IR 05000338/1998011
| ML20207E139 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/01/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207E137 | List: |
| References | |
| 50-338-98-11, 50-339-98-11, NUDOCS 9903100157 | |
| Download: ML20207E139 (23) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION 11
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Docket Nos.:
50-338,50-339-I'
License Nos.:
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Report Nos:
50-338/98-11,50-339/98-11 i
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U ensee:
Virginia Electric and Power Company (VEPCO)
Facility:
North Anna Power Station, Units 1 & 2 Location:
1022 Haley Drive Mineral, Virginia 23117 Dates:
December 20,1998, through January 30,1999
Inspectors:
M. Morgan, Senior Resident inspector R. Gibbs, Resident inspector P. Fillion, Reactor Inspector (Section E8.1)
F. Wright, Senior Radiation Specialist (Sections RI.1, R1.2, R1.3, R2.1, R7.1 and R8.1)
Approved by:
R. Haag, Chief, Reactor Projects Branch 5
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Division of Reactor Projects l
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ENCLOSURE 9903100157 990301 PDR ADOCK 05000338 e
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i EXECL ilVE SUMMARY l
l North Anna Power Station, Units 1 & 2
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y NRC Inspection Report Nos. 50-338/98-11,50-339/98-11 l
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- and plant support.L The report covers a six-week period of resident inspection. In addition, it This integrated inspection included aspects of licensee operations, engineering, maintenance,
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- includes the results of an announced inspection by a regional inspector and radiation specialist.'
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Operations
The decision-making process to initiate the extreme cold weather procedure was -
reasonable and the procedure was properly implemented. The licensee's actions to
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correct a frozen _ casing cooling tank level instrument were appropriate (Section O1.2 ).
Tag outs for bsttery chargers.1-ill and 1-IV, instrument air compressor 1-1 A-C-1,
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. emergency diesel generator 2H, and component cooling water pump 2-CC-P-1 A, were properly performed. The tag outs properly reflected the work scope and all equipment was appropriately tagged in the correct positions (Section 01.3).
The overall condition of risk significant portions of the instrument air system was good.
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Components were properly aligned, labeled, and maintained. The running air compressor' operated within normal operating limits. The area around the air <
. compressors was clean. The licensee properly implemented maintenance rule requirements (Section O2.1).
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Housekeeping in the service water pump building was good and was a marked
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' improvement when compared to conditions previously observed. The diesel-driven fire
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pump and its support equipment were also in good condition and properly aligned for automatic operation (Section O2.2).
Train B of the Unit 1 low head safety injection (LHSI) system was properly aligned for
standby operation. -The inspectors identified no conditions that would prevent train B of the LHSI system from performing its design functions (Section O2.3).
- A Non-Cited Violation was identified for failure to test the Unit 1 boron injection tank
outlet valves in accordance with Technical Specification 4.0.5 requirements. The cause of the missed surveillance test was due to personnel error during a procedure change
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(Section 08.1).
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The inspectors concluded that the Management Safety Review Committee meeting met Technical Specification requirements and substantive assessment issues were addressed in related discussions (Section 08.3).
Maintenance -
Planned maintenance 'on the Unit 1 instrument air compressor cooling water heat L
I exchangers, 2H stub bus relays, and 1 A process vent blower expansion joint was properly performed. Workers were knowledgeable and followed work package s
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instructions. The work was properly approved and risk significant activities were
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properly evaluated for their impact on the plant's core damage frequency (Section M1.1).
Periodic tests associated with Unit 1 control rods, Unit 2 solid state protection system,
and the Unit 2 quench spray system were properly performed. The tests satisfied TS 4.
requirements and were performed by knowledgeable individuals who properly followed
. their procedures. Systems and components were properly returned to their normal plant configuration (Section M1.2).
Enaineerina
A non-cited violation was identified for design deficiencies of the auxiliary building
ventilation system which involved seismic qualifications of the control air supply and electrical power supply qualifications. Initial corrective actions, which included a
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justification for continued operation that placed strict limits on the emergency core -
cooling system leakage operational limits and planned actions to satisfy the design
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requirements were commensurate with safety (Section E1.1).
' The licensee has been proactive in identifying and repairing service water system
(SWS) microbiologically induced corrosion (MIC) pinhole leaks and has followed the NRC-approved generic relief request for resolving these SWS leaks. Development of long-term plans to correct the MIC leaks has been ongoing yet the licensee has not determined the overall scope of these plans (Section E1.2).
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The licensee's efforts to determine the scope of potentially incorrect material for charging pump motor lead lugs and corrective actions were comprehensive. Followup inspection of the laboratory test results on B charging pump motor lead lugs that appeared to be the wrong material type will be tracked as an unresolved item (Section E1.3).
Plant Supoort Individual worker doses were within allowable limits and the licensee continued to lower
annual collective occupational radiation doses (Section RI.1).
The licensee's surveys accurately measured radiation and high radiation areas and all
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areas were properly posted. All locked high radiation areas were properly secured.
Good use of posted radiation dose rate information in the auxiliary building was observed. Overall, housekeeping within the auxiliary building was good with some exceptions (Section R1.2).
The licensee's preparations for a shipment of radioactive material met applicable
regulatory requirements and the observed vehicle radiation surveys were very good
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The removal of a reactor coolant system letdown filter was care?ully performed.
- Workers adhered to their radiation work permit requirements and appropriately followed a
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their procedures. ' Health Physics personnel were effective in supporting the workers by ensuring radiation exposure was kept to a minimum (Section R1.4).
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In general, radiation detection and measurement instrumentation was found in good operating condition. Periodic source checks and instrument calibrations were being -
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performed. Calibration records documented appropriate calibration methods and were
in satisfactory order (Section R2.1).
Self-assessment processes in the radiation protection area were of high quality and had
contributed to program performance improvements (Section R7.1).
Security posts were properly manned, lighting conditions were appropriate, security
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personnel were attentive and the perimeter material condition was properly maintained (Section S2).
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L Report Details Summarv of Plant Status Units 1 and 2 operated at or near full power for the entire inspection period.
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1. Operations
~ 01 Conduct of Operations I
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01;1 ' Daily Plant Status Reviews (71707. 40500)
The inspectors conducted frequent control room tours to verify proper staffing, operator attentiveness, and adherence to procedures. The inspectors attended daily plant status
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meetings to maintain awareness of overall facility operations and reviewed operator logs
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to verify operational safety and compliance with Technical Specifications (TSs).
Instrumentation and safety system lineups were periodically reviewed from control room indications to assess operability. Frequent plant tours were conducted to observe equipment status and housekeeping. Deviation reports (DRs) were reviewed to ensure that potential safety concerns were properly reported and resolved. The inspectors found that daily operations were conducted in accordance with regulatory requirements and plant procedures. Good equipment material conditions were also evident by i
extended problem-free plant operation.
01.2 Extreme Cold Weather Readiness Review
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. Insoection Scope (71714. 37551)
The inspectors walked down various plant areas subject to freezing conditions and reviewed the licensee's extreme cold weather procedure.
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Observations and Findinos During the inspection period, outside temperature reached 10*F which met the
. licensee's criteria for extreme cold weather. As a result, general opemtirig picr.edure 0-GOP-4.2, " Extreme Cold Weather Operations," Revision 7, was implemented. The inspectors reviewed 0-GOP-4.2 and verified the completion of many of its actions. The
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L inspectors verified that the licensee properly implemented this procedure. During
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periods of extremely low temperature, the inspectors noted that the licensee monitored various. heat trace panels for alarms every three hours. The inspectors considered this
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L The inspectors discussed with the operations department superintendent the decision-making process used to enter 0-GOP-4.2. This was donc because one of the entry L
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conditions stated that the procedure should be entered when temperatures are forecasted to go below 32*F for an extended period M time. The inspectors considered
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this entry condition somewhat ambiguous. The iiispectors discussed with the superintendent the meaning of "an extended period of time." The superintendent stated
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that about 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of temperatures below or forecasted below 32*F would cause the
plant to implement the procedure. The inspector's considered the superintendent's
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. interpretation reasonable.
l On January 7, which was prior to 0-GOP-4.2 implementation, level transmitter 2 RS-LT-i l
203A which monitors the Unit 2 casing cooling tank level, froze resulting in an indicated l
high level condition. Actual tank level was not high as verified by a redundant
instrument. The licensee found that the transmitter's enclosure, which is used for freeze
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protection, was partially open. The transmitter was thawed, re-calibrated, and returned
to service. The licensee initiated DR N-99-0020 to determine the cause and to address
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appropriate corrective actions.
l The inspectors verified that the licensee properly entered the appropriate TS action statement when the transmitter was out of service. The inspectors walked down the
- affected enclosure with a senior reactor operator (SRO). The door to the enclosure and similar enclosures for other casing cooling tank level transmitters would not close tightly.
. Also, the enclosure door handles were configured differently from other enclosures which the licensee believed contributed to the event. The inspectors found that the licensee's cold weather procedures did not specifically address ensuring the transmitter
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enclosure doors were secure. The licensee stated that as part of their corrective actions
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the door hardware differences and procedure enhancements to check the enclosures i
would be addressed.
While walking down other freeze protection components with the SRO, the inspectors observed that the level transmitters for the Unit 1 and 2 sodium hydroxide tanks were partially exposed to outside temperature with no heat trace or insulation. The inspectors discussed with the licensee the potential that the transmitters could freeze. The i
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licensee subsequently issued an engineering transmittal which documented that the condition was not a problem since the transmitter's liquid interface was not exposed to freezing conditions. The inspectors reviewed the engineering transmittal and agreed with its conclusion, c.
Conclusions The decision-making process to initiate the extreme cold weather procedure was reasonable and the procedure was properly implemented. The licensee's actions to correct a frozen casing cooling tank level instrument were appropriate.
01.3 System Taa Out Reviews a.
. Inspection Scooe (71707)
Throughout the inspection period the inspectors walked down several system tag outs.
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Observations and Findinas The inspectors walked down the following active tag outs:
i 1-99-BY-0006 (Unit 1 battery charger 1-ill)
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l 2-99-IA-0001 (Unit 2 instrument air compressor)
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2-99-EE-0001 (Unit 2 H emergency diesel gene ator)
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1-99-BY-0008 (Unit 1 battery charger 1-IV)
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l 2-99-CC-0001 (Unit 2 component cooling water pump 1 A)
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l The inspectors'verif.ed that the tag outs were prop 7rly prepared. The tag outs properly I
reflected the work scape and proper authorization was obtained prior to the tag out
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implementation. In tddition, the tag outs were reflected on the plan of the day (POD)
which iridicated management's awareness of the condition. The inspectors walked I
down accessible components and verified that each component was in the required position and properly tagged. Where applicable, the inspectors ensured that the -
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maintenance operating procedure (MOP), which is used by the licensee for specific tag i
out instructions, was properly performed.
During the instrument air compressor tag out review, the inspectors noted that some component descriptiont..n the MOP did no' agree with the tag out descriptions and l
associated component labels. This was discussed with the licensee who stated that discrepancies were allowed as long as the equipment identification number (i.e., mark number) was identical and the discrepancy was not misleading.
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Conclusions Tag outs for battery chargers 1-lll and 1-IV, instrument air compressor 1-1 A-C-1, emergency diesel generator 2H, and component cooling water pump 2-CC-P-1 A were properly performed. The tag outs properly reflected the work scope and all equipment was appropriately tagged in the correct positions.
O2.
Operational Status of Facilities and Equipment
- O2.1 Instrument Air (IA) System Walkdown a.
inspection Scoos (71707. 62707)
On January 7 and 8, the inspectors performed a detailed walkdown of risk significant
. portions of the lA system. The inspectors focused on the air compressors and their cooling water system and piping and valves which supply the lA header. The inspectors
- also reviewed system performance as tracked by the licensee's maintenance rule (MR)
program.
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Observations and Findings
' The inspectors used operating procedures and plant drawings to verify proper valve
< position and labeling.' All components were in their required position and properly labeled. The components checked were in good cunWtion. There was very little rust and no leakage was found. The general area arourni the compressors was clean. The inspectors examined the 4160V breakers for each au compassor and found them to be
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4 in good condition and properly labeled. The inspectors also ensured the running air compressor's operating parameters were within normal operating ranges. The inspectors reviewed section 9.3.1 of the Updated Final Safety Analysis Report (UFSAR)
to ensure the components inspected were consistent with the UFSAR description and
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no problems were found.
The inspectors reviewed the system's performance criteria with the MR coordinator.
The Unit 1 comprecsor was in MR a(1) status due to increased unavailability. The unavailability had been caused by microbiologically induced corrosion of the service water supply and return header piping to the compressor cooling water system and replacement of compressor timers. The inspectors reviewed the licensee's goal setting for the compressor to ensure MR requirements were met. The inspectors found that goals to improve compressor availability had been established and were being monitored. The inspectors reviewed documentation which tracked the number of maintenance preventable func+ional failures (MPFFs) that had occurred during the current assessment period. The inspectors found that the number of MPFFs was below the licensee's established limit fu system reEability performance criteria. Overall implementation of MR requiremems was sa'Jsfied.
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Conclusions The overall condition of risk significant portions of the instrument air system was good.
Components were properly aligned, labeled, and maintained. The running air compressor operated within normal operating limits. The area around the air compressors was clean. The licensee properly implemented maintenance rule requirements.
02.2 Service Water (SW) Pumo Buildina and Diesel-Driven Fire Protection (FP) Pumo Walkdown a.
Inspection Scope (71707)
The inspectors performed a general walkdown of the SW pump building to examine housekeeping and material conditions. The inspectors also checked the condition of the diesel-driven FP pump.
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Observations and Findinas The inspectors toured the SW pump building and noted that the SW pumps and valves
were in good condition. The inspectors also noted that housekeeping was a marked Improvement when compared to conditions previously observed (Inspection Report 50-
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338/97-06; Section O2.1). The building had been recently painted. The inspectors noted that minor oil spillage around the traveling screens and other SW components was routinely removed..The SW building sump pumps were tagged out for corrective maintenance and provisions had been established for use of temporary sump pumps.
Oillevels for the SW pumps and traveling screens were acceptable. The SW building ventilation system including dampers and fans were in good running order and building temperature was maintained about 60*F which indicated the building's freeze protection systems were operationa.
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The inspectors also checked the diesel-driven fire pump. The inspectors noted that residual fuel oil under and around the diesel / pump was minimal. The condition of the
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diesel batteries was good and no battery acid corrosion was evident. The FP diesel
control panel was aligned properly for automatic operation. The fuel oil day tank area
was clean and oil was at proper levels. Based on the reviews and checks performed the
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inspectors noted that the components were in good working order.
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Conclusions i
Housekeeping in the service water pump building was good and was a marked I
improvement when compared to conditions previously observed. The diesel-driven fire j
pump and its support equipment were also in good condition and properly aligned for i
automatic operation.'
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O2.3 Low Head Safety iniection (LHSI) System Walkdown (71707)
t The inspectors performed a general walkdown of accessible portions of train B of the
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Unit 1 LHSI system. The as-built system configuration and valve alignment were compared to system print 11715-FM," Safety injection System," Revision 36. All components were properly labeled and aligned; The inspectors checked the condition j
of numerous piping supports and snubbers and found them to be in good condition.
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Housekeeping and system material conditions were good. The inspectors identified a l
small amount of oil near the LHSI pump motor and the presence of boric acid crystals
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around the pump shaft seal area. Oil level was verified to be at its proper level. Further, l
the inspectors did not identify any active leakage from the pump shaft. The inspectors forwarded these deficiencies to the licensee for resolution. Train B of the Unit 1 LHSI system was properly aligned for standby operation. The inspectors identified no conditions that would prevent train B of the LHSI system from performing its design functions.
Miscellaneous Operations issues (92901, 92700)
08.1 (Closed) Licensee Event Reoort (LER) 50-338/98-004-00: motor operated valve missed surveillance due to personnel error. On September 2,1998, the licensee determined l
that the Unit 1 boron injectbn tank (BIT) outlet valves were not tested in accordance j
with TS 4.0.5. Specifically, valves 1-SI-MOV-1867C and 1-SI-MOV-1867D were not operated in the open and closed directions at their required quarterly surveillance
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interval to ensure their stroke times met test requirements. The valves should have L
been tested prior to July 28,1998. When the problem was found the licensee appropriately entered TS 4.0.3 and satisfactorily tested the valves within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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The licensee determined the cause of the missed surveillance was due to personnel j'
error during a procedure revision. Test procedure 1-PT-213.22," Valve Inservice l
Inspection [ Safety injection System)," Revision 7, which tested the BIT inlet and outlet.
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valves, was deleted and replaced with a new procedure which changed the test
frequency for the BIT inlet valves frorn quarterly to during cold shutdown. ~ The technical justification for this frequency change, however, did not include the BIT outlet valves.
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procedure in place to ensure the required testing took place.
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- The inspectors reviewed operating logs and related test procedures to verify accuracy of the event as described in the LER. The inspectors also verified that corrective actions i
addressed the cause and were comprehensive. This review also verified that once the i
missed surveillance was discovered that proper actions (e.g., entry into TS 4.0.3 and j
subsequent successful testing) were taken by the licensee. No problems were found during this review.- The inspectors also discussed corrective actions with the procedures i
group supervisor. The inspectors were satisfied that the corrective actions were -
l appropriate. These actions focused on counseling of involved individuals on their j
responsibilities during the procedure change process. In addition, the licensee t
performed a critique of the procedure revision process. This critique revealed that en
individual initiating a procedure ch9nge could also be the procedure change reviewer.
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This practice is no longer allowed. The licensee also performed a search for similar
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events and found none. The licensee considered the event to be isolated.
i The inspectors evaluated the safety significance of the missed surveillance and l
determined it to be low. Once the problem was discovered, the valves were tested and l
found to meet TS requirements. In addition, the valves had been successfully tested
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during the previous quarter. Failure to perform the required TS testing of the BIT outlet i
valves is a violation of TS 4.0.5. This licensee-identified, non-repetitive, and corrected l
violation is being treated as a Non-Cited Violation (NCV) consistent with Section Vll.B.1 I
of the NRC Enforcement Policy. This item is identified as NCV 50 338/98011-01.
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'08.2 (Closed) Violation (VIO) 50 339/98003-01: failure to properly implement tagging requirements for the residual heat removal (RHR) system. This violation was identified for failure to properly tag out the RHR system during the April 1998 Unit 2 refueling
outage. The violation also involved the failure of the independent verification process.
i The inspectors reviewed the licensee's response, dated July 28,1998, and verified that identified corrective actions were adequate and appropriately implemented.
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08.3 ~ Manaaement Safety Review Committee (MSRC) Meetina (40500)
On January 27, the inspectors attanded an MSRC meeting at the North Anna site. The inspectors listened to the site vice president's plant status reports and the oversight ~
subcommittee's report. The inspectors determined that the MSRC meeting met TS 6.5.2 requirements for member composition / quorum. The agenda appropriately
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included review items required by TS 6.5.2.7. The inspectors noted that the site vice president's reports generated self-critical discussions of station performance. The
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Inspectors concluded that the MSRC meeting met TS requirements and that substantive
assessment issues were addressed in related discussions.
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II. Maintenance
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M1 Conduct of Maintenance M1.1 Observation of Preolanned Maintenance Activities i
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Inspection Scope (62707)
The inspectors observed all or portions of the following work orders (WOs):
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401861 01, 401862 01, 401863 01 Clean / inspect instrument air compressor
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1-IA-C-1 cooling water heat exchangers j
.403495 01 2H stub bus relay maintenance l
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369031 02 Expansion joint replacement for 1 A process
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vent blower v
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Observations and Findinos --
l All work had been properly approved by operations and was included on the POD.
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When work was associated with a risk significant structure, system, or component, it
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was evaluated to determine its impact on the plant's core damage frequency. Where
.i applicable, appropriate TS action statements were implemented. The inspectors found
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the work performed under these activities was professional and thorough. The work
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was performed with the work package present and in use. Accompanying documents
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such as procedures and supplemental work instructions were properly followed.
j Personnel were experienced, properly trained and knowledgeable of their assignments.
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' Conclusions
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Planned maintenance on the UrP 1 instrument air compressor cooling water heat exchangers, 2H stub bus relaya, and 1 A process vent blower expansion joint was properly performed. Workers were knowledgeable and followed work package instructions. The work was properly approved and risk significant activities were properly evaluated for their impact on the plant's core damage frequency.
M1.2 Miscellaneous Periodic Tests (PT) Observations a.
Insoection Scope (61726).
j The inspectors observed the performance of all or pvtions of the following tests:
1-PT-17.1, " Control Rod Operability," Revision 19
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2-PT-36.5.3A, " Solid State Protection System Output Slave Relay Test (Train
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2-PT-63.1 A, " Quench Spray System
"A" Subsystem," Revision 20
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. Observations and Findinos
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The inspectors verified that the tests were properly approved by management and were
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included on the POD. For risk significant activities, the inspectors ensured that the licensee had evaluated on-line maintenance risks in accordance with the ' licensee's maintenance rule program. The inspectors checked selected components for their pre-test and post test positions to ensure they were properly positioned and no i
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discrepancies were identified. - The inspectors examir,ed test instruments to ensure the instruments had been calibrated and their calibration due date had not expired. When i
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TSs were involved, the inspectors ensured that the appropriate TS action statements were implemented. The inspectors also reviewed the test acceptance criteria to ensure they were consistent with TS requirements and no problems were found. TS surveillance interval requirements were also checked to ensure the required frequencies were satisfied. The inspectors reviewed selected test data to ensure component -
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L performance was satisfactory and no problems were found. Selected test data were L
also independently calculated to ensure reported results were accurate. During test
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performance the inspectors evaluated procedure adherence, communications between
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l the workers, and workers' knowledge of the assigned activities. The inspectors found i
that implementation of these system testing work practices to be satisfactory.
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QQD.clusions l
Periodic tests associated with Unit 1 control rods, Unit 2 solid state protection system, and the Unit 2 quench spray system were properly performed. The tests satisfied TS requirements and were performed by knowledgeable individuals who properly followed their procedures. Systems and components were properly returned to their normal plant configuration.
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l M8 Miscellaneous Maintenance issues (92902)
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M8.1 ' ' LClosed) VIO 50-338. 339/98004-02: failum to properly verify that the backup weather
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l tower wind direction indication was normal after calibration. During instrument i
l calibration, technicians improperly installed wind direction ' equipment on tho back-up j
l meteorological tower such that the indicated wind direction was 180* out from the actual
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wind direction. A violation was identified for failure to properly verify backup weather l
tower wind direction indication following maintenance. The inspectors reviewed the
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licensee's response, dated September 4,1998, and verified that identified corrective actions were adequate and appropriately implemented.
i lit. Engineering E1 Conduct of Engineering E1.1 Desian Deficiencies Associated with Auxiliary Buildina Central Exhaust Ventilation Damoer Controls -
a.
Inspection Scope (37551)
The inspectors reviewed documentation and discussed with engineering personnel design deficiencies associated with the auxiliary building central exhaust ventilation damper controls. The inspectors also walked down the affected components.
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Observations and Findinos The licensee discovered that controls for air operated dampers which direct air flow from
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the auxiliary building ventilation central exhaust pathway through the auxiliary building ll charcoal filters do not meet design requirements. Specifically, the solenoids for i
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dampers 1-HV-AOD-103-1,1-HV-AOD-103-2,1-HV-AOD-103-3, and 1-HV-AOD-103-4 did not have a seismically qualified air supply and their electrical power supply, although
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l powered from the emergency buses, did not pass through an electrical inverter. These
design requirements are discussed in NRC Regulatory Guide 1.52, Revision 1, and were committe 1 to by the licensee as discussed in UFSAR Section 6.2.3.2. The
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inspectors reviewad the UFSAR to confirm the licensee's findings. The licensee initiated
- DR N-98-3918 to determine the cause and to address appropriate corrective actions for
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this non-conform;ng condition.
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The licensee immediately initiated Justification for continued operation (JCO) C-98-01.
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The inspectors reviewed the JCO and determined that formal NRC review was not required because this non-conforming condition did not affect system operability and the
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involved equipment was not in conflict with the TS. As part of the JCO, the licensee i
initiated a compensatory action to reduce the emergency core cooling system (ECCS)
leakage limit from 800 cc/hr to 600 cc/hr to ensure that licensing basis limits for dose to control room operators described in 10CFR50 Appendix A, Criterion 19 would not be
,
exceeded during a loss of coolant accident (LOCA). The inspectors reviewed i
engineering documents, including a 10CFR50.59 screening, which supported the
]
compensatory action and concluded the compensatory action was appropriate.
The licensee'also initiated request for engineering assistance (REA) 1998-231 to f'
- evaluate implementation of a design change package (DCP) to permanently correct the design deficiencies. The inspectors discussed with the licensee the proposed schedule for the DCP implementation. The licensee stated that the DCP would be assigned by May 1999 and is planned to be implemented in 1999. The inspectors considered the
. licensee's proposed corrective actions to be commensurate with safety.
During their evalua'. ion of these design deficiencies the licensee determined the overall risk to the plant and safety significance of these design deficiencies to be low. The i
inspectors performed an independent review of the licensee's safety significance
determination. This effort included a review of the FSAR, Regulatory Guide 1.52 and other documentation, and a walkdown of the applicable sections of the auxiliary building l
ventilation system. Based on this review the inspectors agreed that the overall.
- significance of the design deficiencies was low. Failure to correctly translate design
)
- requirements into specifications, drawings, procedures, and instructions is a violation of
)
,
-10CFR50 Appendix B, Criteria Ill. This licensee-identified, non-repetitive,'and corrected violation is being treated as a Non-Cited Violation (NCV) consistent with Sectiori Vll.B.1
of the NRC Enforcement Policy. This item is identified as NCV 50-338/98011-02.
,
c.
Conclusions i
L L
A non-cited violation was identified for design deficiencies of the auxiliary building
'
ventilation system which involved seismic qualifications of the control air supply and
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' electrical power supply qualifications. Initial corrective actions, which included a
'
justification for continued operation that placed strict limits on the emergency core i
cooling system leakage operational limits and planned actions to satisfy the design requirements were commensurate with safety.
$
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,.,,
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j E1.2 Reoairs of Service Water System (SWS) Pioina Exoosed To Microbioloalcally Induced s
Corrosion (MIC) and Current Status of MIC Control
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a.
Inspection Scope (37551)
-)
i
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The inspectors conducted follow-up inspections of recently discovered pinhole leaks i
. located at suspected SWS piping MIC sites. The inspectors also reviewed pertinent engineering documentation and conducted interviews with engineering personnel to -
!
further assess the licensee's on-going efforts to control MIC.
j
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i b.
- Observations and Findinos :
j On January 7, the licensee discovered a through-wall pinhole leak on the B SWS cooling water supply headers for the charging pumps and instrument air compressors.
On January 13, the licensee discovered another through-wall pinhole leak on the A supply header for the same equipment. On January 28, an additional active MIC leak on the SWS cooling line from the 1-1A-C-1 instrument air compressor coolers was discovered by the licensee. The inspectors verified that the leaks were less than one
.
gpm which was the licensee's limit for determining operability of defects that have been
'
determined to be pin hole leaks. An additional aspect of the licensee's operability -
evaluation was that the leaks did not affect the structural integrity of the piping. The
,
inspectors conducted follow-up inspections for the January 7 and January 28 leaks and
'
in each case the inspectors noted that a WO was properly initiated, appropriate repairs were performed, and a DR was initiated.
The inspectors have noted that the SWS had been experiencing MIC problems for more than two years. In non-destructive examination (NDE) reports, the inspectors noted that radiographic examinations of the SWS welds with through-wall pinhole leaks revealed i
small voids surrounded by exfoliation.
Prior to 1998, when signs of MIC were discovered, the licensee applied for relief -
requests from code repairs.' These evaluations and repairs were made in accordance l
with NRC Generic Letter (GL) 90-05, " Guidance for Performing Temporary Non-Code l
Repair of ASME Code Class 1,2 and 3 Piping." In 1998, the licensee received from the
NRC, a generic relief request which varied from the GL guidance. The 1998 relief l
request no longer required an individual relief request for every MIC induced leak or stain discovered. The inspectors have noted that this relief guidance has been implemented on numerous occasions.
i in 1997, the licensee formed a task team to determine a more permanent solution to the MIC problem. In 1998 the task team approached other plants with similar MIC problems and as a result had incorporated new initiatives into their corrective action plans. The inspectors reviewed these plans and monitored plan implementation and concluded that the licensee's efforts were reasonable.
I j
- c.
Conclusions I
i'
The licensee has been proactive in identifying and repairing SWS microbiologically
'
induced corrosion pinhole leaks and has followed the NRC-approved generic relief
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request for resolving these SWS leaks. Development of long-term plans to correct the MIC leaks has been ongoing yet the licensee has not determined the overall scope of these plans.
E1.3 Charaina Pumo Motor Lua Material Specification - Potential Nonconformance
a.
Insoection Scope (37551)
The inspectors conducted a follow-up inspection of a recently discovered Raychem splice for the Unit 2 it charging pump with signs of overheating. The inspectors conducted intervieu with engineering personnel and reviewed pertinent documentation
,
for an overall assessment of the problem.
b.
Observations and Findinas
.
On January 4 during routine preventive maintenance of the Unit 2 B charging pump, the licensee discovered that a Raychem splice on the A phase motor lead to the pump motor was da 'naged. The splice, which is usually red in color and pliable, was blackened arid appeared damaged by overheating. The inspectors noted that the Raychem-splices for the B and C phases appeared to be normal.
The licensee initially suspected that the motor lead lugs for all three phases were not in conformance with material specification NA3014. This specification requires the use of series 6000 aluminum or aluminum alloyed lugs. The licensee noted that the lugs appeared to be copper which could have contributed to the overheating of the Raychem splice and a potential failure of the lead. The inspectors examined the burned splice and one of the undamaged splices and agreed with the licensee's initial assessment.
The inspectors reviewed the material specifications and verified that the specifications required aluminum lugs. All lugs for the B pump motor leads were replaced, which the inspectors confirmed.
During routine previously planned maintenance activities which occurred in the remainder of the inspection period, the licensee inspected the Unit 2 A and C charging pump motor leads and noted that the lugs met specification requirements. The inspectors performed a follow-up observation of licensee inspection activities and found no problems. At the end of the inspection period, the licensee continued with plans to inspect the Unit 1 charging pump motor leads. In order to confirm that the removed Unit 2 B pump lugs did not meet specification requirements, the licensee sent the removed
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splices / lugs to their corporate metallurgicallaboratory. At the end of the inspection
'
period, the laboratory results which are needed to further evaluate this issue were not available. Pending completion of the laboratory assessment and followup review by the inspectors this issue is identified as an unresolved item (URI) 50-339/98011-03.
c.
Conclusions The licensee's efforts to determine the scope of potentially incorrect material for charging pump motor lead lugs and corrective actions were comprehensive. Followup in'spection of the laboratory test results on B charging pump motor lead lugs that appeared to be the wrong material type will be tracked as an unresolved ite.. _ _ _. _.. _
.._
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E8'
Miscellaneous Engineering issues (92903) -
E8.1 (Closed) Inspection Followuo item (IFI) 50-338. 339/98005-04: diesel generator loading transient analysis for the delayed DBA case. Following the inspection for NRC Integrated Inspection Report Nos. 50-338,339/98-05, the licensee reviewed the control circuits for the major loads which sequence onto the diesel generator for the various design basis events. They specifically reviewed the control circuits to determine the
- timing of the load,i.e. the number of seconds after re-energization of the safety-related bus and/or the number of seconds after the safety injection (SI) and containment depressurization (CDA) signals that the load becomes energized by the diesel generator. The timing of each load for seven scenarios was determined, and time line
~
diagrams for each scenario were prepared. From the timo line diagrams the licensee determined the largest load block. The seven scenarios analyzed were:
e Loss of offsite power (LOOP)
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e LOOP with simultaneous CDA '
q
LOOP followed by Si at 10 seconds
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LOOP followed by Si at 15 seconds l
e-e-
LOOP followed by CDA at 10 seconds j
e LOOP followed by CDA at 15 seconds
This analysis was done in July of 1998, and it concluded that the largest load block was bounded by the_ existing diesel generator transient loading analysis. No more than two _
!
motors could start simultaneously at any given time. The IFl had been established after
,
it was thought that three motors could start simultaneously. The analysis showed that
three motor starts were not credible. The inspectors reviewed all the control circuits for
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- the _ major loads sequenced to the diesel generator, and found that the licensee's time
line diagrams were correct. Tile licensee's diesel generator sequencing scheme t
analysis bounded the delayed Si and CDA scenarios.
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IV. Plant Support
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R1 Radiological Protection and Chemistry (RP&C) Controls l
l R1.1 - Occuoational Radiation Worker Exoosure
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a.
Inspection Scope (83750)
'
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The inspectors reviewed and evaluated radiation protection program performance and l
licensee's progress in maintaining occupational radiation exposures As Low As is i
Reasonably Achievable (ALARA). The inspection included reviews of records and
procedures and interviews with licensee personnel. The status of collective personnel i
exposure and maximum individual radiation exposures for 1998 were reviewed.
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b.'
Observations and Findinas TCollective occupational radiation exposures continued to decline. Total site collective doses in person-rem were 359 in 1996,102 in 1997, and 270 in 1998. There were
!
refueling outages (RFO) in years 1996 and 1998. The three year averages in person-rem / unit declined from 243 in 1995,142 in 1996,125 in 1997 to 110 in 1998.
.
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i The licensee failed to meet the 1998 Unit 2 RFO outage goal of 100 person-rem by l
approximately 57 person-rem. This also resulted in the failure to meet the 1998 annual collective dose goal of 216 person-rem by approximately 53 person-re'm. Increased
,
reactor coolant radioactivity following the Unit 2 shutdown contributed to the increased
collective doses and failure to make the outage and annual collective dose goals.
!
Causes for the increased reactor coolart activity were not fully understood and the
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licensee was working _with industry persons experiericed in reactor chemistry to better understand the causes of the elevated reactor coolant radioactivity and resulting increased doses, j
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All occupational radiation worker doses were well within allowable limite.
i c.
Conclusions i
Individual worker doses were within allowable limits and the licensee continued to'iower annual collective occupational radiation doses.
I R1.2 : Radio!aalm! Controls
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a.
Inspection Scope (83750)
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The inspectors toured the auxiliary building to observe implementation of radiological-l controls and to verify the controls met licensee and regulatory requirements.
j
'b.
. Observations and Findinas
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The inspectors reviewed licensee radiation surveys of toured areas and made l
ladependent radiation surveys in those areas to evaluate the adequacy of the licensee's i
surveys. The inspectors also observed radiological control postings and made radiation j
surveys to verify radiation and high radiation areas were properly posted. All locked i
high radiation areas (LHRA) were also checked to verify they were properly secured and controlled.
The inspectors observed the establishment of low dose areas with!n the auxiliary
building and the use of radiation area signs indicating radiation dose rate ranges in
'
those areas. This provided useful information to the radiation worker attempting to
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minimize personal radiation exposures.
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. Housekeeping and cleanliness within the auxiliary building were good with some l
H exceptions. There was some chipped paint, faded or di.ty paint, and boron l
accumulation on one room floor. The inspectors noted o work order had been posted at
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the door to have the floor cleaned. g The tool room in the auxiliary building was cluttered with tools that were not in their assigned storage areas.
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Conclusions :
j The licensee's surveys accurately measured radiation and high radiation areas and all
- areas were properly posted. All LHRAs were properly secured. Good use of posted radiation dose rate information in the auxiliary building was observed. Overall,
housekeeping within the auxiliary building was good with some exceptions.
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R1.3 ~ ~ Transoortation of Radioactive Materials.
I
) a.
Inspection Scope (86750)
j
A shipment of the surface contaminated material was reviewed to verify the licensee was implementing the applicable licensee procedures and NRC and Department Of '
'
Transportation shipping requirements.
The inspection 1ncluded reviews of records and procedures, interviews with licensee
,.
i personnel, and observations of licensee personnel preparing a radioactive material
-
shipment.. The process for estimating the radioactivity of the surfece contaminated
components was reviewed.' The preparation, packaging, and ra'diadon surveys for the
- transport of the low level radioactive material shipment were observed.
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b.'
Observations and Findinos
'
I Preparations for a shipment of low level radioactive material were observed and were reviewed with licensee' personnel. The estimate of radioactivity was adequate. The transportation package and transport vehicle were properly prepared. ' Shipping L
paperwork met applicable requirements and the radiological surveys of the transport vehicle were very good.
c.
Conclusions L
The licensee's preparations for a shipment of radioactive material met applicable regulatory requirements and the observed vehicle radiation surveys were very good.
R1.4' - Latdown Filter Chance-out l
a..
inspection Scooe (71750)
i LThe inspectors' observed activities associated with the replacement of a reactor coolant
. system (RCS) letdown filter, b.
Observations and Findinos j
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' On January 4, the inspectors observed maintenance and health physics (HP) personnel
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remove a letdown filter. The inspectors verified that workers followed their radiation work permit requirements. The area was properly posted for radiation hazards. The i
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. - - - - ~ - _ - -. -... -
-.. -... -... - ~.
.... -... -. -. - - - - - -.
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- area was also enclosed with a tent with an associated air blower / filter in the event the
L L area became airborne. The inspectors observed that maintenance personnel were assisted by a procedure coordinator. This helped expedite the evolution and therefore
lower radiation exposure. Use of the coordinator also ensured that procedure i
L adherence was appropriate. HP personnel were effective in their support of the
{
L evolution. Radios were used which helped the HPs support the workers more efficiently.
!
L The filter change-out occurred without incident.
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c.
Conclusions.
l
.
l The removal of a reactor coolant system letdown filter was carefully performed.
l l
. Workers adhered to their radiation work permit requirements and appropriately followed their procedures. Health Physics personnel were effective in supporting the workers by
.
l ensuring radiation exposure was kept to a minimum.
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t R2 Status of RP&C Facilities and Equipment l
f R2.1 Radiation Survev and Monitorina Eauioment
!
a.
Insoection Scope (83750)
l L
t L
The inspectors observed and examined portable radiation monitoring equipment
,
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L operating in the auxiliary building and the radiological survey equipment used by the
-
inspectors and HP technicians during the survey of a radioactive material shipment.
'
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The instruments were inspected to verify they operated properly, had received periodic response checks, and were calibrated in accordance with licensee procedures.
i
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l b.
Observations and Findinas
!
The radiation monitoring instruments, which included radiation detectors, contaminatiori friskers, and air samplers, had valid calibration dates and were being response checked as required by the licensee's procedures. The inspectors reviewed the last two calibration records for several of the instruments. The reviewed calibration records documented appropriate calibration results.
During the examination of one of the continuous air monitors the inspectors noted that the flow through the flow meter was about half of the recommended flow. The finding was re' ported to the instrumentation staff and upon their investigation, the air monitor was promptly replaced. The licensee scheduled the removed air monitor for
.
. maintenance and repair.
!
L c.
Conclusions in general, radiation detection and measurement instrumentation was found in good
. operating condition. Periodic source checks and instrument calibrations were being
,
performed. Calibration records documented appropriate calibration methods and were in satisfactory order,
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16 i
R7
, Quality' Assurance in RP&C Activities -
. R7.1 Radiological Protection Self-Assessments
= a.
Scope of inspection (83750. 84750. 86750)~
i The inspectors reviewed several self-assessments in various radiation protection
'{
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program areas to evaluate their quality.'
>
b.
? Observations and Findinas L Guidance for the self-assessment process was procedurally controlled with established frequencies for the various program area reviews. The inspectors reviewed the last two i
self-assessments in several program areas. The inspectors found the checklist for the'
?
assessments were thorough. The licensee, in general, had qualified personnel to j.
conduct the reviews. Assessment documentation was thorough and complete. The
!
. licensee also performed some bench marking with other licensee's and had received some.outside support on some assessments.
c.
Conclusions Radiation protection self-assessments were of high quality and contributed to program l
performance improvements.
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R8-Miscellaneous'RP&C lasues (83750)
R8.1 - (Closed) Violation 50-338. 339/98003-04: inadequate radiological survey on camera prior to releasing from the radiation control area. The inspectors reviewed the corrective actions for the violation which involved a failure to adequately survey a camera for radioactive contamination on May 4,1998. The finding was identified as a violation of licensee procedures and 10CFR20.1501 survey requirements. The licensee response
- to the violation, dated July 28,1998, described corrective steps which had been completed and corrective steps taken to avoid further violations. Additional detectors
- that are more sensitive to low levels of radioactive byproduct contamination were installed at the radiological control area (RCA) exit and procedures were revised to l
y address the proper use of the new instrumentation for the release of materials from the l~
RCA. : The licensee also developed training for the staff in the proper use of the new instrumentation. The inspectors verified the equipment had been installed and the training had been provided.
l-IS2 Status of Security Facilities and Equipment (71750)
'
During.the inspection period, the inspectors performed routine walkdowns of the protected area perimeter to assess security / general barrier conditions. On January 8
!
and 14, the inspectors performed an off-hours inspection of the protected area
perimeter. This inspection included observations of lighting conditions under vehicles, trailers, around protected area tanks, and support buildings. Protected area fencing
-
and the presence of roving security personnel were observed. Off-hours attentiveness of security personnel was also checked. The inspectors concluded that security posts
s L
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j were properly manned, ligh?g conditions were appropriate, security personnel were
- attentive and the perimeter Uaterial condition was properiy maintained.
V. Management Meetings
'
l X1 Exit Meeting Summary-i
(
The inspectors presented the inspection results to members of licensee management at l
l the conclusion of two weekly inspections on January 29,1999 and at the conclusion of (
the six-week inspection on February 2,1999. The licensee acknowledged the findings
'
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-' presented.
i i:
l The inspecters ' asked the licensee whether any materials examined during the i
inspection should be considered proprietary. No proprietary information was identified.
.
,
. PARTIAL LIST OF PERSONS CONTACTED l
Licensee f
.
I
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l-J. Bishoff, Director, Design Engineering
}
t D. Christian, Vice President, Nuclear Operations
E. Dreyer, Supervisor Health Physics - Technical Services
!
l B. Evans, Supervisor Health Physics - Operations
!
B Foster, Superintendent, Station Engineering
- C. Funderburk, Manager, Station Safety and Licensing J. Hayes, Director, Nuclear Oversight D. Heacock, Manager, Station Operations and Maintenance
L. Jones, Acting Superintendent, Radiation Protection
.
'
P. Kemp, Supervisor, Licensing ~
L. Lane, Superintendent, Operations B. Leonard, Manager, Nuclear Engineering l
T. Maddy, Superintendent, Security j
W. Matthews, Site Vice President H. Royal, Superintendent, Nuclear Training
,
D. Schappell, Superintendent, Site Serv'mes i
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- R. Shears, Superintendent, Maintenance l
A. Stafford, Superintendent, Radiological Protection
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NBQ j
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l K.' Coyne, Region ll Inspector Trainee
. N. Kalyanam, North Anna NRR Project Manager j
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18
INSPECTION PROCEDURES USED
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IP 37551:
- Onsite Engineering IP 40500:
Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing
Problems b
. lP 61726:
Surveillance Observations
. IP 62707:.
Maintenance Observations
,
IP 71707:
Plant Operations IP 71714:
Cold Weather Preparations
,
IP 71750:
- Plant Support Activities.
IP 83750:
~ Occupational Radiation Exposure '
IP 84750:
- Radioactive Waste Treatment and Effluent and Environmental Monitoring
IP 86750:
Solid Radioactive Waste Management and Transportation of Radioactive
- Materials
<
IP 92700:
Onsite Followup of Written Reports of Nonroutine Events at Power
'j
- Reactor Facilities -
IP 92901:
Followup - Plant Operations IP 92902:
' Followup - Maintenance
IP 92903:
Followup - Engineering ~
!
e ITEMS OPENED AND CLOSED l
!
i Opened
'50-338/98011-01-NCV failure to perform the required TS testing of the BIT outlet valves (Section 08.1)
,
50-338/98011-02 NCV failure of the design control process such that the auxiliary building ventilation system as-built
,
configuration did not meet all design requirements (Section E1.1)
l
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50-339/98011-03 URI potential nonconformance with material
. specifications for charging pump motor lead lugs (Section E1.3)
!
Closed l
50-338/98004-00 LER motor operated valve missed surveillance due to
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personnel error (Section 08.1)
50-338/98011-01 NCV failure to perform the required TS testing of the BIT outlet valves (Section 08.1)
.l
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50-338/98011-02.,
NCV failure of the design control process such that the L
auxiliary building ventilation system as-built configuration did not meet all design requirements (Section E1.1)
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-19 50-339/98003-01:
VIO failure to properly implement tagging requirements I
for the RdR system (Section 08.2)
50-338,339/98004-02 V:0 tailure to properly verify that the backup weather tower wind direction indication was normal after
cW5tation (Section M8.1) -
50-338,339/98005-04 IFl diesel generator loading transient analysis for the
!
delayed DBA case (Section E8.1)
,
50-338,339/98003-04 VIO inadequate radiological survey on camera prior to releasing from the radiation control area (Section i
R8)
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