IR 05000338/1990001
| ML20012D526 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/16/1990 |
| From: | Caldwell J, Fredrickson P, King L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20012D525 | List: |
| References | |
| 50-338-90-01, 50-338-90-1, 50-339-90-01, 50-339-90-1, IEIN-86-001, IEIN-86-009, IEIN-86-1, IEIN-86-9, NUDOCS 9003280013 | |
| Download: ML20012D526 (19) | |
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NUCLEAR REGULATORY COMMIS$10N
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g 101 MARIETTA STREET N.W.
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Report Nos.: 50-338/90-01 and 50-339/90-01
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Licensee: Virginia Electric and Power Company 5000 Dominion Boulevard Glen Allen, VA 23060
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Docket Nos.: 50-338 and 50-339 License Nos.:
Facility Name: North Anna 1 and 2 Inspection Conducted: Januar 4 - February 16, 1990 Inspectors:
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7 -N - fo J. L. Caldwelli Senior Resident inspector Date Signed
Y h FM 3-N *f e L. P. King, ResTdent Inspector Date Signed
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Accompanying s ect )r:
S. M. Shaeffer Approved by:
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P. E. Fredrickson, Section Chief Ddte Signed Division of Reactor Projects f
SUMMARY Scope:
This routine inspection by the resident inspectors involved the following areas:
plant status, maintenance, surveillance, engineered safety feature walkdown, operational safety verification, operating reactor events, cold
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weather protection, licensee event report followup, and action on previous inspection findings.
During the performance of this inspection, the resident inspectors conducted reviews of the licensee's backshift operations on the following days January 4, 5, 8, 9, 11, 17, 18, 24, 29 and 30.
Results:
Within the areas inspected, two non-cited violations were identified:
one for the failure to comply with TS 3.9.12 (paragraph 9); and one for failure to follow an operating procedure (paragraph 8). Also within the areas inspected, one unresolved item was identified regarding the potential for a violation of TS6.8.4a(paragraph 6).
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f REPORT DETAILS 1.
Persons Contacted Licensee Employees L. Edmonds, Superintendent, Nuclear Training
- R. Enfinger, Assistant Station Manager
- J. Hayes, Superintendent, Operations (Acting)
D. Heacock, Superintendent, Engineering
- G. Kane, Station Manager.
- P. Kemp, Supervisor, Licensing W. Matthews, Superintendent, Maintenance
- A. Parker, Jr., Supervisor, Maintenance Engineering T. Porter, Nuclear Safety Engineering Supervisor
- J. Smith, Quality Assurance Manager
- A. Stafford, Superintendent, Health Physics
- J. Stall, Assistant Station Manager (Acting)
- F. Terminella, Supervisory, Quality V. West Superintendent, Outage Management Other licensee employees contacted included engineers, technicians, operators, mechanics, security force members, and office personnel.
NRC management site visit:
On January 10, 1990 Mr. M. Sinkule, Chief. Division of Reactor Projects Branch 2, Region II, visited the North Anna Power Station for a station tour and to meet with Station Management.
On February 9, 1990, Mr. J. Milhoan, Deputy Regional Administrator, Region 11, and P. Fredrickson, Chief, Division of Reactor Projects Section 2A, Region 11, visited the North Anna Power Station for a station tour and to meet with Station Management.
- Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph.
2.
Plant Status Unit I commenced the inspection period on January 4 operating at approximately 100% power,- day 15 of continuous operation.
On January 23, Unit 1 experienced a reactor trip from 100% power due to a failed main
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feedwater regulating valve driver card.
The card failure caused the "C" feedwater regulating valve to close resulting in a low level in
"C" SG with a steam flow to feed flow mismatch (see paragraph 7 for details). On January 27, the licensee attempted to fill and test the "B" gas stripper system, but was unable to fill the system due to numerous leaks.
The
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problems with the leak test of the gas stripper appear to be related to the Rubidium gas contaminations in the auxiliary building (see paragraph 6 for details).
The inspection period concluded on February 14 with the unit operating at approximately 100% power, day 21 of continuous operation.
Unit 2 commenced the inspection period on January 4 operating at approximately 100% power, day 241 of continuous operation.
As discussed in NRC Inspection Report 338,339/89-35. Unit 2 has been experiencing an increasing unidentified RCS leakage rate.
The rate, though increasing, was still well within the TS requirements.
Several containment entries were made during the inspection period and identified leaking components were repaired using leak repair material such as Furmanite.
By the end of the inspection period, the RCS unidentified leak rate had been reduced from a high of 0.5 gpm to approximately 0.14 gpm.
The inspection period
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concluded on February 14 with the unit operating at approximately 100%
power, day 282 of continuous operation.
3.
Maintenance (62703)
Station maintenance activities affecting safety-related systems and components were observed / reviewed to ascertain that the activities were conducted in accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with TS requirements.
On January 17, the inspector witnessed maintenance being conducted on the QS system heat tracing. The maintenance was being conducted in accordance with work request 652057 and procedure EMP-C-HT-NSR-1, Removal, Trouble-Shooting and Repair of Heat Tracing.
No problems were identified by the inspector.
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Also on January 17, the inspector witnessed portions of design change
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DCP-89-43-3, which provided the instructions for the reconstitution of I
specific spent fuel assemblies.
These assemblies have been used during l
one full cycle and developed a leak in at least one fuel pin during the cycle.
The reconstitution, which was being conducted by Westinghouse, l
involved removing the failed pin and replacing it with a stainless steel pin.
Each of these assemblies would then be scheduled for use in a core at some later date.
The inspector witnessed the work on fuel assembly
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J-37/LM0L65.
No problems were identified at this time, however problems l
did occur later (see section 9 regarding LER 338,339/90-02 closecut),
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On February 4, the inspector observed maintenance on 1-05-5, a four inch
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stainless steel gate valve manufactured by the Anchor Valve Company.
The
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valve had developed a leak and the licensee determined that the gasket needed replacing.
The inspector questioned the maintenance technicians and foremen concerning the proper material to be used for a replacement gasket.
They were unable to answer the question and subsequently contacted maintenance engineering to determine the proper type of gasket and material to be used.
The inspector determined from the vendor drawing that the specified gasket was a Craneseal, which the inspector was later I
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informed was not available. Maintenance engineering determined a suitable replacement type and material for the gasket. The inspector reviewed the information and was satisfied that the replacement gasket material used was acceptable.
The inspector also observed maintenance being conducted on 1-QS-3, a 3/4 inch gate valve. This valve is a drain off of the quench spray pump discharge filter.
The valve seat and disc were lapped and the valve was reinstalled in the system.
The post-maintenance test was satisfactory in that no visible leakage was observed.
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On February 7 the inspector witnessed portions of electrical procedure, EMP-P-EP-9, Testing of Non-Containment Isolation 480 Volt Breakers.
This maintenance activity was being performed on Unit 1
"H" emergency diesel generator breaker, 1-EP-MCH-12Bl.
The only problem observed by the inspector involved two procedure deviations attached to the procedure which changed the same procedural step.
Af ter a discussion with the technician, the inspector determined that both deviations performed the same change, just worded differently.
The technician informed the inspector that the electrical shop recognized the procedure needed to be upgraded and was in the process of being rewritten by the procedures upgrade group.
On February 14, the inspector witnessed maintenance being conducted on the Unit 1 "A" containment vacuum pump (1-CV-P-3A). The work, which involved the replacement of the pump, was being performed in accordance with work request 651923 and maintenance procedure MMP-C-GP-NSR-1, Inspection and Repair of Non-Safety Related Pumps in General.
The inspector did not identify any problems related to the actual work but did observe several deficiencies which related mainly to inadequate procedures and planning.
The procedure was a generic procedure and the specific steps were hand written in by the maintenance foreman.
These steps were elementary and did not provide any specific guidance to the mechanics.
This lack of guidance was demonstrated by the technicians being unprepared for collecting water once the cooler connections had been broken.
This held up the job while the technicians waited for the delivery of absorbent
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material to be placed around the cooler connections in order to complete L
the disconnection.
The absorbent material was needed to prevent the l
spread of contamination, since this pump was potentially contaminated.
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The technicians were also not completely aware of how to remove the coupling from the pump shaft.
The specific instructions were not written
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into the procedure.
When the decision was made to use heat to remove the coupling, the technicians determined that an 0-ring would most likely be destroyed.
Planning had not procured this 0-ring for the job, therefore the job was again stopped to allow the 0-ring to be obtained and to allow the maintenance personnel to re-group and make sure of the proper way to remove the coupling.
An additional work stoppage occurred when the technicians determined that the area roped off around the pump by HP was not big enough to facilitate
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the removal of the pump. This discovery was not made until after the work
had consnenced instead of being checked out before the job started. The HP technician thought that the "B" pump next to the "A" pump was the one to be worked. The "B" pump was adequately roped off and iust by accident the
"A" pump was included in the roped off area.
The final discrepancy observed by the inspector involved a review of the procedure, MMP-C-GP-NSR-1, which revealed an initial condition which was not signed as completed.
This initial condition was a foreman sign-off documenting that the mechanics had been briefed concerning the work to be performed.
The inspector was able to determine based on discussions with the mechanics on the job that this briefing had taken place.
However, it does demonstrate that the foreman and the workers on the job did not
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review the procedure to verify all initial conditions, prerequisites etc.
were completed prior to commencing work.
No violations or deviations were identified.
4.
Surveillance (61726)
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The inspectors observed / reviewed TS required testing and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that LCOs were met and that any deficiencies identified were properly reviewed and resolved.
On January 8, the inspector reviewed 1-PT-69.9B, Leak Rate Test of the Gaseous Waste System, which was performed on May 3, 1989.
The inspector reviewed the valve checkoff sheet and drawing 11715-FM-97A to verify the boundaries tested by the procedure were correct.
No problems were noted.
On January 29, the inspector witnessed the performance of 1-PT-36.5.3A, Solid State Protection System Output Slave Relay Test (Train A).
The licensee was conducting the RPS/SI slave relay testing with Unit 1 at 100%
power. The inspector did not ioentify any problems.
No violations or deviations were identified.
5.
ESFSystemWalkdown(71710)
The following selected ESF systems were verified operable by performing a
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walkdown of the accessible and essential portions of the systems on February 14, 1990:
a.
The emergency generator fuel oil system for Unit 1 using 1-0P-6.8A.
The following comments were noted:
(1)
1-F0-300 and 1-F0-301 should be listed under " Fuel Oil Pump House Room 1".
(2) Under " Emergency Generator Room IJ",
1-EG-307 is labeled 1-EG-30 '
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The diesel air system for the IJ diesel per 1-0P-6.7A.
No problems were noted, Breaker Checklist per 1-0P-26-A, which involved the alignment of c.
electrical breakers for ESF and other safety-related equipment. The following comments were noted:
(1) The breaker handles for breaker F1 and F2 are broken and no work request tag is visible (see page 12).
(3) Breaker A3R has a noun description, but no numerical label (see page 15).
(4) Breaker Dil-4.16 K.V. Bus 1J Htn is not listed in the procedure (see page 15).
(5)
In most cases, the noun description on the breaker checkoff sheet is not the same as written on the panel (see pages 17 thru 22).
(6) Breaker C1 and C2 for MOV-1720B and MOV-1720 are shown closed and are actually open.
1-0P-14.1 indicates the required positions to be open.
The breaker checkoff sheet should also indicate open except when the system is operating (see pages 23 and 32).
No violations or deviations were identified.
6.
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 status was maintained. The inspectors periodically questioned shif t personnel relative to their awareness of plant conditions.
Through log review and plant tours, the inspectors verified compliance with selected TS requirements and LCOs.
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 controls, searching of personnel, packages and vehicles; badge issuance and retrieval; escorting of visitors; patrols; and compensatory posts.
On a regular basis, RWPs were reviewed and the specific work activity was monitored to assure that the activities were being conducted per the RWPs.
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 tours and 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, and annuciator alarms; and observing housekeeping.
The inspector is concerned about the recent increase in the number of personnel contaminations as a result of Rubidium gas in the auxiliary building.
NRC Inspection Reports 338,339/88-33 and 338,339/88-36, identified that corrective actions to eliminate rubidium gas contamination in the auxiliary building have been ineffective.
TS 6.8.4a requires that programs be established, implemented and maintained to reduce leakage from those portions of systems outside the containment that could contain highly radioactive fluids during a serious
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transient or accident to as low as practical levels. The systems should include the gas stripper. The program shall include the following:
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Preventative maintenance and periodic visual inspection requirements
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and, 11.
Integrated leak test requirements for each system at refueling cycle
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intervals or less.
Section i of TS 6.8.4a, as stated above, requires preventive maintenance activities be developed and used to prevent radioactive leaks.
NRC Inspection Report 338,339/89-30, under the operational reactor event paragraph, stated that a review of the work histories on several of the diaphragm valves indicated that the diaphragms had not been replaced since
1982 and 1983.
The manufacturer recomends changeout every five years.
Licensee management informed the inspector that they did not intend to replace all Grinell valve diaphragms and "0" rings on a five year basis, i
but would follow the requirements set forth in maintenance administrative procedure, MD-ADM-12.0.
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The inspector reviewed maintenance administrative procedure MD-ADM-12.0, Grinell Valve Maintenance Program.
Step 5B of the procedure states that certain valve diaphragms and "0" ring replacements may be deferred based l
on the valve function and service.
Valves that may be deferred must fit into one of the following categories:
a.
Isolable valves, b.
Nonisolable valves installed in systems other than borated fluid systems or systems containing hazardous fluids and radioactively contaminated fluid systems.
In regards to section.ii of TS 6.8.4A, the inspector reviewed 1-PT-57.8B, Leak Rate Test of 1-BR-EV-2B, ("B" Gas Stripper) and associated equipment and piping.
The inspectors review of the procedure, which was last
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performed on October 24, 1988, indicated that when the gas stripper pressure was raised to 65 psig in step 4.6, using primary grade water,
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there was no provision for shutting off the primary grade water supply prior to monitoring the system for a pressure decrease.
Consequently, step 4.8, which requires a walkdown of the system to check for leaks was marked "not applicable" because there was no observed decrease in system j
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pressure.
The licensee was notified of the apparent discrepancy and has corrected the test procedure to require shutting the primary grade water supply valve and then monitor for a pressure drop. The licensee maintains however, that the primary grade water valve was shut and pressure
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monitored for ten minutes during the previous leak tests, even though the procedure indicated it was not done in that order.
On January 20, 1990, the "B" gas stripper was tagged out for maintenance and on January 27, 1990, an attempt was made to fill the 'B' gas stripper for a operating pressure leak test.
A pipe seam leak developed at
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1-BR-TE-1038 with the stripper 36 percent full and at 4 psig.
Further investigation revealed additional leaks.
The fill was secured and work requests to repair the leaks were initiated.
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On January 30, 1990, as a result of air samples, both
"A" and
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strippers were posted as airborne radioactive areas (1.77 X M.P.C).
The ventilation was then secured in order for HP to sample for gas buildup in the auxiliary building. As a result of securing the ventilation, numerous leaks on valves and possible cracks in piping were discovered in the auxiliary building on the 244 foot level in the vicinity of the "A" gas stripper, on the 244 foot level near the demineralized valve alley, on the charging oump (2-CH-P-1A) discharge flange and several leaks on the 274 foot level in the vicinity of the primary sample room sink.
The inspector expressed his concerns to the licensee about the contamina-tions due to gas leaks. A task force is planned to be organized to detect and fix the source of leaks. The inspectors are following the progress of the task force.
The "B" stripper has recently been leak tested six times and still has leaks to be repaired.
The inspector believes that those leaks have not developed since the last periodic leak test, but are now being identified as a result of correctly performing the periodic +est.
The possibility that the licensee has not met TS 6.8.4a by improper leak testing and not performing adequate preventive maintenance such as the Grinnel valve diaphragm replacements, will be identified as Unresolved item 338,339/90-01-01.
This item will remain unresolved pending further information from the licensee regarding the periodic test and identification of preventive maintenance on nonisolable Grinnel valves.
No violations or deviations were identified.
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7.
Operating Reactor Events (93702)
The inspectors reviewed activities associated with the below listed reactor events.
The review included determination of cause, safety significance, performance of personnel and systems, and corrective action.
The inspectors examined instrument recordings, computer printouts, operations journal entries and scras reports and had discussions with operations, maintenance and engineering support personnel as appropriate.
On January 23, at 1522, Unit 1 experienced an autoraatic reactor trip from 100% power.
The trip signal was a low level in the "C" SG with a steam flow to feed flow mismatch, resulting from the closure of the "C" main feed regulating valve. The root cause of the event was the failure of the driver card which controlled the position of the "C" main feed regulating valve and caused the valve to fail closed.
All safety systems operated as required and the operators performed well in placing the plant in a stable condition following the trip.
The licensee replaced the failed driver card and inspected the other drive cards.
A post-trip review was performed and the unit was restarted on January 24 with the unit back to 100% power on January 26 following clearing of secondary chemistry holds.
No problems were encountered during the restart.
No violations or deviations were identified.
8.
ColdWeatherPreparations(71714)
The inspector reviewed the licensee's winterization program as established in maintenance administrative procedure M.D.
ADM-20.0, Plant Winterization /Summerization Program.
This procedure is scheduled to be performed between October 1 and November 30 of each year for the winterization portion of the procedure.
However, there is no provision for the procedure to be reperformed following its completion, if for some reason the weather becomes warm and then turns cold again.
Presently, the licensee must rely on personnel memory and operating experience to ensure that the cold weather protection activities are still valid if the weather turns cold following warmer temperatures.
This situation has been discussed with the licensee and they are reviewing their program to determine if enhancements are needed.
To date, the inspector is not aware of any problems which have arisen form this situation.
The inspector reviewed the licensee's PMs which were completed in accordance with M.D. ADM-20.0 and concluded that they appear to be comprehensive.
These procedures were completed during the months of September, October and November of 1989.
This area has had a relatively mild winter with the exception of December which was exceptionally cold.
The inspector is only aware of one problem related to freezing of equip-ment or components; this involved the RWST level instruments. These instruments failed to operate in December when the outside temperature had been unusually cold for several days. The normal method of freeze protec-tion was the heat tracing which was working but was overcome by the intense cold temperatures.
The licensee ir. stalled herculite covers over
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the instruments and placed heaters in the temporary enclosures.
This corrective action returned the instruments to an operable status and the licensee did not experience any further problems.
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The inspector did discover a problem with operations department procedure 1-MISC-18, Cold Weather Operations. As a result of an industry-identified EQ problem concerning the potential for super-heated steam to be
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experienced in the main steam valve house following a main steam line j
break, the licensee established controls over the main steam valve house vents.
1-MISC-18 was changed to require that with the unit operating in modes 1, 2 or 3 the top floor vents and lower door cover must not bc l
installed.
This requirenient was established to ensure that the heat created by the super-heated steam would not be trapped in the valve house.
i On February 13, with both units operating at 100% power, the inspector toured both Unit 1 and 2 main steam valve houses and discovered that the top floor vents on one the three sides in both valve houses were covered with herculite.
Following discussions with the licensee, the covers were removed and engineering was requested to review the situation and determine if a safety or design problem existed.
The engineering review provided to the inspector concluded that the remaining uncovered top floor vents were more than adequate to prevent excessive temperatures in the main steam valve houses.
The licensee informed the inspector that the covers had been installed in December during extremely cold and windy conditions to ensure that freezing of equipment would not occur.
However, this evolution was conducted in direct conflict with operations procedure 1-MISC-18 and without the benefit of an engineering review.
Since the vent covers were installed in non-compliance with 1-MISC-18 this event will be identified as a violation of TS 6.8.1 for failure to follow procedure, but will be a
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non-cited violation (338,339/90-01-02) beccuse of the low level of safety significance and that appropriate corrective actions were initiated by the licensee following identification of the situation.
9.
LER Follow-up (90712)
The following LERs were 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 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 TS conditions had been identified.
(Closed)LER 338/88-02, Manual Reactor Trip in Anticipation of Loss of the Main Condenser.
The event occurred when the three running circulating water pumps "A", "B",
and "C" tripped simultaneously and condenser vacuum was observed to be decreasing rapidly.
Prior to the manual trip, the Unit I had been experiencing seriodic blockage of the circulating water pump screens by fish.. The l' censee has detemined, however, that the tripping of the circulating water pumps was not due to the fish problem and was unable to determine the actual root cause of the event.
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corrective hetion, the licensee developed a new preventative maintenance procedure which performed an evaluation of the Unit 1 and 2 CW system protection circuitry and did not find any discrepancies.
The new procedure will be performed every refueling outage.
During the trip, all safety-related equipment functioned as designed, with the exception of the
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steam driven AFW pump which successfully started and operated for about 40 minutes before tripping unexpectedly.
SG 1evel did not decrease signifi-
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cantly. The cause of the AFW trip was a blown plug in the governor of the valve stroke limiter / regulation valve which possibly struck the trip valve
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linkage and actuated the valve.
The licensee decided to remove the suspect stroke limiter from the AFW turbine as it provides redundant overspeed control and has been determined by the vendor to be ineffective on this type of turbine.
The Surry station was notified of this potentially generic modification.
The inspector reviewed procedure EMP-P-CW-1, Circulating Water System Vacuum Logic, the modification
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package for the AFW turbine, and the other corrective actions for the event contained in the LER closeout package. This LER is closed.
(Closed)LER 338/88-27, Inconsistency Between the Technical Specifications and the VFSAR on ESF Relay Testing.
The situation was discovered by the licensee while reviewing NRC Information Notice 88-83, Inadequate Testing of Relay Contacts in Safety-Related Logic Systems.
The inspector reviewed the Supplemental LER issued on July 26, 1989, which included the results
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of an engineering review of ESF testing, failure history, and additional corrective actions taken. The engineering review determined which ESF relays should be functionally tested on-line based upon a reinterpretation of the requirements for meeting TS 3/4.3.2.1.
The licensee has been issued and is currently testing ESF relay equipment in accordance with TS change numbers 123 and 107, issued on September 2,1989.
The inspector considers the LER closed.
(Closed) LER 338, 339/88-17, Failure to Test Containment Personnel Airlock Equalizing Valves.
The subject valves were covered by blank flanges in l
accordance with the vendor manual, however, were not tested whenever the
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overall airlock leakage test (every six months) was performed.
Following a review of procedure 1/2-PT-62.1, Containment Air locks--Leakage Rate, The licensee discovered that no procedure for testing the equalizing t
l valves was being performed.
On February 17, 1988, the emergency equalizing valves were satisfactorily leak-tested indicating that the
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valves were likely to have been leak-tight for the er, tire unsurveilled
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period. The licensee determined the cause of the event to be an incorrect I
procedure described in the vendor manual and in 1/2-PT-62.1 as well as a failure of station personnel to identify the problem during procedure reviews.
Procedure 1/2-PT-62.1 was revised to delete the requirement that the valves be blank flanged during subsequent testing.
The inspector reviewed the LER closecut package and considers this LER closed.
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(Closed) LER 339/88-01, Inadvertent Start of the Steam Driven Auxiliary Feedwater Pump. The event involved the inadvertent start of the turbine driven AFW pump 2-FW-P-2 as it was being isolated for maintenance.
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licensee attributed the event to personnel error combined with no pre-job briefing being performed to caution the operator to manually isolate 2-MS-S-TV-211A prior to opening the power supply breaker. Corrective actions included the enhancement of the tagging process to computerize and partially automate the generation of equipment tags.
This effort should help standardize the tagging process and reduce the operators administra-tive workloads.
This event was also included as an example of a procedural TS violation issued in NRC Inspection Report 338,339/88-31.
The inspector reviewed the corrective actions documented in the LER closecut package and considers this LER closed.
(0 pen) LER 338,339/88-21 Error in Control Room Habitability Design Basis Calculation.
The subject LER was issued in November 1988 by the licensee as a result of discovering an error in a design basis calculation.
Due to this. error, the design basis fuel handling accident would result in radiation doses to control room personnel exceeding 10 CFR 20 limits because isolation of the normal ventilation supply does not automatically occur. To compensate for the error in the design basis, station operating procedures were revised to require operation of the control room emergency ventilation system during fuel movement.
In addition, the licensee consnitted to perform calculations on various accidents to determine the radiation doses to control room personnel.
This study reviewed GDC-19 requirements and determined that current operating practices were non-conservative in that no allowance was made in the dose estimates to account for ingress / egress to the control room during an accident and the resultant pathway for contaminants.
To resolve this concern, measures have been taken to verify that the control room envelope is maintained at l
an adequate positive pressure.
Completed modifications and procedures revisions include:
revisions to i
1-EP-0, Reactor Trip on Safety Injection, to ensure that the control room l
emergency ventilation fans are started on recirculation in the event of a safety injection; a revision to the VFSAR to reflect the new GDC-19 -
analysis; revisions to EPIP-4.17. Monitoring of OSC and TSC, to include HP surveys to be performed in the control room during an emergency response; revisions to 1-AP-5.2, Common Radiation Monitoring System, requiring
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activation of the bottled air system and placement of the control room l
I emergency ventilation system in service on receipt of a fuel building radiation alarm and additional required actions; and revisions to 1-09-21.7, Main Control and Relay Room Emergency Ventilation, which changes the normal alignment of 1-HV-FL-8 and 2-HV-FL-8 from turbine building suction to the recirculation mode suction.
The licensee is currently in the process of performing additional modifications to the control room habitability ventilation system.
The completion date for these modifications has been extended to June 30, 1990, per correspondence from the licensee dated December 21, 1989, to the NRC.
The outstanding modifications to be performed includes:
1)
auto-start of the emergency control room ventilation fans in recirculation mode upon receipt of a bottled air system actuation signal and 2)
auto-isolation of the normal control room air supply and exhaust upon
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receipt of a fuel building high-high radiation alarm.
These outstanding modifications are intended to ensure long-term compilance with GDC 19 of i
Appendix A to 10CFR50.
LER 338,339/88-21 will remain open pending completion of these modifications.
(Cicsed) LER 338, 339/88-26, Missed Technical Specification Surveillance l
Due to Inadequate License Amendment Review.
The issue involved the licensee's discovery that the surveillance requirement for performing a source check on the Westinghouse Process Vent Gaseous Radiation Monitor, RM-GW-102, prior to releasing the contents of the WGDT, was not being performed as required by TS 3/4.3.3.11.
The event was attributed to inadequate license amendment review.
The inspector reviewed the licensee's corrective actions which included various procedure revisions to require performing a source check prior to releasing a WGDT and also prior to commencing a head purge. The inspector determined the corrective actions taken for the event adequate to prevent recurrence.
(Closed) LER 338,339/90-02, Fuel Building Ventilation not Aligned through the Charcoal Filters During Fuel Movement.
This LER discussed an event which occurred on January 27 due to an operator error which resulted in a violation of TS 3.9.12.
The TS requires that the fuel building ventilation be aligned to discharge through the auxiliary building HEPA and charcoal filter any time fuel is being moved in the spent fuel pool.
During the time in question Westinghouse personnel were performing fuel reconstitution evolutions in the spent fuel pool and the operators failed to align the fuel building ventilation through the auxiliary building charcoal filters prior to Westinghouse comencing work.
Following the discovery, the fuel building ventilation was properly aligned and a review of the operation revealed no fuel damage or release of radioactive material had occurred. The licensee investigated the event and determined the main cause of the event was operator error, but also determined that inadequate procedures contributed a great deal to the event. The require-
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ment for the ventilation alignment had been left up to operator memory and L
the applicable procedures did not reference each other.
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The licensee initiated the following corrective actions:
a.
Work in the fuel building was stopped until the event could be reviewed and additional administrative controls could be implemented, b.
Disciplinary action was taken with the operator involved in this event.
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Operating Procedures 1-0P-21.5, Operation of the Auxiliary Building c.
lodine Filters, was revised to add a sign off step that ensures 1-0P-21.7, Main Control and Relay Room Emergency Ventilation, is completed prlor to performing fuel movement.
d.
Operating Procedure 1-0P-21.7 was revised to add a sign off step that 1-0P-21.5 is completed prior to performing fuel movemen.
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A new Miscellaneous Operating Procedure,1-MISC -47, Fuel Handling Pre-Job Review, was developed which contains a sign off step that requires 1-0P-21.5 and 1-0P-21.7 to be complewd prior to fuel movement or heavy load movement over irradiated fuel, f.
Fuel movement procedures were revised to require 1-MISC-47 to be completed prior to fuel movement.
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In addition, an operations representative was assigned in the fuel building during the remaining fuel inspection activities.
The inspector reviewed the corrective actions and determined them to be adequate.
Fuel reconstitution re-connenced on January 30 without further problems.
Since the licensee discovered the non-compliance with TS-3.9.12 had immediately corrected the problem, and initiated corrective actions to prevent recurrence, and also since the safety significance was minor since no radioactive material was released, this violation of TS 3.9.12 will be identified as a Non-Cited Violation (338,339/90-01-03).
10. ActiononPreviousInspectionItems(92701,92702)
(Closed) IFI 338/87-24-07 Review Design Adequacy of Steam Generator and Air Ejector Isolation.
The licensee has completed the design review as suggested. The recommendations are:
a.
Health Physics should develop an increased Hi Hi setpoint for RM-SV-121 corresponding to the allowable gaseous radioactive effluent release limit; b.
To increase condenser availability, the exhaust valves (TV-SV-121-1,-2, 103) and auxiliary steam supply valves (FCV-AS-100 A/B) should become phase B isolation valves instead of phase A.
(Closed) IFI 338/87-24 09, Review Hydrogen Gas Control In Steam Generator Following a Tube Rupture. The licensee has changed the procedure to add a precaution regarding the possibility of hydrogen gas buildup in the SGs following a tube ru sture.
The response from engineering indicates that although a combusti)1e mixture did exist during the 1987 tube rupture event there was no ignition source present.
The only way to prevent having the mixture occur would be to deoxygenate the emergency condensate storage water.
(Closed) VIO 338/87-21-01, Violation of Technical Specification 6.8.1.a.
Unit 1 and 2 operating procedures 1/2-0P-3.4, were revised to ensure that a positive pressure is maintained in the pressurizer when the RCS is drained down and vented.
Training was conducted to ensure the operators understand the conditions which must be met in order to perform reactor coolant pump maintenance while in this mode.
(Closed) IFl 338,339/88-27-01, Procedure Change to Require an Operator to Check Open the Inlet Air Louvers on the Start of an Emergency Diesel
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Generator.
The inspector verified that the licensee added a step to the i
l emergency diesel generator slow start test procedures to require an operator to check the louvers each time the EDG is operated.
(Closed) VIO 338,339/88-31-06 Installation of Non-Seismic Trolleys above Emergency Switchgear.
The licensee has completed EWR 89-114A which removed the unqualified holsts installed above the stations 480 volt load centers.
Alternate equipment has been acquired to safely move the equipment without affecting the integrity of the load centers'
qualifications.
The inspector reviewed the corrective actions taken for the violation and considers them adequate to correct the seismic concern
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of the trolleys above class 1E electrical cabinets.
(Closed) 338/339 TI-2515/94, Moderator Dilution Event.
The licensee addressed this issue in a letter dated June 1,1981.
Administrative procedures are in effect at North Anna which preclude the potential for inadvertent dilution by isolating (via key lock) the dilution water source. The incident in the TI took place at a Babcock and Wilcox plant where the NA0H tank connects to the suction of the decay heat pumps.
North Anna has a separate residual heat removal system and NA0H can only leak to the RWSTs.
(Closed) UNR 338,339/87-01-04, Possible Inoperability of the 2H and 2J EDG's. The licensee commissioned Colt Industries to perform a study using the worst case loading situation on the EDG during an accident. The study by Colt Industries concluded that the 2H and 2J EDG's were operational even though the local limits had been inadvertently set at 3000 KW, (Closed) LIV, 338,339/87-01-01, Failure to Provide a Maintenance Procedure and Perform A Post Maintenance Test On The Control Room Emergency Ventilation System.
A ventilation system flow test was performed after the discovery of the problem by the NRC Control Room Habicability Survey Team and the emergency ventilation flow rate was adjusted to be in accordance with TS.
The licensee has also established a maintenance procedure for the performance of the intake filter cleaning.
A violation, 338,339/88-36-01, involving escalated enforcement was issued covering this and several control room habitability issues.
(Closed) IFI, 338,339/87-01-03, Potential ASCO Solenoid Valve Problem.
The licensee has continued to stroke 2-TV-B0-200F and had no further problems with this valve.
A license review of Information Notices 85-17 and 86-17 was conducted and the licensee concluded that the problem did not exist at North Anna.
However, the conclusion was based on the assumption that instrument air was oil free.
This assumption was later determined to be invalid since instrument air was found to contain oil contaminants.
In early 1988, a violation, 338,339/88-02-01, was issued regarding improper methods used to test air operated valves with ASCO solenoids. The issues in this IFI are contained in and will be tracked by this violation,
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(Closed) IF1, 338, 339/87-19-16, Review Evaluation of Startup Problems for Possible Common Cause.
Following the 1985,1986, and 1987 refueling outages, the licensee experienced numerous equipment and personnel related problems, which affected the restart of the units. The licensee conducted a study of the problems and could not determine a common cause other than inattention to detail and inadequate procedures.
Numerous meetings were conducted by plant management with station personnel to emphasize the importance of attention to detail and the need to elimir. ate personnel errors.
Several programs have been established including the self-checking, coaching, and procedures upgrade programs. These programs and other related efforts have been successful as demonstrated by the successful restarts of Unit 1 and 2 following the 1989 refueling outages.
Unit 2 has not experienced a power transient such as a reactor trip or shutdown since the startup following the 1989 refueling outage.
(Closed) 338/339 TI-2515/93, inspection for Verification of Quality Assurance Request Regarding Diesel Generator Fuel Oil Multi-Plant Action Item A-15.
The inspector verified that the licensee has a program for sampling and inspecting the diesel fuel oil tanks. The sempling frequency is in accordance with the TS 4.8.1.1.2b requirements, which is quarterly.
The inspector also compared the licensee's program to Regulatory Guide 1.137 and determined that the program appeared to meet the Regulatory Guide's requirements for sampling with the exception of two areas.
The first involves the sampling frequency for water in the fuel oil tanks which is monthly in the regulatory guide.
The second is the requirement in the regulatory guide to sample new fuel oil p,ior to adding it to the tanks.
The licensee presently samples fuel oil quarterly as discussed above and does not sample the new fuel prior to adding it to the tanks.
The inspector did get a comitment from the licensee to review their program and bring it into compliance with the regulatory guide unless they develop good justification to the contrary.
Since the licensee does have a sampling program and is in compliance with the TSs the item is considered closed.
(Closed) LIV 338,339/88-11-01 Failure to Perform Surveillance Test on the Wide Range Containment Pressure Instruments.
Per a review of the corrective actions in LER 338,339/88-18, the inspector determined that based on the fact that the instruments were calibrated and operable and appropriate corrective actions have been instituted to prevent recurrence, this item is closed.
(0 pen) IFI 338,339/88-11-04, Development of the Check Valve Program in Response to IE Notice 86-09 and 86-01. The licensee has issued VPAP-0807, Check Valve Maintenance Program, effective November 24, 1989, as a result of earlier comitments to establish and implement a check valve PM program in response to liiPO SOER 86-3.
Due to the recent issuance of the procedure, the inspectors will continue to monitor the licensee's implementation of the check valve program.
(Closed) LIV 339/87-34-02, Violation of Technical Specification 3.9.4.
This licensee identified violation which involved the latching of control
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rods without containment isolation was also documented by LER 339/87-10.
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The corrective actions associated with the LER were reviewed and the LER was closed in NRC Inspection Report 338,339/88-31. The corrective actions for the LIV anc LER were the same, consequently the LIV is considered closed based on the 1988 review of the corrective actions.
(Closed) VIO 338,339/87-19-01, Violation of TS 6.8.1.c - Inadequate Control Room Emergency Surveillance Procedure and TS 3.7.7.1
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Habitability. The corrective action for this violation was verified to be adequate based on review of related LER 338,339/88-21 discussed in paragraph 9.
(Closed) IFI 338,339/87-19-07, NRR Letter 5-4-87 - Adequacy of Procedure for Access Control of Control Room.
This IFI was previously addressed in NRC Inspection Report 338,339/88-28, which involved maintaining the control room envelope at a positive pressure with relation to adjacent areas, and was found to be complete with the exception of the implementa-tion of several outstanding modifications discussed in paragraph 9 under LER 338,339/88-21. The remaining issues will be followed by this LER.
11.
Exit The inspection scope and findings were summarized on February 14 with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results listed below.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.
Dissenting comments were not received from the licensee, item Number Description and Reference
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338,339/90-01-01 Unresolved item - Potential violation of TS , 6.8.4a for failure to implement an adequate PM program and adequately leak check contaminated gas systems (paragraph 6).
338,339/90-01-02 Non-Cited Violation - Failure to follow 1-MISC-18 and ensure that all main steam valve house top vents were uncovered (paragraph 8).
338,339/90-01-03 Non-Cited Violation - Violation of TS 3.9.12 for failure to align the fuel building ventilation system tnrough the charcoal filters when spent fuel was being manipulated in the spent fuel pool (paragraph 9).
11. Acronyms and Initialisms AFW Auxiliary Feedwater
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AP Abnonnal Procedure AUX Auxiliary CAD Computer Assisted Drawing CAE Condenser Air Ejector CDA Containment Depressurization Actuation
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CR0 Control Room Operator CW Circulating Water DCP Design Change Package DHR Decay Heat Removal DUR Drawing Update Request EDG Emergency Diesel Generator EP Emergency Procedure EQ Environmental Qualification ESF Engineered Safety Feature EWR Engineering Work Requests GPM Gallons Per Minute HP Health Physics IFl Inspector Follow-up Item
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INP0 Institute for Nuclear Power Operations KW Kilowatt LCO Limiting Condition for Operation LER Licensee Event Report MCC Motor Control Center MOV Motor Operated Valve MPC Maximum Permissible Concentration MREM Millirem MSSV Main Steam Safety Valve NRC Nuclear Regulatory Commission NSE Nuclear Safety Engineering
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OSC Operations Support Center PDTT Primary Drain Transfer Tank PES Plant Engineering Services PORV Power Operated Relief Valve PM Preventative Maintenance
PROM Progrannable Read Only Memory PSIG Pounds Per Square Inch Gauge PTSS Periodic Test Scheduling System QS Quench Spray RCS Reactor Coolant System RHR Residual Heat Removal RMS Radiation Monitoring System RPS/S1 Reactor Protection System / Safety Injection RSHX Recirculation Spray Heat Exchanger i
RTD Resistance Temperature Detector RWP Radiation Work Permit RWST Refueling Water Storage Tank S/G Steam Generator SALP Systematic Assessment of Licensee Performance SI Safety injection SNSOC Station Nuclear Safety and Operating Committee
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SOER Site Operating Event Report STA Shift Technical Advisor i
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TI Temporary Instruction TS Technical Specification TSC Technical Support Center
UE Unusual Event URI Unresolved Item UFSAR Updated Final Safety Analysis Report
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VCT Volume Control Tank WGDT Waste Gas Decay Tank
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WOG Westinghouse Owners Group i
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