IR 05000338/1978037
| ML19269C004 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/11/1979 |
| From: | Kidd M, Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19269B977 | List: |
| References | |
| 50-338-78-37, 50-339-78-32, NUDOCS 7901190196 | |
| Download: ML19269C004 (17) | |
Text
e e RtCog UNITED sT ATEs n
NUCLEAR REGULATORY COMMISSION o,,
=
REGloN ll
).,.,
g r
c 101 M ARIETTA sTRE ET. N.W.
"8 ATLANTA, GEORGIA 30303 o
%,
f
- ...*
Report Nos. - 50-338/78-37 and 50-339/78-32 Docket Nos. : 50-338 and 50-339 License Nos. : NPF-4 and CPPR-78 Licensee: Virginia Electric and Power Company P. O. Box 26666 Richmond, Virginia 23261 Facility Name: North Anna Power Station, Units 1 and 2 Inspection at: North Anna Power Station, Mineral, Virginia Inspection conducted: October 2 - November 3, 1978 Inspector:
M. S. Kidd, Resident Reactor Inspector
/ 2.//////
Reviewed by:
/2. C.
A R. C. Lewis Chief Date Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch Inspection Summary Inspection on October 2 - November 3, 1978 (Report Nos. 50-338/78-37 and 50-339/78-32)
Unit 1 Areas Inspected:
Rout.ine inspection by the resident inspector of station personnel changes,
- 11owup on IE bulletin, licensee event and event reports review, witnessing of an emergency planning exercise, followup on previously identified open items, and settlement of Category I structures.
The inspection involved 26 man-hours by the NRC resident inspector.
Unit 2 Areas Inspected:
Routine inspection by the residert inspector of preoperational testing quality assurance program, administrative controls for preoperational testing, followup on IE bulletin, observation of staf f training, witnessing of an emergency planning exercise, preop test witnessing, conduct of plant tours, and comparison of selected installed systems to FSAR drawings. The inspections involved 39 man-hours by the NRC resident inspector.
Results: Of the thirteen areas inspected, no items of noncompliance or devia-tions were found in eleven areas; two apparent items of noncompliance were found in two areas (infraction - failure to control construction documents issued to operations and test personnel (339/78-32-01) - paragraph 7.b; infraction - inadequate maintenance procedures (338/78-37-03) - paragraph 17).
7901190196
.
.
.
RII Report Nos. 50-338/78-37 and 50-339/78-32 I-1 DETAILS I Prepared by:
8. C.
/2/#//f M. S. Kidd,' Resident Reactor Inspector Date Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch Dates of Inspection: October 2 - Novemb.er 3,1978 Reviewed by:
8. C.
o;A
/2/N/78 R. C. Lewis', Chief Date Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch 1.
Persons Contacted Virginia Electric and Power Company (VEPCO)
C. E. Arritt, Administrative Assistant 2/
W. R. Cartwright, Station Manager 1/2/3/4 W. F. Diehl, QC Engineer, Operations 3/5 M. E. Fellows, Technical Assistant, Records L. O. Goodrich, Supervisor, Mechanical Maintenance M. A. Harrison, QC Engineer, Construction J. R. Harper, Instrument Supervisor E. W. Harrell, Engineering Supervisor 2/4/5 S. L. Harvey, Operating Supervisor 2/3/5 D. M. Hopper, Health Physics Supervisor 4/5 J. H. Horton, Chemistry Supervisor 1/
G. A. Kann, Engineer J. D. Kellams, Superintendent, Station Operations 1/2/3/4/5 R. P. Kinsey, Supervisor, Electrical Maintenance J. W. Martin, Jr., Supervisor QA, Operations and Maintenance D. G. McLain, Engineering Supervisor 1/2 G. E. Pederson, Training Coordinator P. G. Perry, Senior Resident Engineer, Construction 3/
P. A. Slatter, Resident QC Engineer, Construction D. L. Smith, Resident QC Engineer, Operations 1/2/4 E. R. Smith, Jr., Supervisor, Engineering Services 1/2/3/4/5 B. R. Sylvia, Director, Nuclear Operations 3/
D. E. Thomas, Electrical Maintenance Coordinator 3/
D. C. Woods, Senior Engineering Technician 2/3/4/5
.
.
RII Report Nos. 50-338/78-37 and 50-339/78-32 I-2 Stone and Webster Engineering Corporation J. R. Broadwater, Lead Primary Plant Systems Engineer P. Craddock, Field QC Inspector, Mechanical R. J. Daly, Lead Advisory Engineer M. J. Dunston, Construction Acceptance Testing Engineer R. O. Potts, Supervisor, Document Control
,
1/ Denotes those present at management interview on October 6,1978 2/ Denotes those present at management interview on October 12, 1978 3/ Denotes those present at management interview on October 20, 1978 4/ Denotes those present at management interview on October 27, 1978 5/ Denotes those present at managt ent interview on November 3,1978 2.
Licensee Action on Previous Inspection Findings (Open) Unresolved Item (338/78-32-04):
Seismically Unqualified Auxi-liary Contacts.
Two additional sets of instantaneous contacts not having seismic qualification documentation were found installed in Unit 1 (Details I, paragraph 19).
3.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
One unresolved item disclosed during the inspection is discussed in paragraph 18 of this report.
4.
Management Interviews Management interviews were conducted on October 6,12, 20 and 27 and November 3, 1978, with station management and other licensee staff members denoted in paragraph 1.
All subjects presented in these Details were discussed.
The apparent Infraction involving document control (339/78-32-01) was discussed October 12, 20 and 27 with station management defining corrective measures which had been undertaken as of the two latter date.
.
RII Report Nos. 50-33B/78-37
.
and 50-339/78-32 I-3 The apparent Infraction involving inadequate procedures which resulted in spillage of contaminated water (338/78-37-03) was discussed on October 27 and November 3.
The inspector's findings were acknowledged and licensee management discussed corrective actions which had been initiated.
5.
Station Personnel Changes (Units 1 and 2)
.
Effective September 30, 1978, C. E. Necessary, formerly Superintendent of Station Operations, was assigned to the Production Operation and Maintenance Support group in VEPCO's corporate of fices.
T. D. Kellams, Operating Supervisor, was temporarily assigned as Superintendent of Station Operations and S. L. Harvey, Shift Supervisor, was temporarily assigned as Operating Supervisor.
Records of education, work experience, and related training for Kellams and Harvey were reviewed and compared to the requirements and sugges-tions for their respective positions given in ANSI N18.1-1971, "Selec-tion and Training of Nuclear Power Plant Personnel," which is referenced by Unit 1 Technical Specification 6.3.1.
These were also compared to FSAR Section 13.1.
No discrepancies were noted.
6.
Quality Assurance For Preoperational Testing (Unit 2)
The quality assurance plans and programs for preoperational testing of Unit 2 were reviewed and discussed with licensee personnel, including involvement to date, plans for future surveillance and audit activities, training for QA/QC personnel, and qualifications of selected individual findings were as follows:
a.
Program for Testing QA/QC involvement in the preop program is defined largely by ar Operational Quality Assurance Local Guideline entitled, "Preopera-tional Testing Program." This document implements QA/QC functions described in sections 5 and 11 of the Nuclear Power Station Quality Assurance Manual (NPSQAM).
It provides for an ov:rall review of the test program, including a comparison of specific tests to FSAR section 14 commitments and for audit / surveillance of each safety-related preoperational test. This overall program review is scheduled to be completed prior to the start of hot functional testing.
VEPCO's Construction QA group will audit system data packages at the time of conditional release of systems to VEPC0 for testing defined by Quality Assurance Construction Instruction 14.1, as
" Conditional Release Auditing."
.
.
RII Report Nos. 50-338/78-37 and 50-339/78-32 I-4 b.
Surveillances/ Audits to Date As of October 23, 1978, the only preoperational tests begun were 2-P0-16, " Reactor Containmont Isolation Valve Type
"C" Testing" and 2-P0-40, " Hydrostatic Test of Reactor Coolant System and Associated High Pressure Auxiliary System."
The inspector's observations regarding QC involvement during the conduct of 2-PO-40 were documented in IE Report 50-339/78-28.
Review of activity logs maintained by QA for 2-PO-16 and 2-P0-40 revealed no adverse findings requiring corrective action and reinspection.
c.
Personnel Qualifications Table 17.2-0 of VEP-1-3A, VEPCO's " Topical Repott - QA Program-Operat. ns Phase," states that QA/QC personnel qualifications will conform to ANSI N45.2.6-1973, " Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants." Records of education, related training, and work experience were reviewed for two inspectors, two inspector /
auditors, and the Resident QC engineer (onsite supervisor) and compared to the provisions of ANSI N45.2-6.
No items of noncom-pliance or deviations were identified.
d.
Training Program The training program for testing and operational QA personnel is defined by Section 7.1 of the "QA Operations and Maintenance Instruction Manual," dated July 19, 1977.
This program was reviewed and discussed with the Resident QC Engineer - Operations.
Tne program was found to cover the commitments of Section 5.2 of the NPSQAM. The inspector was informed that the training program was currently undergoing extensive revision. Review of the draft Instruction revealed it to be much more detailed and comprehensive, while retaining the features required by the NPSQAM. The inspector had no questions in this area.
7.
Administrative Controls for Preoperational Testing Prior inspection efforts in this area were documented in IE Report 50-339/78-26, Details I, paragraph 14.
As noted in that report, reviews were continuing in certain areas.
Those areas are discussed below.
a.
Coverage of Specific Tests in FSAR Table 14.1-1 As noted in IE Report 50-339/78-26, Details I, paragraph 14.b(1),
discussions had been held with licensee personnel to clarify /
verify that all commitments of FSAR Table 14.1-1 and, Regulatory
.
RII Report Nos. 50-338/78-37 and 50-339/78-32 I-5 Guide 1.68, "Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors," (1973) for conduct of preop tests would be covered. On October 27, 1978.
The inspector met with the test program director to conclude these discussions. Info rma-tion provided at that time confirmed that all testing committed to had been planned for and procedures identified. The inspector had no further questions in this area.
b.
Document Control - Drawings and Manuals Plant drawings and specifications for Units 1 and 2 are provided and updated by Stone and Webster. Changes to such documents may be initiated by VEPC0 or S&W. During the inspector's review of this functional area, the following documents were reviewed and discussed:
(1) Station Administrative Procedure 103, " Instructions for Deficiency Report s," dated October 28, 1977.
(2) Section 6 of the NPSQAM, " Document Control," of various dates through April 17, 1978.
(3) S&W Project Manual, Section 2.2,
" Engineering and Design Requirements, " dated July 21, 1978.
(4) S&W Engineering Assurance Procedure 6.1, " Document Control,"
dated April 14, 1978.
(5) S&W Nuclear Project Operating Procedure 500, " Field Procedure for the Control and Flov of Engineering and Design Coordination Reports (E&DCR)," dated February 2,1978.
(6) POP 717, " Document Control," dated April 6,1978.
Review of the above documents and discussions with VEPC0 and S&W personnel revealed that master indexes are available for drawings which indicate their current revision numbers and that a mechanism exists to ensure that affected test procedures will be updated when manual or drawing changes occur.
Within the area of provision of current, approved drawings to the site, it was found that the program for Units 1 and 2 contained a weakness, in that the " controlled drawings" maintained for use of operating and test personnel were not being routinely annotated to reflect existence of documents which af fected them. At present, S&W provides all drawing and specification revision and distribu-tion services for Units 1 and 2.
This is to continue until
.
.
RII Report Nos. 50-338/78-37 and 50-339/78-32 I-6 Unit 2 is operational and all master drawings are transferred from construction to operations, at which time VEPCO operations will handle changes as defined in Section 6, paragraph 5.1.2.c of the NPSQAM.
The construction program for drawing changes and annotation of drawings to denote documents such as Engineering and Design Coordination Reports (E&DCR) which may affect them is implemented by POP 500 and POP 717.
Paragraph 5.8 of POP 717 states that, " Controlled issues of drawings and E&DCRs shall be posted by the Document Control Field Clerk, except in those cases where the documents are transmitted directly to Accountable Holders authorized to maintain their own files." Paragraph 6.3.4 of POP 717 states that, "The Document Control Supervisor will insure that E&DCRs affecting any documents are directed to the appropriate Records Clerk, who will insure that the E&DCR number is posted to the affected document at the Accountable Holders station." Discussions with S&W Document control personnel revealed that only the controlled documents held by coretruction are updated / posted by them and it was assumed that VEPCO operations records personnel were updating their own controlled documents as allowed by POP 717. Operations personnel informed the inspector that they had believed the documents received f rom S&W to be already posted / updated except for North Anna Specifications. It was also revealed that VEPCO operations had requested some months previously to be taken off of the distribution list for E&DCR's except for those which affect Specifications.
Licensee management was informed October 20, 1978, that this app ared to be in noncompliance with Criterion VI of Appendix B to iL CFR 50 and Section 17.1.4.6 of the FSAR which requires, in part, that measures be established to assure that documents, including changes, are reviewed, approved, and distributcd to and used at the location where activities prescribed in those documents are performed. In that the construction document control program in effect does not assure updating of cont-olled documents held by operating and test personnel and the operations program per Section 3 of the NPSQAM is not in effect yet, the overall progrom appears to be deficient in this area.
Licensee management agreed that the program was deficient and stated that measures were being under-taken to correct the problem. The inspector stated that corrective measures on the matter, which appeared to be in noncompliance (Infraction 339/78-32-01) with Criterion VI of Appendix B to 10 CFR 50 would be inspected as they are implemented.
An unresolved item for Unit 1 (338/78-27-01) had been previously identified concerning updating of Unit I drawings and remains ope RII Report Nos. 50-338/78-37 and 50-339/78-32 I-7 c.
Design Changes and Modifications Design changes for Unit 2 will be controlled by the construction /
S&W program until the operating license is issued, when the operational program as defined by Section 3, " Design Changes," of the NPSQAM becomes effective.
Documents reviewed during the inspection of this functional area included the following:
VEPCO Quality Assurance Manual Section 3.1, " Design Control
.
Engineering and Construction," dated April 4,1978.
Sr' EAP 6.1, " Document Control," dated March 11, 1977
.
EAP 5.4, " Review, Approval of Project Production Drawings,"
.
dated June 8,1978 EAP 2.9,
" Preparation, Review, and Control of Licensing
.
Reports,' dated July 17, 1978.
.
EAP 6.3,
"Preparatica, Review, Approval, and Control of Engineering and Design Coordination Reports," dated July 17, 1978.
POP 717, " Document Control," dated April 6,1978
.
POP 814, " Procedure for the Release, Testing and Turnover to VEPC0 Operations of Installed Systems," dated' April 28, 1978.
ADM 103, " Instructions for Deficiency Reports," dated
.
October 28, 1977.
ADM 104, " Implementation of A-E Construction Design Changes
.
after Receipt of Operating License," dated February 24, 1978.
Review of the above revealed that:
(1) A formal method has been established for initiating, reviewing and approving requests for design changes and modifications to equipment that has been turned over to the test group for preoperational testing.
(2) The review process provides for assuring that all proposed plant changes are reviewed for potential rSAR and unreviewed safety question impac RII Report Nos. 50-338/78-37 and 50-339/78-32 I-8 (3) When the review process above identifies the need for a change to the FSAR and/or proposed Technical Specifications, procedures and responsibilities are established to assure that the changes will be made.
(4) Controls have been established to assure that design changes will be subjected to measures commensurate with those applied to the original design.
(5) A formal method has been established to bring proposed or implemented design changes to the attention of the test group for incorporation into the test program.
Except for the related matter of updating controlled documents to annotate proposed or implemented design changes discussed in paragraph 7.b, there were no questions in this area.
d.
Preventive Maintenance Program Preventive maintenance for the station is made up of programs administered by the electrical and mechanical maintenance groups and the instrument group.
These programs are defined by the following documents:
(1) Administration of the North Anna Power Station Mechanical Maintenance Preventive Maintenance Program (2) North Anna Power Station Planned Maintenance System, Electrical (3)
1-PT-32.7.1, Safety Related Instrument Calibration The programs contained in (1) and (2) above have been in effect for Unit I and will be implemented gradually for Unit 2 as systems are turned over to VEPCO.
Document (3) was in draft at the conclusion of the inspection; in that most of the calibrations performed are done on a refueling of eighteen month basis, the program has not been fully implemented for Unit 1 or 2.
Program (3) will control scheduling of all preventive maintenance - type calibrations for all instruments considered to be safety related.
This is determined by either the safety significance as to whether the instrument is needed to fulfill a Technical Specification surveillance requirement.
Individual calibration procedures for more esoteric pieces of equipment (e.g. oxygen analyzers) were also in preparation at the conclusion of the inspection. These procedures will be reviewed and discussed further when finalized (open items 50-338/78-37-04 and 50-339/78-32-03).
RII Report Nos. 50-338/78-37 and 50-339/78-32 I-9 e.
Water Chemistry Controls Discussions with the station chemistry Supervisor and review of applicable documents revealed that controls for fluid systems undergoing preoperational testing have been established, including water quality requirements, layup of systems, sampling requirements, and corrective actions for out-of-specifi. cation conditions.
Documents discussed were:
WCAP 7452, " Chemistry Criteria and Specifications" (RCS
.
Makeup), dated March,1977.
WCAP 8113, " Steam Side Water Chemistry Control Specification,"
.
dated Janua ry,1975 Primary Water Sources, the Pure Grade (PG) water tanks and the Refueling Water Storage Tank, are maintained in accordance with WCAP 7452. These tanks are sampled on a daily basis. The inspector had no questions in this area.
8.
Implementation of Administrative Controls for Preop Testing During the inspection discussions were held with D. G. McLain, Engineer-ing Supervisor, who will function as the preop test program director and G. A. Kann, who will be the lead test engineer, to ascertain their degree of familiarity with administrative controls for conduct of the program. Responses to questions posed by the inspector revealed that these individuals were familiar with and understood the following:
a.
Responsibilities of key test personnel, including themselves; b.
Method and responsibility for appointing test personnel; c.
Lines of authority and responsibility; d.
Organizational interfaces for organizations involved in the test program; and e.
General description of the test program.
The inspector had no questions on the results of the above discussion RII Report Nos.. 50-338/78-37 and 50-339/78-32 1-10 9.
IE Bulletins a.
IEB 78-05, Malfunctioning of Circuit Breaker Auxilit y Contact Mechanism - General Electric Model CR 105X This IEB was reviewed for Units 1 and 2 in July, 1978 and closed for Unit I at that time. The licensee's review for Unit 2 was not complete, thus an open item (339/78-22'01) was identified.
By letter dated August 4, 1978, Serial No. 444, the licensee stated that none of the auxiliary contacts in question were used in Unit 2 safety related systems.
Open item 339/78-22-01 is closed.
b.
IEB 78-10, Bergen-Paterson Hydraulic Shock Suppressor Accumulator Spring Coils The response to this IEB was addressed and closed for Unit 2 in IE Report 50-339/78-23.
The licensee addressed this IEB for Unit 1 in separate correspondence, dated August 17, 1978 (Serial No. 391).
That letter stated that no Bergen-Paterson snubbers are installed in Unit 1.
Licensee personnel were informed that there were no further questions on this IEB for Unit 1.
10.
Licensee Event Reports Review (Unit 1)
The following LER's were reviewed to verify that reporting requirements had been met, corrective action taken, licensee personnel reviewed each event, no unreviewed safety questions existed, no violations of regulations of license conditions were involved, and corrected LER's had been submitted, if required.
a.
LER 78-34, Safety injection As noted in the LER, following a reactor trip conducted as part of a startup test on April 28, 1978, a condensor dump value stack open, causing cooldown of the reactor coolant system (RCS) and an SI from low pressurizer pressure and level. The test was being witnessed by IE Inspectors at the time of the SI (IE Report 50-338/78-13, Details I, paragraph 9.b).
The RCS experienced a cooldown of 105 F in less than one hour, exceeding the 100 F per hour limit of Technical Specification 3.4.9.1.
Evaluation of the cooldovr. by Westinghouse revealed that limits of ASME-III and Appendix G to 10 CFR 50 were not violated.
The inspector questioned licensee personnel as to why the event lasted five to six minutes.
He was informed that, although the operator would normally close the main steam isolation valve on the affected header, in this case the operators had been previously
RII Report Nos; 50-3.8/78-37 and 50-339/78-32 I-11 instructed to perform as few manual functions as possible due to the test in progress, 1-SU-36, " Unit Shutdown From Outside the Control Room."
b.
LER 78-35, Safety Injection Another SI was experienced April 30, 1978.with Unit 1 in Hot Standby.
Evaluation by station personnel revealed that although one high steam line flow channel was tripped with a surveillance test in progress, no supporting evidence for a second channel trip could be found, thus the event was concluded to be spurious.
(Two of three steam flow channels in conjunction with low-low T average required for SI).
Review of this event revealed that very little cooldown of the RCS occurred.
The inspector stated that there were no further questions on these two events, but that all pertinent information, such as the operator conditioning which prolonged the first SI, should be included in the written reports. This comment was acknowledged.
11.
Quality Assurance Records Storage Facility (Units 1 and 2)
During the operational QA audit for Unit 1 in September, 1976, it was found by NRC inspectors that the physical records storage facility did not meet the provisions of ANSI N45.2-9,1974, and duplicate records were not being maintained. Also, in September, 1976, VEPCO committed through its Topical Report for Operational QA, VEP-1, that a new record storage facility would be constructed by June of 1978.
This Topical Report was accepted by NRR.
In December, 1977, Region II inspectors noted that construction of the storage facility had not been started and an open item (77-57-04 for Unit 1) was identified for followup inspection. On May 5, 1978, VEPCO notified IE:II by letter No. 260 that the facility was expected to be complete by July of 1979. This matter of extension of the completion date for the facility was reviewed by IE Headquarters and NRR and found to be acceptable.
Licensee personnel were informed that the inspector had no further questions at that tice, but that item 338/77-57-04 would remain open.
12.
Operating Staff Training On October 25, 1978, the inspector attended a training lecture for nuclear instrument technician trainees conducted by the station training organization. The lecture covered the Westinghouse P-250 computer and the Hathaway annunciator and event recorder systems and was part of
.
RII Report Nos.- 50-338/78-37 and 50-339/78-32 I-12 the indoctrination program for trainees in steps 1 and 2 of VEPCO's
" Nuclear Instrument Technician Development Program."
This program consists of eight (8) steps, each lasting about six (6) months. The material covered on October 25 was in agreement with the g neral plans and schedules of the development program. The inspector had no ques-tions in this area.
.
13.
Plant Tours Periodic tours of selected plant areas were conducted during the inspection period, with emphasis on Unit 2 areas. During these tours, conducted October 2, 12, 17, and 24, 1978, the following items were observed as available for inspection:
a.
Hot Work: Adequacy of fire prevention / protection measures used.
b.
Fire Equipment: Operability and evidence of periodic inspection of fire suppression equipment.
c.
Housekeeping: Minimal accumulations of debris and maintenance of required cleanness levels in systems under or following testing.
d.
Equipment Preservation:
Maintenance of special preservative measures for installed equipment as applicable.
e.
Component Tagging:
Implementation and observance of equipment tagging for safety or equipment protection.
f.
Instrumentation: Adequate protection for installed instrumentation.
g.
Cable Pulling:
Adequate measures taken to protect cable from damage while being pulled.
h.
Communication:
Effectiveness of public address system in all areas of the site.
i.
Equipment Controls:
Ef fectiveness of jurisdictional controls in precluding unauthorized work on systems turned over for testing.
j.
Foreign Material Exclusion:
Maintenance of controls to assure systems which have been cleaned and flushed are not re-opened to admit foreign material.
k.
Security:
Implementation of security provisions.
Particular attention to maintenance of the Unit 1/Uait 2 interf ac.
.
RII Report Nos. 50-338/78-37 and 50-339/78-32 I-13 1.
Testing: On October 12, the adequacy of a hydrostatic test in progress on a portion of the primary vent and drain system was spot-checked. The testing was conducted per S&W Field Quality Control Procedure QC 15.2, " Inspection Requirements for Hydrostatic Testing of Installed Systems." The inspector observed a portion of the walkdown of the system while at test pressure.
It was also observed that a test gauge with a current calibration sticker was in use and marked up flow diagrams defining test boundaries were being using by the Advisory Engineer, the Authorized Nuclear Inspector (Code Inspector) and an FQC Inspector during their walkdowns. The inspector had no questions on this test.
During the tours of October 2 and 17 the inspector was also acting as a tour guide for members of the Office of the Secretary of the Commission (NRC).
No significant adverse findings were made during the tours.
Minor comments were given to station management for their consideration.
14.
Station Emergency Drill On October 20, 1978, an unannounced emergency drill was conducted per Section 7.1.2 of the station Emergency Plan, which requires an annual exercise to evaluate effectiveness of the Plan. This type of exercise is used to determine the operating staff's ability to classify and handle emergencies. determine the ef fectiveness of the station emergency organization in handling emergencies, check communications with offsite agencies, and to verity adequacy of evacuation and accountability procedures.
The inspector observed the drill from the Units 1 and 2 control room in order to evaluate personnel responses within the scope of the drill scenario.
Members of plant management and QC personnel were stationed at various strategic locations in order to evaluate responses.
The drill involved simulated rupture of a waste gas decay tank which contained radioactivity levels requiring evacuation of portions of the plant, but not a total plant evacuation.
Responses by control room personnel appeared to be orderly.
Immediately following completion of the exercise, plant management gathered for a preliminary critique.
The inspector attended this meeting. Observations were given by each member of management.
These were recorded and were compiled, along with critique checklists, for later review during an official meeting of the station Nuclear Safety and Operating Committee.
All of the inspectors observations wera encompassed by those of plant management.
An independent critique was developed by QC. This writeup was forwarded to the QA Supervisor - Operations and Maintenance for inco rpo ra t i sn into an overall operations audit performed for the System Nuclear Safety and Operating Committe RII Report Nos. 50-338/78-37 and 50-339/78-32 I-14 In that weaknesses in emergency procedures and response techniques were identified and corrective actions planned, it appeared that the purposes of the drill had been secomplished.
Station management was informed that the inspector had no further questions at that time.
15.
Preop Test Witnessing - Unit 2 On October 24, 1978, the inspector observed fluthing activities in progress for "C" safety injection accumulator fill line (SI-465-602-Q2).
The flushing was conducted per S&W Advisory Operations flush procedure AD-0PS-2-P-8 and NAS Specification 407, " Cleaning of Systems and Components during Construction," with flush water being taken from the Unit 2 refueling water storage tank.
Three sample cloths were taken on the above date, with the last one being accepted by FQC and Advisory.
The performance of sampling and interpretation of deposits on the cloths were observed to be in accordance with NAS 407.
Within the scope of testing witnessed, no discrepancies were noted.
16.
Comparison of As-Built System to FSAR Description - Unit 2 10 CFR 50.57(a)(1) requires, in part, that before an operating license is issued, the facility will have been substantially completed in conformity with the application (FSAR), as amended.
As a means of determining the completion status of Unit 2 and the accuracy of FSAR information, the inspector selected flow diagrams for the reactor coolant system (RCS) for comparison to FSAR drawings and actual field installation.
The latest available station drawings, FM-93A and FM-93B (both Revision 9, dated March 1, 1978), were compared to FSAR Figures 5.1-1 and 5.1-2, dated July 1, 1977. This preliminary review, still in progress at the conclusion of the inspection period, revealed minor differences such as vent and drain valve locations.
During discussions on this matter, station management stated that the FSAR drawings would soon undergo extensive revisions through the amendment process.
Comparison of the actual installations of piping and components to the above drawings was also continuing at.the conclusion of the inspection period.
17.
Contaminated Water Spill Unit 1 On October 24, 1978, several hundred gallons of contaminated water from the chemical and volume control system (CVCS) were inadvertently spilled onto the floor of the auxiliary building basement level,
RII Report Nos. 50-338/78-37 and 50-339/78-32 I-15 resulting in contamination of thirteen persons and indirect shutdown of Unit 1.
Discussions with station personnel and review of selected station documents revealed the information given in the following paragraphs.
On the day shift (8:00 a.m. - 4:00 p.m.) on October 24, the alternate RCS charging header from CVCS was removed from. service, including draining of portions of the line, to allow repairs to leaking packing on 1-CH-280, an isolation valve for a flow element in the line.
Draining was through vent valve 1-CH-282.
In accordance with VEPC0 custom, these two valves were not physically tagged, but they were listed on the " Tagging Record," a form utilized per NPSQAM Section 16 for maintenance activities.
They were entered as " Drains Open" by valve number on the lower half of the Tagging Record (N1003904).
At shif t turnover, the status of the line was discussed by the oncoming Assistant Control Room Operator (ARCO) and the ACRO he was relieving.
This turnover included a detailed discussion af the line status, including how it had been drained and the fact that drain valves were still open.
Turnover between the Shift Supervisors apparently esta-blished that the line was "out of service" with no other details.
On the 4:00 p.
to 12:00 p.m.
shift, the ACR0 asked the supervisor
.
for permission to clear the tags on the header and was given permission and instructions on how to do it.
The Tagging Record was partially covered when presented to the supervisor, such that he still was not aware that the line had been drained (lower portion covered). Shortly after the ACR0 had gone to the auxiliary building to clear the tags (approximately 5:45 p.m.) the control room operator noted a decreasing volume control tank level and decreasing reactor coolant pump (RCP)
seal injection flow from the CVCS.
Attempts to contact the ACR0 who was clearing tags failed and other individuals were dispatched to find him, investigate the apparent loss of water, and increase RCP seal injection. At about 6:05 p.m., the open valves were closed and an eva-cuation of the auxiliary building was begun.
Water from the open valves spilled onto the floor of the auxiliary building (approximately 1,000 gallons or more) and collected in drains and s umps.
Some water splashed onto the controls for a component cooling water valve which controls flow of cooling water to a Unit 1 RCP thermal barrier (one type of cooling), causing it to close. Due to increasing temperatures on the RCP, operation personnel decided to trip the reactor (approximately 6:13 p.m.) and shut down the RC,
RII Report Nos. 50-338/78-37 and 50-339/78-32 I-16 Thirteen persons were contaminated as a result of the event. They were successfully decontaminated onsite.
No significant release of radio-activity to areas outside the plant was evident.
Details of the
-
radiological aspects of the event are given in IE Report No. 50-338/
78-34.
Licensee management was informed that it appeated that procedures available to control this type of evaluation were not adequate to meet the requirements of Technical Specification 6.8.1.a.
This specifica-tion requires that written procedures be established, implemented, and maintained for those procedures in Appendix A of Regulatory Guide 1.33, November 1972.
Sections I.4 and I.5 of RG 1.33 Appendix A address procedures for draining and refilling and control of maintenance, respectively. The inspector stated that lack of procedures to ade-quately control these functions appeared to be in noncompliance (Infraction 338/78-37-03) with Technical Specification 6.8.1.a.
When the auxiliary building was evacuated, an individual serving as a watch for a manual containment isolation valve on the instrument air system was also evacuated. This valve is normally closed, but can be opened under administrative control - maintenance (if a watch who would shut it if an accident requiring containment isolation occurred (Tech-nical Specification Table 3.6-1).
Evacuation of the watch resulted in entry into the action statement of Technical Specification 3.6.3.1 and a thirty day report (LER) is due by November 24, 1978.
18.
Settlement of Class I Structures On October 24, 1978, the inspector was advised that analysis of survey measurements had indicated possible differential settlement between Unit I containment and the Unit I safeguards building, points 143 and 142 of Technical Specification Table 3.7-5, respectively. A prelimi-nary review indicated differential settlement of 0.032 feet, which is greater than 75% of the total allowed (0.04 feet) and thus reportable per speci fication 3.7.12.1.a. An in-depth analysis by station personnel revealed that the original comparison had used data from dif fering seasons of the year because data for point 142 was not available for the total time frame from baseline of May 1976 (Bases for Specification 3/4.7.12) to May of 1978, at which time the latest surveys were made.
This point had been reset (moved or lost) twice during the above time frame due to construction activities and apparently no correlations could be made to provide continuity of data. Licensee's analysis of seasonal fluctuations for other points on containment and the safeguards building and other structures around containment revealed a differential settlement of 0.008 feet for points 143 cad 142, well within the limi-tations of Table 3.7-5.
An indepth inspection by a Region II Specialist is planne '
.
.
RII Report Nos. 50-338/78-37 and 50-339/78-32 I-17 The analysis by station personnel did reveal however, that in addition
-
to point 142, several other settlemen*, points can not be monitored as required by Specification 4.7.12.1 due to either resetting of survey points after May 1976, or the fact that the points were not esta-blished until after that date. Based on discussions with plant manage-ment and review of related data, the inspector estimated that as many as half of the points listed in Table 3.7-5 (tota.1 of 33) do not have continuous data back to the baseline date.
Station management was informed that this would be considered an unresolved item (338/78-37-04). The inspector was informed by station management that the problem would be addressed in correspondence to the NRC, defining the problem and probably requesting changes to the Technical Specifications.
This is identified as an open item on Unit 2 (339/78-32-03) to assure that those Technical Specifications accurately address baseline data which is available.
During these discussions, the inspector was also apprised that at times three or four months have elapsed between the time surveys were made and actual recording of final data in the periodic test form for final comparison of data.
The inspector stated that this amount of delay was not acceptable. Plant management concurred. Time'iness of data reduction will be reviewed further when the unresolvad and open items denoted above are reinspected.
19.
Non-Seismically Qualified Auxiliary Contacts feni
- )
.
LER 78-51 for Unit 1 identified instances whe:
field added instan-
.
taneous relay contacts where found to be unqualified seismically (Unresolved Item 338/78-32-04).
On October 25, 1978, the inspector was informed by plant management that two additional contacts had been found without appropriate documentation through the continuing investi-gation. These were found in the control circuits for sodium hydroxide addition valves QS-102A and QS-102B. This was reported as a prompt LER per Technical Specification 6.9.1.8 and a written report is to be submitted by November 7,1978.