IR 05000338/1988036
| ML20247F036 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/21/1989 |
| From: | Caldwell J, Fredrickson P, King L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20247F032 | List: |
| References | |
| 50-338-88-36, 50-339-88-36, NUDOCS 8904030297 | |
| Download: ML20247F036 (16) | |
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i(-..yntary UNITED STATES A
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REGION 11 '
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101 MARIETTA STREET, N.W.
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~ ATLANTA, GEORGIA 30323
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Report Nos.: 50-338/88-36 andL50-339/88-36 Licensee:. Virginia Electric & Power Company Richmond, VA 23261 Docket Nos.: 50-338 and 50-339 License hos.:
NPF-4 and NPF-7-
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- Facility Name: North Anna 1 and 2 Inspection.Condu ted: December 31, 1988 through February 2, 1989
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' Inspectors:
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Jf L. Caldyell,'Serii Resident Inspector Date ' Signed r
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Kin Resid~ent Inspecto Date.51gned
3/.n/M Approved by: i, W
P.' E. FrYdrickson, Section Chief Da'te Signe6 Divisicn of; Reactor Projects SUMMARY.
Scope:
This1 routine inspection by the resident inspectors involved the following areas:
plant status, maintenance, surveillance, operational safety verification, and licensee ' event report (LER)
followup.' During the performance.cf this inspection, the resident inspectors conducted reviews of the-licensee's 'backshift operations on the following days: December'30, 1988; January 5, 12, 13, 20,<21, 25, 26,'30 and February 2, 1989.
Resultsi Within the areas inspected, one example of an apparent violation, seven. additional examples of a violation cited in NRC Inspection Report 338,339/88-31, one Unresolved Item, and' one Inspector Followup Item (IFI) were. identified.
(0 pen)~ Apparent Violation 338,339/88-36-01, Failure to take prompt and adequate corrective action concerning inadequate instrument air quality.
(Paragraph 4)
(0 pen)
Violation 338,339/88-31-02, Seven additional examples of a violation listed in NRC Inspection Report 338,339/88-31 for failure to follow procedures.
(Paragraph 5)
(0 pen)
IFI 338,339/88-36-02, Tagging of the boric acid vent and drain valves.
(Paragraph 5)
ADOCK 00000338Q@
8904030297 890327 PDR G.
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(0 pen) * Unresolved Item, 338,339/88-36-03, Region II health physics staff review of the violation of radiation work permit requirements.
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(Paragraph 5)
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- Unresolved items are matters about which more information is required to determine whether they are acceptable, or may involve violations or deviations.
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REPORT DETAILS
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1.
' Persons Contacted Licensee Employees M. Bowling, Assistant Station Manager.
J. Downs, Superintendent, Administrative Services,
- R. Driscoll, Quality Control Manager
- R. Enfinger,' Assistant Station Manager G. Gordon, Electrical Supervisor
- L. Hartz, Instrument. Supervisor D. Heacock, Superintendent, Technical Services
- G. Kane, Station Manager.
- T. Porter, Superintendent, Engineering
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- J. Stall, Superintendent, Operations
- A. -Stafford, Superintendent, Health Physics F. Termine11a, Quality Assurance Supervisor D. Thomas, Mechanical Maintenance Supervisor Otherzlicensee employees contacted included engineers, technicians, operators, mechanics, security' force members, and office personnel.
- Attended exit interview
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2.
Plant Status Unit 1 The. inspection period began with Unit 1 operating at 100% power. On January 15, 1989, the unit commenced a coastdown to the refueling outage at a reduced TAVG of 584 degrees F and 100% power. The inspection period ended on February 2, 1989, with the unit operating at 9.9% power and
581.9 degrees F.
Unit I has been operating continuously on line for 175 days.
Unit 2 The inspection period began-with Unit 2 in a coastdown to the refueling outage with a TAVG of 577 degrees F and 100% power. The inspection period
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ended with the unit operating at 68.2% power and 571.5 degrees F (TAVG),
i and the unit has been operating on line continuously.for 354 days.
3.
Maintenance (62703)
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L Station maintenance activities affecting safety related systems and components were observed / reviewed to ascertain that the activities were
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conducted in accordance with approved procedures, regulatory guides and
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industry codes or standards, and were in conformance with Technical l
Specifications.
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During this inspection period, the inspector witnessed maintenance
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conducted on Unit 1 Quench Spray Pump recirculation check valve, per work order 001554.
The licensee discovered that the disc lock nut had come loose causing excessive play between the disc and the swing arm, preventing the disc from seating fully. An engineering work request was written to tighten the nut and tack weld it to the stud. The recircula-tion line is normally isolated and used for test purposes, and does not affect system operability.
On January 9, 1989, the inspector witnessed work on 2-QS-FT-204, flow transmitter for the Quench Spray Pump. recirculation line.
Instrument technicians were replacing the flow instrument transmitter manifolds located inside the instrument enclosures near the refueling water storage tank.
The procedures and radiation work permit were reviewed and no problems were identified.
On January 12, 1989, while witnessing installation of heat lamps in the Unit 1 pipe tunnel, the inspector noted that the auxiliary feedwater piping to the steam generators was severely corroded.
On January 13, 1989, the licensee was requested by Region II management to evaluate the wall thickness of the piping. An inspection of the piping was conducted and indicated that the piping was above the minimum wall thickness. The corrosion was caused by the piping being submerged in ground / rainwater for extended periods of time.
The licensee installed an air operated sump pump in the pipe tunnel to preclude recurrence of the problem.
The licensee also removed the rust from the piping.
On January 10, 1989, the inspector and Region II Section Chief inspected the emergency nitroger, backup to the service air supply for inflation of the spent fuel pool transfer gate seals. This gate is installed between the fuel pool and transfer canal. The service air piping and supply from the nitrogen bottle were walked down by the inspectors, and this walkdown revealed that most of the valves and the nitrogen bottle were not labeled.
The inspectors then reviewed the alarm response procedure for low spent fuel pool level. This procedure contained no reference to the use of the emergency nitrogen bottle as a backup supply for loss of service air. The inspectors informed the licensee of their findings and were told that the procedures were already in the process of being revised to reflect the backup nitrogen bottle and associated valves, and that the updates would -
be completed prior to the refueling outages.
On February 1,1989, the inspector re-checked the service air valves and nitrogen bottle and found that the licensee had labeled all of the valves and the bottle. A review was conducted of the alarm response procedure 1-AR-27.1, " Loss of Spent Fuel Level" and abnormal procedure 1-AP-27.3,
" Placing Nitrogen Backup in Service to SFP Gate Seal", both dated January 12, 1989.
This review indicated that these procedures had been updated appropriately.
No violations or deviations were identified.
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4.
Sur'veillance(61726)
The. inspectors observed / reviewed Technical Specification required testing -
. and verified that testing was performed in accordance with - adequate procedures, that test instrumentation was calibrated,.that. limiting conditions ~ for operation (LCO) were ' met and that any deficiencies identified.were properly reviewed and resolved.
During this inspection period, the inspe " ors reviewed problems associated with air operated valves, deficiencies in the instrument air system, and associated -Justifications for Continued Operation (JCO). -The NRC expressed concern about the licensee's corrective action program with.
regard to the valve -and air system problems in an Enforcement Conference on February 7,1989. The following describes the inspectors review in-these areas.
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a.
Air Operated Valve Problems On January 9, 1989, the. inspector noticed that the control room annunciator " Auxiliary Feed Pumps Discharge Valves 1-FW-HCV-100 A/B Not Full Close" was lit.
The inspector questioned the control operator about this condition and was told that valve 1-FW-HCV-100B was open because water had been detected in the air supply during a surveillance test. These valves are closed by air and controlled from the control room ' console. After further inquiry, the inspector determined that durir.g periodic test 1-PT-71.2, Auxiliary Feedwater Pump (1-FW-P-3A) and ~ Valve Test, on January 4,1989, the operator noted that the valve operated sluggishly. A resultant inspection by an instrument technician noted water in the controller. A priority work request was submitted dated January 7, 1989, to perform work on the controller.
During the performance of the work request on 1-FW-HCV-1008, water was discovered in the controller and in the diaphragm at the top of the valve. The licensee inspected and repaired, as necessary,-the controllers and operators' for both Units 1 and 2 auxiliary feedwater system air operated valves.
During valve inspection, the licensee found water in varying amounts in all of the auxiliary feedwater valves in both units. The licensee was able to demonstrate that, even though undesirable, the presence of water in the controllers did not render the valves inoperable.
During this inspection period, the inspector also reviewed valve manipulation procedure 1-MISC-27, Instrument Air Blowdown for 1988.
This review indicated that moisture had also been discovered in auxiliary feedwater valves on September 4 and September 15, 1988.
On September 4, 1988, about 76 mis. of water were drained from the regulator supplying instrument air to the 1-FW-HCV-100B controller.
A work request (#374420) was generated to inspect for water in the valve controller, and the work request indicated that water had been blown from the air supply line over a period of 21/2 hours on
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September 7, _1988.
On September 8, 1988, after sitting overnight, a
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steady stream of water was drained from 1-FW-HCV-100B instrument air i
lines for 7 1/2 minutes.
Maintenance identified the need for
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engineering to investigate and resolve the problem.
Engineering attributed the problem of water in the valve regulator to condensa-tion in the air lines leading to the auxiliary feedpump house. These air lines run from the bottom of the quench spray basement through a pipe tunnel to the auxiliary feed pump room. The manholes over the pipe tunnel had been uncovered during the night, allowing the temp r-ature in the pipe tunnel to drop below the dew point of the instru-ment air. The corrective action was to replace the manhole covers and keep blowing the water out of the instrument air lines. However, it does not appear that the controller was inspected during the performance of the maintenance.
The September 15, 1988 performance of 1-MISC-27 indicated that a trace of moisture existed in the regulators for auxiliary feedwater pressure control valves (PCV's),1-FW-159A and B.
No work request was generated to determine the cause and corrective action for these valves.
Past problems have been noted with solenoid operated valves (SOV)
during inspec 'ons conducted January 25-29 and February 8-12, 1988, (NRC Inspection Report 338,339/88-02). As a result of NRC concerns, Virginia Power elected to shut down both units to inspect, repair or replace-suspect solenoid valves.
In addition, an Enforcement Conference was held on March 28, 1988, as a result of the violations j
identified in Inspection Report 338,339/88-02.
The licensee
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responded to the violation by letter dated June 27, 1988, and stated that an analysis was performed on several of the valves to determine the failure mechanism. This included a nondestructive examination and chemical analysis. The response further stated that the assessment of the valves was not complete and a more detailed inspection of S0V's would be performed during the next refueling outage (May 1989).
As background information, service water was inadvertently introduced to the instrument air system in April 1987, during a Unit,1 outage.
The intrusion occurred while the licensee was blowing service water out of the Recirculating Spray Heat Exchangers (RSHX) with air, following the completion of the Type C testing of the RSHX isolation valves. This process is conducted so that the RSHXs are left in the required dry and clean condition to ensure the proper fouling factor is maintained. To perform this evolution, the operators installed an air manifold which inadvertently interconnected the instrument air and service air systems. Due to a 20 psid difference between service air and instrument air, the service water in the RSHXs was forced into the instrument air header.
The intrusion was discovered when water was observed flowing from the instrument air lines in the Quench Spray building. The instrument air lines for both units were blown down to remove the service water.
But due to the physical location of the blowdown valves, water that intruded past the
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auxiliary jfeedwater ' valve air regulators' into the valve controllers would' not-have been removed without physically disassembling the i
iL controller and valves.
Check valves in the instrument air lines
'should have prevented water from intruding into. areas. in the'
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auxiliary building, with the exception of the component cooling water as outlet valves for. the residual-heat. removal heat exchangers.
The
' inspector < could 'not-verify 'that these 1.ines had been blown down.
during the:1987 intrusion.
A chemistry sample of the water found in the controller of feedwater valve 1-FW-HCV-1008 in January 1989 indicated the presence'of. service-
. water in the air supply. This is the same controller in which waters was found in September 1988, indicating that in both cases, a portion of the water was due to intrusion from the service water system.
b.
Compressed Air System
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The. instrument air system was designed with ' two air compressors powered from. the emergency bus, with cooling supplied by ' service water.
Two service air compressors were also provided to back-up the instrument air system.
The instrument air system contains refrigerant type dryers, and both instrument air and service air
. are designed as oil free systems.
However, due to unreliability-of the. originally designed compressed air. system, the. licensee --
installed oil-lubricated. temporary. Sullair compressors to supply instrument air'in about 1982, and as early as 1983, construction. air-was tied to the service air headers, to supply service air.
The ' inspector reviewed design changes and preventive maintenance associated with the compressed air system, as well as corrective actions.
A review of the Design Change Package which installed the temporary Su11 air compressors indicated that conditions had changed which invalidated the original assumption of the 10 CFR 50.59 review.
The review stated that the probability of an accident or the conse-quences of an accident or malfunction of equipment as previously evaluated in the Updated Final Safety Analysis Report (UFSAR) was not increased.
However, because of the degraded condition of the origiral air compressors the probability of occurrence has been increased with the complete reliance on the temporary Su11 air com-pressors. For example, the UFSAR states in paragraph 9.3.1.3.1 that a loss of air can only occur from a rupture of the main instrument air headers or major subheaders but not due to a loss of offsite power.
The presently installed Sullair compressors, which are used for instrument air instead of the original compressors, are not powered from the emergency bus and therefore a loss of offsite power would result in a loss of instrument air.
In addition, only one original instrument air compressor is presently considered operable by the licensee. This compressor could not supply the needs for botn units.
The licensee intends to make the original air compressor:,
operable and will eventually replace them with new compressors.
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The Design Change packages for installation of the Su11 air
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compressors also indicated that the UFSAR needed to be changed. A review of the controlled document and revision sheet indicated that this was r.ever completed even though the design change package was signed off as complete. Several changes to the UFSAR are necessary to properly represent the present configuration of the instrument air system.
With regard to preventive maintenance, the inspector reviewed tech-nical manuals that contain the vendor's recommended preventive maintenance procedures and the associated parameters that should be monitored. A review of the maintenance history for the compressed air system indicated that only part of the recommended preventive maintenance was being accomplished.
Work request 376311 was written in May 1988 on the Sullair compressor drye r.
This work request indicated that the refrigerant pressures were low and the coils were dirty. The pressure was low due to a ieaky pressure switch. This pressure switch was not replaced and the unit was not recharged until September 1988. The dryer may not have been capable of removing the proper amount of moisture required to keep the instrument air quality within the appropriate guidelines during this time.
Numerous work orders were written to repair blowdown line blockage and repair the original instrument air dryers. The inspector noted
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that work order tags were hung on both of the original instrument air dryers for extended periods of time indicating low refrigerant pressure.
The inspector traced out the system in the auxiliary building and noted that on January 10,.1989, the crossover valve 1-1A-1671 was open allowing service air to supply the instrument air system. This allows oil and moisture laden service air to bypass the receivers and tie directly into the inlet of the dryers.
It can be reasonably assumed that due to the malfunction of the dryers, moisture and oil was carried over into the instrument air system from the construction air compressors which supply service air.
The original service air compressors are out of service and construction air is used to feed the service air system.
Work request 375512 was written in June 1988 to repair the coalescent filter on the discharge line from the Sullair compressor.
This filter was isolated and bypassed for a significant period of time in 1988, allowing oil to carry over into the instrument air system.
The design changes to the compressed air system and the inadequate preventive maintenance contributed to oil contamination in the air supply. A review of licensee internal letters dated March 3,1988 and March 29, 1988, indicated that the licensee was aware of the seriousness of the oil contamination in the instrument air system.
The letter dated March 3, 1988, indicated that 16 of 21 locations failed ASTM D-4285 " Standard Test for Indicating 011 or Water in
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Compressed Air." The letter stated the following: "the.results of
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the inspection indicate that extensive oil contamination exists in the Unit 2 -turbine building portions of the service air system. -In addition, evidence was found of significant oil contamination at the instrument air and service air receivers for both units in the Auxiliary Building with the contamination extending past the dryers into the main instrument air distribution header."
The oil discovered past the dryers was most likely-due to the inoperability or possible bypassing of the-instrument air dryers and filters.
The March 29, 1988 letter stated that action was'taken to reduce the use of construction air and obtain better utilization of the Sullair compressors.
However, a review of the maintenance history indicates that there was continued reliance on construction air.
This was demonstrated on June 14, 1988, when the construction air compressors were secured to be serviced.and instrument air pressure dropped to 91 psig. The letter also called for special tests to inspect the branch lines of the instrument air system to determine. the extent of contamination of the system. The licensee intends to perform these special tests during the ~ upcoming refueling outages.
During this inspection period, the inspector discussed with the licensee other concerns regarding the instrument air system.
For example, the. service air supplements the -instrument air system through pressure control valves that are set to open at an air pressure of 98 psig. It was a normal occurrence for' these valves to be open allowing.the oil and moisture laden service air to supply instrument air. components. The instrument air low pressure alarm in
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the control room is set at 88 psig and would not alarm as -long as construction air via the -service air system was making.up to the instrument air system.
Consequently, the control room operators would not be aware that instrument air was being supplied by the undesirable service air.
In June 1988, the licensee initiated a Safety System Functional Inspection (SSFI) on the instrument air system.
The final' SSFI report was made available to the NRC in October.1988, and identified numerous problems with the compressed air system, many of them previously discussed in this report. Although the NRC considers the compressed air design deficiencies, including the invalidated 10 CFR 50.59 review, to have been detected by the SSFI and therefore licensee identified, prompt corrective action was not taken to immediately resolve some of these problems.
For example, no dew points were taken until the inspectors asked for this information in January 1989.
In addition, a review by the inspector of the auxiliary and turbine building logs indicated that the recommenda-tions made by the SSFI had not been performed. The auxiliary build-ing log did not indicate what checks would be necessary to ensure that the dryers were operating properly (normal refrigerant suction and discharge pressures).
It states that excessive air flow would be anything greater than 500 CFM.
However, the licensee's ball type
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flow meters used to; indicate flowrate are not calibrated, 'and
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therefore flow rate is not measurable with this instrumentation. The inspector also reviewed.the last completed valve lineup checklist and.
l it indicated'that the valve lineup was. changed so that the lineup of'
-the auxiliary _ building portion of the system was, not' required. to be performed. The licensee has since performed the checklist ~ and fo'und vahes out of position, such as the crossover valve from service air to instrument air previously mentioned. Other important valves' have been blue tagged to provide a warning not to operate these valves without permission of the shift supervisor. These valves include the.
bypasses around the dryers.
The inspector also reviewed a letter dated December 14, 1988-to licensee management generated as a result of the SSFI findings that prepared a. list of action items that-could be worked immediar.ely.
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However, the action on these items was scheduled to be worked during the months of. January through July 1989 and not immediately as requested.
10 CFR Part 50, Appendix B, Criterion XVI states that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that' the cause of the condition is determined and corrective action is taken to preclude repetition.
The above failure of the licensee to take prompt and adequate corrective action, between the April 1987 water intrusion event and January 1989, to ensure that the instrument air quality was sufficient in ensuring the operability of the safety-related equipment it supplied will be identified as an apparent Violation (338,339/88-36-01).
c.
Justification for Continued Operation (JCO)
On January 3, 1989, the licensee was requested to submit a justification for continued operation both for the discrepancy in the VFSAR and the problems with water found in valve controllers. The licensee provided both JCOs on January 13, 1989 and in a phone call with Region II and NRR explained that all temporary corrective actions had been completed including the teardown and maintenance of all of the affected air operated controllers and valve diaphragms.
Selected valves were blown down to ensure water had not gone past the check valves to other parts of the instrument air s, stem. Heat lamps had been installed in the pipe tunnel to ensure the temperatures did not drop below the design dew point of 50 degrees F.
The NRC concurred in the JCO's as discussed with the licensee.
5.
Operational Safety Verification (71707)
By observations during the inspection period, the inspectors verified that the control room manning requirements were being met. In addition, the inspectors observed shift turnover to verify that continuity of system i
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sta'tus was - maintained. _ The inspectors periodically questioned. shift
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personnel. relative to-their awa' eness of plant conditions.
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review'and plant tours, the inspectors verified compliance with selected
. Technical Specification.(TS) and Limiting Conditions for Operations.
In the course of the monthly activities, the resident inspectors included a review of the licensee's physical security program. The performance of various' shifts 'of_ the security force was observed in the conduct of daily activities. 'to include: protected and vital-areas access. controis, searching: ~ of personnel, packages and vehicles, badge issuance and retrieval.
On a regular basis,. radiation work permits (RWP) were reviewed and the
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specific work activity was monitored to assure the activities were being conducted per the RWPs. Selected radiation. ' protection instruments were periodically. checked and equipment _ operability and calibration frequency were verified.
The inspectors kept informed, on a daily basis, of overall status of both units and of any significant safety matter related to plant operations.
Discussions were held with plant management and various members of the operations staff on a regular basis. Selected portions of operating logs
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.and data sheets were reviewed daily. The inspectors conducted various plant toursand made frequent visits to the _ Control Room. Observations included: witnessing work activities in progress;_ verifying the status of operating and. standby safety systems and equipment; confirming valve positions, instrument and recorder readings, annunciator alarms, and housekeeping, a.
Operational Problems The discussion on the following seven events demonstrates a continu-ing problem at North Anna involving inattention to detail, such as failure to follow procedures. Each of these items was documented by the licensee on Deviation Reports (DRs), demonstrating the continued effectiveness of the licensee's program for self identification of problems. All DRs require management review, and specific corrective actions were taken to correct each item.
In some instances, disci-plinary action was taken, including dismissal.
Similar problems were documented in Violation 338,339/88-31-02, which involved 12 examples of failure to follow procedures and configuration control.
The licensee's response to this violation (338,339/88-31-02) was comprehensive, not just addressing the speci-fic corrective actions associated with each problem, but looking at the errors collectively and initiating programmatic root cause corrective action for the problem of personnel errors and inattention to detail.
These programmatic corrective actions consist of the initiation of several new programs including the Coaching Program, the Self Checking Program, the Self Assessment Program and Configura-tion Management Program.
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-BasedL on a.
review of the licensee's response to Violation
338,339/88-31-02, the_ inspector observed increased management
. attention and lack of ~ tolerance in :the area of personnel errors
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and inattention to detail.
Due to the fact that the new programs initiated ' as a result of :this violation have not had time to become fully effective in reducing-and preventing similarievents, the following items will not be identified as new and. separate violations, but rather. as additional-examples of Violation 338,339/88-31-02.
The first additional example occurred on January 3,1989, when an operator trainee, under the direction of a licensed control room operator, actuated the wrong switch in the Unit 2 control room while attempting to start. a containment vacuum-pump. The vacuum' pump is.
normally actuated to maintain the containment in a subatmospheric condition..The switch actually operated was-for 2-QS-MOV-202A, isolation valve for the sodium hydroxide (NA0H) addition tank to the Refueling. Water Storage Tank (RWST) instead of the switch for the containment vacuum pump, 2-CV-P-3A'.
The inadvertent operation of the NA0H isolation valve resulted in dumping.approximately 240 gallons of NA0H into the-bottom of the RWST, A procedure was written to drain the'NA0H,from the line going to the RWST and a vendor was contracted
.to-install a portable demineralized to clean up the system. During this periodLof time, the NADH tank level did not drop below Technical Specification limits.
The process of starting and stopping the containment vacuum pump, 2-CV-P-3A is a normal evolution that occurs frequently. Both of the switches for the vacuum pump and the NADH isolation valve are located-next to each other on the same horizontal line of vertical board switches in the control room and are the same. type of switch.
However, this personnel error caused an inadvertent actuation of Engineered Safety Feature (ESF) equipment. Consequently the licensee made the required 10 CFR 50.72 report to notify the NRC of the occurrence.
The second additional example occurred on January 4, 1989, when Emergency Diesel 2-EE-EG-IH was inadvertently started during the performance of post operational procedure 2-0P-8.5A. During perform-ance_ of the procedure, the operators erroneously placed the control switch in the manual local position 'when it should have been placed in manual remote.
The third additional example occurred on January 4,1989, when the wrong Unit i valve was opened, causing boric acid to be drained from an operable boric acid tank. The valve disposition resulted in the loss of 13 percent level on the
"A" boric acid tank (92 percent to 79 percent).
This did not result in draining the tank below the Technical Specification lower limit (75 percent). An operator opened 1-CH-444 (1-CH-FL-1 Filter Outlet Drain) instead of 1-CH-447 (2-CH-FL-1 Filter Outlet Drain) during the hanging of tags for work l
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on 1-CH-146 (2-CH-FL-1.0utlet Isolation Valve). Independent operator verification of proper tagout boundaries was being performed using
. remote parameter trends due to the high contamination and radiation-
' levels in the area of the valve.
The. operator hanging the tags noted excessive drain flow-from -the tank at the same time the control room operator noted decreasing tank level in the wrong boric acid tank, and' closed the drain valve. The valve. in question did not-have a valve identification tag.
In NRC Inspection Report 338,339/88-05, paragraph -8.c, the inspectors identified that several of the boric acid system ' vent and drain valves were-not labeled. The licensae stated that the. valves had!
been labeled following the inspector notification, but the tag must.
have fallen off.'
The tagging of the vent and drain valves will be identified as Inspector Followup Item (338,339/88-36-02).
On January.15, the fourth additional example of the violation-occurred as documented in DR 89-59. This event involved the failure to follow a chemistry sampling procedure by chemistry technicians.
During the process of obtaining a primary sample, the chemistry -
technician failed to reclose the sample valve as required. by the procedure.
The action created a leak out of the primary, which was
.not discovered until the control room operators performed a primary leak rate surveillance test 2-PT-52.2A during that same day. The results of the leak rate test showed the unidentified primary. leak '
rate to be in excess of the Technical Specification (TS) limit of one gpm. The operators entered a TS action statement which required the leak rate to be reduced to less than one gpm within four hours or commence a reactor shutdown.
Knowing that chemistry had taken a primary sample that day, the operators verified the positions of the sample valves, and found and closed the suspect valve. Following the valve closure, the unidentified leak rate was recalculated and determined to be less than one gpm. This evolution took a little over an hour and the operators exited the TS action statement without requiring a reactor shutdown.
Station Management has reinstructed the chemistry technicians to ensure that the sampling procedure is properly followed.
The fifth additional example of the violation involved a failure to follow procedure during a surveillance test on January 27, 1989.
This event as documented in DR 89-112, involved an electrical technician lifting the wrong lead during the performance of 2-PT-36.9.1.J, Degraded Voltage / Loss of Voltage Functional Test 2J Bus.
The technician lifted lead TD-59 instead of TD-58 as required by Step 4.6.4 and tripped the containment recirculation fan 2-EP-CB-28B.
The purpose of the step was to lift lead TD-58 to prevent the loss of fan 2-EP-CB-28B during the undervoltage test.
Following the technician's error, the operators restarted the fan but because of another problem lost the 2-EP-CB-28A fan.
There was minimal safety significance related to the event because containment temperature control could be maintained with two fans and these fans trip during an accident.
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Because of' continuing. problems with the undervoltage test in the past
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, the licensee had recently made major modifications to the procedure.
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' The procedure was: again reviewed and considered to be a good proce-dure and the cause of the event was determined to be personnel error.
The individual involved has been counseled by Station Management.
The sixth additional example of the violation involved a personnel-error which resulted in the overflowing of the Component ' Cooling Water.(CCW) head tank fill funnel.
This event occurred on January 24,1989 (DR 89-106) and involved the transferring of water containing Potassium Chromate from a -55 gallon drum to the CCW head tank. The operator performing the evolution was briefed prior to its performance by the Shift Supervisor.
The auxiliary operator. then proceeded to pump the water from the 55 gallon' drum to the funnel'on top of the CCW head tank. Once the. pump was started the. operator left the area.
Another operator noticed the funnel overflowing, secured. the pump, attempted to dam 'up the spill and notified the control room. The spill was estimated to be approximately 10 gallons and some of the water reached all floors of the auxiliary building.
Th'e spill occurred because the fill valve was only partially open and the pumping rate was greater than the valve could handle. Also, according to station policy, the operator performing -the evolution was supposed to: stay with the pump until the evolution was completed.
Following the event, the operator involved was reassigned to.other duties and subsequently submitted his resignation from Virginia Power effective February 8, 1989.
The seventh additional example occurred on January 31,.1989 as documented in DR 89-128. This event involved a failure to follow a radiation waste processing procedure, causing the discharge of a low level waste tank. other than the one desired.
An operator was requested to open the discharge valve on 1-LW-TK-3B to allow the tank to be properly discharged through the radwaste discharge building.
Instead, because he did not have the procedure with him, he opened the discharge valve for the other tank, 1-LW-TK-3A, discharging approximately 210 gallons before the control room operator discovered the problem and secured the discharge.
HP determined that the discharge of tank 1-LW-TK-3A did not involve any violation of release limits.
Based on the non-licensed operator's past performance and the present error, licensee management chose to terminate the operator's employment with VEPCO.
All of the above errors involved some disciplinary action taken by licensee management.
The final one being termination cf employment, demonstrating management's lack of tolerance with the continuing l
problem of inattention to detail.
The new programs, established to bring attention to the problem and provide some solution, and the message that management will not tolerate continuing mistakes should reduce the number of personnel errors in the future.
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Health' Physics
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Based on a review - of licensee Deviation Report' (DR) 89-62, tne.
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i inspectors became aware of an event involving two Stone and Webster Engineering Company (SWEC) engineers ' violating Radiation Work Permit-(RWP) requirements.
The event occurred on January 16, 1989 and'
involved two SWEC engineers entering ~~a posted high radiation area witlout the required continuous Health Physics (HP) coverage..The engineers had jurt come ' from Surry and were on site.without the knowledge of the site SWEC manager. The virit to North Anna was to obtain measurements in the penetration areas for a potential design change package on the boron injection tank.
The engineers discussed their work with Station HP technicians and were told the proper RWP number and the requirements for entry into the area.
fhe engineers were informed that continuous HP coverage would be aquired unless they were advanced radiation worker trained and checked out their own meter.
However, the e.'gineers' had just come from the Surry Power Station where advanced training is not required to be able to check out a meter and enter a high radiation area without HP coverage.
After discussion. with HP, the SWEC engineers proceeded to don anti-contamination clothing and make preparations to enter the Unit 2 containment penetration' area in the auxiliary building.
The engineers entered the high radiation area without HP coverage and without a meter.
Neitner engineer had received advanced radiation worker training and therefore could not check out a meter.
The engineers stayed in the area for approximately 1 1/2 hours -until discovered by two station operators. The engineers were told by the station operators to leave the penetration area and report to the HP
. Shift Supervisor.
The engineers dosimeters were read by HP and revealed that one
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engineer received 9 mrem and the other received 10' mrem. Therefore i
no overexposure occurred.
Based on a worse-case scenario of a hot
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spot of 70 mrem / hour the licensee calculated that the engineers could have received approximately 105 mrem, which is still within the station / federal dose 15.its.
The engineers were escorted off site and their security badges were terminated.
SWEC was notified that these two engineers would not be allowed to work at either North Anna or Surry in the future.
This item will be identified as an unresolved Item 338,339/88-36-03 pending further review by the regional HP staff.
NRC Inspection Report No. 338,339/88-33, paragraph 6 identified the inspector's continuing concerns on Rubidium 88 contamination in the Auxiliary Building.
There were another 55 personnel contaminations from January 5, 1989 to January 25, 1989. The inspector has requested
the licensee to provide a list of the actions, recommended by the
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licensee task force, to be taken to alleviate the problem.
The inspectors will continue to monitor the licensee actions concerning this issue.
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6.
Lic'ensee Event Report (LER) Follow-up (90712)
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The following. LER.was -reviewed and closed. The inspector verified that reporting-requirements' had been met, that causes had been identified,. that
' corrective ' actions appeared appropriate, that generic applicability had
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been considered, and that the LER forms were complete. Additionally,;the inspectors confirmed that no unreviewed safety. questions were involved and that violations of regulations or Technical Specifications (TS) conditions had been appropriately identified.
(Closed) LER 339/87-11, Beari.ng Temperature Surveillance ' Not-performed
' Yearly As Required By Technical Specifications.
The periodic test was placed on,the-automatic test schedule and should preclude recurrence of-this event.
7.
Station Drawing Review The inspector reviewed the service water-system, feedwater system and safety injection system drawings in the control room and technical support center. Several discrepancies were noted. The technical support center-drawings were not up to date. Revisions had been made to the drawings in the control room and not those in the technical support center. Licensee management took immediate action to update the technical. support center drawings.
The inspector will continue to monitor the drawing program.
8.
Exit' Interview The inspection scope and findings were summarized on Februrry. 2,1989, with those persons indicated in paragraph 1 above.
Thv inspectors-described the ' areas inspected and discussed in detail tne inspection findings listed below. The licensee did not identify as propriett y any of the material provided to or reviewed by the inspectors during this inspection. Dissenting comments were not received from-the licensee.
(0 pen) Apparent Violation 338,339/88-36-01, Failure to take prompt and adequate corrective action concerning inadequate instrument air quality.
(Paragraph 4)
(0 pen)
Violation 338,339'88-31-02, Seven additional examples of a
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violation listed in inspection report 338,339/88-31 for failure to follow procedures.
(Paragraph 5)
(0 pen)
IFI 338,339/88-36-02, Tagging of the boric acid vent and drain valves.
(Paragraph 5)
(0 pen) Unresolved Item 338,339/88-36-03, Region II health physic staff review of the violation of radiation work permit requirements.
(Paragraph 5)
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