cubicle (February 22; March 3)
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Fuel Handling Building (February 20)
In addition to the above, the inspectors regularly visited the Control Room durine normal work hours to review logs and records and to conduct di' ussions with Control Room personnel.
c.
Observations (1) Control Room Instrumentation Conformance with Technical Specifications Control Room monitoring instrumentation was observed to verify that instrumentatic and systems required to support Mode 5/6 operations (as applicable) were in conformance with Technicel Specification (TS), Limiting Conditions For Operations (LCOs).
The following instrumentation / indications were observed with respect to the LCOs indicated:
Boric Acid Flowpath (Fabruary 26)
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Boric Acid Transfer Pumps Operability TS 3.1.2.5
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(March 3)
Boric Acid Storage Tank Level and TS 3.1.2.7
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Temperature (March 3)
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Reactor Coolant System Baron Concen-TS 3.9.1 tration (February 19, 22; March 3)
Residual Heat Removal Flow TS 3.9.8
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(February 19)
Source Range NI Operability TS 3.9.2
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(February 20 and 22)
~ Radiation Monitor Operability TS 3.3.3.1
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(February 22)
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RM 207
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RM-VS-104 A/B
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RM 215 A/B
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RM-VS-103 A/B
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AC/DC Electrical System Availability TS 3.8.1.2,
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and Distribution (March 6)
3.8.2.2, and 3.8.2.4 (2)
Radiation Controls Radiation controls established by the licensee, including posting of radiation areas, the conditions of step-off pads, disposal c# protective clothing, filling out radiation work permits, compliance with radiation work permits, personnel monitoring devices being worn, cleanliness of work areas, radiation control job coverage, area monitor operability (portable and permanent), area monitor calibration, and personnel frisking procedures were observed on a sampling basis in the following areas:
Primary Auxiliary Building (PAB) (February 14,27,28)
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Containment Airlock Area (February 20, 22; March 3)
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Fuel Handling Building (February 20)
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Containment (February 20, 22; March 3)
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Radiation Work Permits (RWP) were reviwed on February 22, 27 and March 5, 1980 for completeness. The inspectors j
verified through direct observation that the requirements of RWP #6423 - Reactor Containment "C" Reactor Coolant Pump Cubicle 718' Elevation - were satisfie.
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Plant Housekeeping Plant housekeeping conditions including general cleanliness conditions and control of material to prevent fire hazards were observed in areas listed in paragraph b.
Maintenance of fire barriers and fire barrier penetrations in these areas was also observed.
(4)
Control Room Manning Control room manning was obserr d on the dates noted in subparagraph b above and duri-other periodic control room visits. A shift turnover in a control room was observed on February 27.
(5) Operational Surveillance Tests The inspectors reviewed completed OSTs available during Control Room tours to verify that surveillance tests required
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were being completed, that tests were being reviewed according to approved procedures, and that appropriate corrective actions were initiated if necessary.
The following OSTs were reviewed by the inspectors:
OST 1.36.7, Offsite to Onsite Power Distribution Systems
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Breaker Alignment Verification, Revision 14, performed March 1, 1980.
OST 1.36.9, AC Power Source Breaker Alignment Verification
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During Shutdown, Revision 4, performed March 1, 1980.
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OST 1.39.1, Weekly Battery Check, Revision 3, performed
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March 2, 1980.
OST 1.49.2, Shutdown Margin Calculation, Revision 8,
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performed March 1 and 2, 1980.
On Macn 3,1980 t'ie inspectors witnessed the performance of OST 1.7.3 Boric Acid Transfer Pump Operational Test, Revision 12. The inspectors verified that:
the test procedure was available and in use;
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special test equipment required by procedure was calibrated
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and in service; test prerequisites were met;
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the system was restored to an operable alignment for
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the current plant operational mode;
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tests were in conformance with TS and completed within
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time frequencies specified; the completad test was reviewed as required by facility
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administrative requirements; and the test was performed by qualified individuals.
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(6) Plant Security / Physical Protection Implementation of the physical security plan was observed in the areas listed in paragraph b above with regard to the following:
Protected area barriers were not degradod;
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Isolation zones were clear;
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Persons and packages were checked prior to allowing
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entry into the Protected Area; Vehicles were properly searched and vehicle access to
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the Protected Area was in accordance with approved procedures; and Security access controls to Vital Areas were being
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mainta!ned and that persons in Vital Areas were properly authorized.
(7) Operational and Maintenance Administrative Controls Equipment Control procedures used by the licensee to restrict plant activities were examined to verify that tags were properly filled out, posted, and removed as required by approved procedures.
The inspectors reviewed logs and records for completeness. The inspectors verified proper posting of the following tags / controls:
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Caution tags on auxiliary feedwater throttle valves (February 12,1980)
Caution tags on Residual Heat Removal pump and valve
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controls (February 14,1980)
Out-of-service stickers on Safety Injection pumps
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(February 12,1980)
Jumpers / Lifted Leads (February 26,1980)
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Except as noted in paragraph d below, the inspectors' findings in the areas identified above were acceptable.
d.
Findings (1) The inspectors observed that, as the current autage progressed, the quality of frisking performed by personnel exiting the PAB Controlled Area through the Mens Locker Room portal was deteriorating, i.e., although whole body frisks were being performed as required by licensee procedures, on occasion personnel performed them in a hurried or inattentive manner.
The inspectors immediately brought their observations to the attention of the Station Superintencent, Radcon Supervisor, and Radcon Foreman, who concurred that a breakdown in frisking practices and subsequent contamination of non-controlled areas might occur'if preventive actions were not taken.
The licensee progressively implemented a series of measures in an effort to preclude such an occurrence.
These included:
prominently displaying signs at all frisker stations
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that explained and clarified frisking requirements; conducting training for all licensee and construction
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personnel to reemphasize the importance of frisking and a review of frisking procedures (when possible, the inspectors participated in the training); and, distributing by memorandum. a warning to all licensee and
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construction personnel that disciplinary action could result if an individual was observed leaving a Con-trolled Area without performing an acceptable whole body frisk.
This. item will remain unresolved (80-06-01) pending review during subsequent inspections to assess the adequacy of the licensee's actions.
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(2)
Inadvertent Backleakage into RWST During pumpdown of. water from the refueling cavity back to the coolant recovery tanks following refueling, a closed valve, PV-47, in the flow path leaked by its seat and passed approximately 5000 gallons of reactor coolant into the Refueling Water Storage Tank (RWST). The storage tank had-been pumped dry and opened earlier for maintenance. It was later determined that no maintenance work was being done on the RWST during the time water was being pumped from the refueling cavit.
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The water was discovered on February 27, 1980 by a radiation technican who was taking a routine air sample in the RWST.
There was no airborne contamination problem as a result of the inadvertent leakage to the RWST. The leakage resulted in approximately six inches of standing water in the tank, within six inches of a manway that was open for maintenance.
The water was subsequently pumped out of the RWST.
Radcon personnel cleaned and surveyed the area prior to maintenance resumption.
The pumping evolution which resulted in the valve leakage was performed by operators using a Temporary Operating Procedure (TOP) 80-7, " Transferring Water from the Reactor Cavity to the Coolant Recovery Tanks." The inspector expressed concern to the Operations Supervisor concerning similar subsequent activities using TOPS.
In order to make operators more aware of the possibility of inadvertent and/or unplanned releases as a result of leakage into undersized or unisolated tanks, the licensee agreed to include a suitably worded statement in future TOPS as a precaution.
This item will remain unresolved pending review of new Temporary Operating Procedures.
(80-06-02)
(3) Unlocked High Radiation Barrier On February 22, 1980 during a general tour of containment, the inspectors, accompanied by a licensee radiation control technican, found a radiation control barrier for a posted High Radiation Area (the Reactor Head Storage Area - 692'
Elevation) to be unlocked. The barrier was immediately locked by the technician upon discovery.
The inspectors subsequently determined that the area was conservatively posted, in that the radiation levels in the area controlled by the barrier in question were less than 100 millirem per hour. Moreover, all actual High Radiation Areas within the area were specifically posted and positive access control provided.
This finding was discussed with the Radcon Foreman who sub-sequently submitted a Maintenance Work Request (MWR 806222)
to fabricate and install a more substantial barrier for the head storage area.
The inspectors determined that the licensee's immediate and proposed corrective actions were adequate.
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(4)
Fire Barrier Integrity - Fire Doors During the current outage, maintaining fire barrier integrity has been a recurrent problem due to major maintenance /
modification activities.
The Senior Resident Inspector had expressed concern to the licensee on this subject during a previous inspection (Report 50-334/79-24).
In response, the licensee had initiated tours by roving safety engineers, who among other duties, were to assure the integrity of the fire barriers by imediately closing any doors found open, by posting fire watches if necessary, and by reporting maintenance deficiencies for corrective action.
Technical Specification 3.7.15 states:
"All penetration fire barriers protecting safety related areas shall be functional. With one or more of the above required penetration fire barriers non-functional, a continuous fire watch on at least one side of the affected penetration shall be establishad within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />." This requirement is applicable at all times.
On separate, routine inspection tours of the PAB the inspectors noted that the following fire doors were open and unattended:
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Door to MCC Room.
752' Elevation.
(February 27 & 28).
Door between PAB and " Elevator" Stairwell.
752' Elevation.
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(February 27 & 28)
t Door near West Cable Vault.
735' Elevation.
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(February 27)
Door between PAB and Pipe. Tunnel.
722' Elevation
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(February 14 & 28)
No fire watch had been posted at any door listed above nor could the licensee provide adequate assurance that the roving tour would discover and close the door or post a fire watch within the time allowed by TS.
In addition, it was noted that several fire doors (including some listed above) required maintenance.
Based on inspectors'
observations, several doors were positioned such that, had the fusable link on the door melted, the door closer would not have actuated, or would not have been capable o. fully closing the door. On some doors the hardware (knobs, latches, etc.) was missing and replaced by wire loops.
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These findings were brought'to the attention of the Station Superintendent on February 29, 1980.
At that time the licensee committed to the following corrective actions:
initiating an ongoing Maintenance Work Order to cover
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subsequent maintenance work necessary for proper fire door operation; and
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overhaul of all existing automatic fire door closing
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mechanisms, a replacement with more powerful models.
The failure of the licensee to assure fire barrier integrity is a non-compliance with Technical Specification 3.7.15.
(80-06-03)
4.
Refueling Operations On February 20, 1980 the inspectors observed activities during the 1600-2400 shift related to refueling in the Spent Fuel Building. On February 22, 1980 the inspectors observed activities during the 0800-1600 shift related to refueling cetivities inside containment.
The following activities were observed:
Core monitoring was in accordance with TS 3.9.2.;
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Boron concentration was in accordance with TS 3.9.1;
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The individual directing f'uel handling activities held a senior
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operator license, had no other duties, and was constantly present; Containment integrity was maintained as required by TS 3.9.4.a,
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3.9.4.b and 3.9.4.c; Radiation control personnel were present;
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Vessel water level was in accordance with TS 3.9.10;
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Communication between the control room and the refueling floor
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was established and maintained in accordance with TS 3.9.5; Fuel movement was conducted in accordance with approved pro-
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cedures; An audible source range nuclear instrument count rate could be
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heard in containment; Residual heat removal system operation was in accordance with TS -- 3.9.8; Fuel accountability methods were in accordance with established
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procedures;
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Core internals, leads, vessel studs, etc., were stored to protect
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against damage; and Housekeeping on the refueling deck and refueling bridge was
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maintained in accordance with approved precedures.
Except as noted below, the inspectors found the licensee activities to be acceptable.
a.
Tool Control on the Refueling Floor The inspectors examined the tool control log being maintained in containment and questioned the individual maintaining the log concerning his responsibilities.
It was determined that tre individual did not have a clear understanding as to the specific area to which tool control applied, nor was consistent control being exercised over certain items.
This finding was brought to the attention of the Maintenance Supervisor who immediately counseled appropriate personnel in the applicable tool control requirements.
The inspectors will follow this item during subsequent inspections for the purpose of reviewing tool control logs maintained during other maintenance / modification activities and interviewing personnel assigned to tool control activities for the purpose of assessing the adequacy of licensae tool control procedure. (80-06-04)
5.
In Office Review of Licensee Event Reports (LERs)
The inspector reviewed LERs submitted to the NRC:RI office to verify that the details of the event were clearly reported, including the accuracy of the description of cause and adequacy of c;rrective action.
The inspector determined whether further information was required from the licensee, whether generic implications were indicated, and whether the event warranted onsite followup.
The following LERs were reviewed:
- 79-48/03L Dessicant Bag Found in EDG Fuel Tank 80-01/01T Seismic Analysis Errors
- 80-02/01T Loss of RHR Flow
- 80-04/03L Radiation Monitor Setpoints Less Conservative Than Required
- 80-05/03L Operator Failed to Follow Radiation Monitoring Procedures
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80-06/04T Tritium in Quarterly Components Exceeding Reporting Level 80-07/01P Misalignment of Filter Banks During Refueling Activities 80-08/01T Potential Overstress on Cable Trays During OBE
- 80-09/03L Failure of EDG Sequencer 80-10/03L Boric Acid Transfer Pump Trip During Refueling 80-11/03L Valve Failure in Boron Injection Flow Path No items of non-compliance were identified.
Except as noted below, the LERs reviewed were found to be acceptable.
- Reports selected for onsite follow-up.
80-04/03L Radiation Monitor Setpoints not Conservative and 80-05/03L Operator Failure to Follow Radcon Procedures The inspector reviewed the subject reports and determined that the reports did not contain all pertinent information as specified in reporting guidance.
The inspector discussed the appropriate guidance found in NUREG 0161 with the licensee and obtained a licensee commitment to submit supplemental reports on the above items.
The inspector reviewed the supplemental reports and determined that no further action was necessary.
6.
Onsite Licensee Event Followup For those LERs selected for onsite followup (denoted by asterisks in Paragraph 5), the inspector verified that the reporting requirements of the Technical Specifications and Procedures SAD 14 and SAD 23 had been met, that appropriate corrective action had been taken or planned, that the event was reviewed by the licensee as required by Technical Specifications and Procedure SAD 21, and that continued operation of the facility was conducted in accordance with Technical Specifications and did not constitute an unreviewed safety question as defined in 10 CFR 50.59 (a)(2).
The following findings relate to the LERs reviewed onsite:
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20 LER 79-48/03L - Dessicant Bag found in EDG Fuel Tank.
At the close of this inspection, the licensee's review and evauation were continuing, including planning for internal inspection of other EDG fuel system tanks. The licensee is additionally reviewing the administrative controls associated with the construction and maintenance of the equipment to determine the possible source of the material. At the close of this inspection, although the matter was still under review, both EDG units had been inspected and satisfactorily returned to service. Additional information is provided in IE Inspection Report No. 50-334/79-27. Unresolved Item 79-27-07 will remain open pending completion of the licensee's inspections and evaluations and review of those results by NRC:RI.
- LER 80-02/01T - Loss of RHR Flow.
This event was previously discussed in IE Inspection Report No. 50-334/80-01 with respect to inspector evaluation of the event and the licensee's immediate corrective actions.
The licensee subsequently issued Operating Manual Change Notice No.
80-32 on February 28, 1980 which revised Temporary Operating Procedure No. 80-1, Air Eductor Operation, to provide additional prerequisite and operation steps to preclude air binding of RHR pumps by providing constant venting of the pumps during air eductor operation.
The inspector noted ihat the provisions appeared appropriate for prevention of further air binding but were not included in any permanent plant
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procedures. At an exit meeting on March 7,1980, the Operations Supervisor stated that the provisions of OMCN 80-32 or equivalent measures would be incorporated into permanent procedures used for air eductor system operation during future refuelings.
Unresolved Item 80-01-10 (Para-graph 2 of this report) will remain open pending incorporation of such provisions prior to the next refueling evolution and review of the revised procedures by NRC:RI.
LER 80-09/03L - 1A EDG Sequencing Timer Malfunction.
This event was previously discussed in IE Inspection Report No. 50-334/80-01 with respect to the inspector's preliminary review of the event, compliance with TS Limiting Conditions for Operation, and the progress of the licensee's investigation and evaluation of the event.
During this
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inspection, the licensee's event report and its attached " Report on Partial Loss of Power on February 1, 1980 and Failure of No. 1 Diesel Generator Load Sequencer," dated February 25, 1980, were reviewed by the inspector including:
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The details of the above reports were reviewed with respect to
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the equipment elementary diagram and wiring diagram (Drawing tios.
11700-RE-21-CE, Revision 1 and -RE-14-C, Revision 4, respectively)
including direct observation of the installed equipment and wiring. The details of the licensee's report with respect to the physical installation and its relationship to the conclusions drawn by the licensee's evaluation were confirmed.
The inspector reviewed the sequences of prior testing, discovery
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of the malfunction, troubleshooting, and correction and determined that the system performance and response appeared to be consonant with the identified wiring discrepancies and circuit conditions.
The licensee's evauluation of the potential and actual consequences
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of tne event was reviewed with respect to the above and appears to be reasonable and accurate.
The licensee concluded that the effect of the malfunction on plant safety was negligible in that the redundant EDG unit was available and minimal engineered safety feature equipment is required to be operable during operation in Modes 5 and 6.
The inspector reviewed wiring verifications and checkouts performed
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by the licensee via a detailed review of the above referenced reports with the DLC Technical Advisory Engineer and observation of the wiring in the cabinets with respect to the above referenced drawings. The inspector considers the checkouts to have been adequate subject to further verification via integrated system testing as further discussed below.
During the initial phases of the licensee's investigation, consideration
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was given to the possibility of unauthorized entry into the control cabinets as being a potential cause of the subject wiring errors. Although this possibility was never positively substantiated or eliminated, the complexity of wiring in the cabinet, the lack of individual wire marking, the potential consequences of the wiring discrepancies, and the difficulty in making such connection changes supports the licensee's conclusion that intentional miswiring was not involved in the incident.
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The LER specifies that the licensee is continuing the ir.vestigation of the matter and that additional testing would be completed prior to
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plant restart and to verify equipment operability. At the exit meeting on March 7,1980, the inspector informed the licensee that the results
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of the ongoing investigation, including the identification of additional
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corrective or preventive action to preclude similar loss of adminis-trative controls, should be provided in a followup report to the LER.
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Additionally, the licensee stated that the Operating Surveillance
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Tests Nos. 1.36.3 and 1.36.4, which test the integrated operation of the EDG sequencer under simulated loss of power conditions, would be performed prior to plant restart.
Item 80-01-11 (Paragraph 2 of this report) will remain unresolved pending submittal of the above supple-mental LER, completion of the above testing, and review of the completed
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activities by NRC:RI.
LER 80-05/03L - Operator Failed to Fe-4 Radiation Monitoring Procedures.
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i The inspector's review of the event a.d associated activities was previously reported in IE Inspection Report No. 50-334/80-01, Paragraph
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LER 80-04/03L - Radiation Monitor Setpoints Less Conservative than a
Required by TS. The event reported by the LER is the subject of an item of noncompliance discussed in IE Inspection Report No. 50-334/
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80-01, Paragraph 3.
Further review of the licensee actions taken in
response to this event will be made pending reacipt and review of the licensee's response to the item of noncompliance.
7.
Containment Hydrogen Recombiners - Potential for Blower Failures
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The facility's hydrogen recombiners are equipped with an encased, motor driven blower which operates in the internal environment of the l
recombiner. The 440VAC, 3 Phase power leads to the blowers are routed through a hermetically sealed connector on the blower casing, through
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flexible conduit inside the blower casing, to the blower motor terminal box. The portion of the leads internal to the blower casing are apparently provided as a pre-sealed part of the hermetic connector,
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extending 2-3 feet from the connector to the motor.
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These leads are unusually insulated.
In both recombiners, the leads appear to be No.14 AWG solid copper, with all three leads in contact with each other as they pass through the flexible conduit to the motor.
The leads in one unit appear to be insulated with only a
" varnish" type coating, having no additional jacketing.
In the other recombiner unit, the leads are wrapped with an adhesive tape which appears to be a " glass tape" or of similar composition.
In both cases, the leads appear subject to chafing against each other and other metallic parts of the conduit and its connectors.
Based upon the mounting configuration of the motor / blower unit, it also appears that the leads would be subject to significant vibration during the units' operations.
The above condition was discovered by the licensee during routine preventive maintenance on the recombiners.
The licensee has contacted the recombiner vendor and has received preliminary information indicating that the insulation described above may be incorrect for the installation.
Discussions between the licensee and inspector identified a mutual concern for the durability and effectiveness of the lead insulation in a recombiner operating environment.
The licensee is continuing to pursue resolution of these concerns with the vendor and is expecting additional information and delivery of replacement connector / lead harnesses prior to reassembly of the recombiner units.
The inspector requested notification from the licensee upon receipt of the additional information and parts to allow further evaluation of the reported conditions. This item will be followed during future inspections (80-06-05).
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8.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable, items of noncompliance or deviations.
Unresolved items addressed during this inspection are discussed in Paragraphs 2, 3, and 6 of this report.
9.
Exit Interview Meetings were held with senior facility management periodically during the course of this inspection to discuss the inspection scope and findings.
A summary of inspection findings was also provided to the licensee at the conclusion of the report period.
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