IR 05000382/1993032
| ML20058E629 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/29/1993 |
| From: | Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058E621 | List: |
| References | |
| 50-382-93-32, NUDOCS 9312070084 | |
| Download: ML20058E629 (12) | |
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k APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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i Inspection Report:
50-382/93-32 i
Operating License: NPF-38 Licensee:
Entergy Operations, Incorporated i
P.O. Box B Killona, Louisiana 70066 l
Facility Name:
Waterford Steam Electric Station, Unit 3
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Inspection At: Taft, Louisiana
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Inspection Conducted:
September 19 through October 30, 1993 j
l Inspectors:
E. J. Ford, Senior Resident Inspector J. L. Dixon-Herrity, Resident Inspector
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Approved:
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Thomas F. Stetka, Chief, Project Section D Da'te '
l Inspection Summary-l Areas Inspected: Routine, unannounced inspection of plant status, operational i
safety verification, maintenance and surveillance observations, and review of l
licensee event reports.
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Results:
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i The licensee reacted quickly to eliminate an industrial safety concern
(Section 2.1.2).
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i A second example of the apparent violation identified in NRC Inspection
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Report 50-382/93-33 was identified for the failure of licensee i
personnel to promptly identify and enter the failure of Valve MS-120B
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into the corrective action system for proper resolution (Fection 2.2).
i A shift supervisor failed to use all available on-shift resources in e
diagnosing a test anomaly (Section 2.2).
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i A violation was identified for failure to follow procedures. A system
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e operating procedure step requiring Valve CMU-ll31 to be returned to its i
locked closed position was not adhered to for 2 months ard resulted in the failure of the automatic makeup system for the ultimate heat sink j
(Section 2.3).
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9312070084 931129 '
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Operators had previously identified a problein with the makeup system's
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ability to keep up with system losses, but failed to enter this problem into the corrective action system to allow the cause to be identified
(Section 2.3).
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The conservative health physics practice of surveying all material i
before it was removed from the site enabled the licensee to identify a l
bottle of radioactive gas prior to its removal from site (Section 2.4).
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Routine maintenance activities and surveillances observed were performed i
e according to procedure and good communications were noted between the
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different departments (Sections 3 and 4).
l Health physics technicians reacted appropriately to the inadvertent l
potential contamination of individuals during the special test of the
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containment spray system (Section 4.1).
-l Summary of Inspection Findings:
A second example of an anp:rer.t v;olation documented in NRC Inspection
Report 50-382/93-33 was identified (Section 2.2).
Violation 382/9332-01 was opened (Section 2.3)
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Licensee Event Report 382/92-16 was closed (Section 5.1).
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Attachment:
Persons Contacted and Exit Meeting
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I DETAILS
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f l PLANT STATUS The plant operated at full power frem the beginning of the inspection period
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turbine valve testing. On October 17, 1993, power was reduced to 98.2 percent l
to maintain the departure from nucleate boiling ratio within Technical
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Specification limits as a result of a loss of the plant. monitoring computer.
The plant was eturned to full power the same day and ran smoothly until October 28, 1993, when power was lowered to 92 percent again to allow for routine turbine valve testing.
The plant was returned to full power and
operated there untii the end of the inspection period.
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2 OPERATIONAL SAFETY VERIFICATION (71707)
The objectives of this inspection were to ensure that this facility was being
operated safely and in conformance with regulatory requirements and to ensure
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that the licensee's management controls were effectively discharging the licensee's responsibilities for continued safe operation.
2.1 Plant Tours 2.1.1 Essential Chillers Refrigerant
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On September 17, 1993, the inspectors reviewed the licensee's plans to rc-place
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the use of refrigerant R-12 after January 1, 1996 (the federally mandated cutoff date for the use of R-12). All of the plant's essential chillers
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currently utilize R-12 to be operable. The operability of the chilled water system affects all safety-related systems which rely on chilled water to
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maintain room environments. The licensee plans to modify the chillers to use
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refrigerant R-134a during the next major preventive maintenance outage
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(chillers are rebuilt every 3 years), scheduled to occur in 1995.
2.1.2 Industrial Safety On Septemaer 22, 1993, the inspectors went to the site of a medical emergency
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outside the fuel handling building rail car bay. The bay doors were open and properly posted for both radiation control and security.
The individual, who
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was working outside the posted area, was not contaminated and his injuries did not require ambulance response. The injury resulted from the individual
slipping on moss which had grown on a grating. The inspectors noted that,
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following the accident, the area was cleaned and others like it were painted
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with caution stripes to aid in preventing future accidents.
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-4-i 2.1.3 General Tours On October 4,1993, the inspectors toured all areas of the plant and noted numerous steam leaks in the turbine building.
In particular, there were large leaks from piping associated with a drain collection tank and Main Feedwater Pump Turbine A.
The inspectors noted the use of shielding and catch devices
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to contain the leakage. Discussions with licensee personnel disclosed several i
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previous attempts to stop the leaks coming from the drain collection tank
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piping. The inspectors also questioned the origin of portions of brick and
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insulation on the 40-foot elevation of the turbine building. This debris was
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located under overhead piping below the high-pressure turbine and was later i
identified to be debris left over from previous repairs to leaks in the e
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vicinity of the high-pressure turbine on the next higher elevation.
t During subsequent tours on October 12 and 13, the inspector noted that the debris had been removed and the steam leaks corrected.
2.1.4 Tour of Main Steam Isolation Valve Rooms j
On October 14, 1993, the inspectors toured the main steam isolation valve
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rooms. Housekeeping appeared to be degrading; this was due, in part, to extensive painting activity. Much of the overhead support had been painted and this required the use of extensive scaffold systems. The inspectors discussed the degraded housekeeping with the licensee and it was corrected.
The inspectors questioned whether the scaffolding affected the operability of
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the atmospheric dump valve, due to the close proximity of one of the platforms
to local control air lines. Other areas, including nitrogen valves in the j
vicinity of the nitrogen accumulator and instr:m?ntation panels for the
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feedwater isolation valves, had been shielded to prevent scaffolding from l
falling on them if it collapsed. The inspector reviewed Nuclear Operations Construction Procedure N0CP-207, Revision 5, " Erecting Scaffold," which
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required that a 1-inch clearance be left between the scaffold and adjacent
safety-related equipment.
Review of the scaffolding engineering checkli'4 ror
'e particular scaffold
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indicated that it conformed to requirements 1M s area. The inspector l
questioned the close proximity to the air lit W.i the foreman responsible
for the scaffold erection and the system engit.. for the atmospheric dump
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valves. The foreman and the engineer responsible for the original engineering-
review of the scaffold verified that the clearances were 1-inch or greater.
i The system engineer reviewed the concern and stated that the air line was not l
required for valve operation and thus, if lost, would not affect the valves
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operability.
2.2 0_perability of Valve MS-1208 l
On October 11, 1993, while performing Surveillance Procedure OP-903-094, l
Revision 7, "ESFAS Subgroup Relay Test - Operating," Main Steam Line 2 Normal
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Drain Valve MS-1208, a containment isolation valve, failed to stroke closed as
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required by the procedure. This occurrence was not logged and a Condition
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Identification (CI) was not written. On October 13, 1993, the administrative operations staff became aware of the discrepancy through discut tons with the shift technical advisor supervisor but were unsuccessful in gat ing further
data from the off-duty shift. The licensee then conservatively c lared the valve inoperable, wrote a CI and a condition report, and continueo attempts to contact the off-duty shift personnel. The motor-operated valve was evaluated using the Valve Operation Test and Evaluation System (V0TES) and no problems
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were found.
I Subsequently, the licensee determined that the valve operator motor overloads were found tripped after the initial test on October 11. An operator was i
dispatched to stroke the valve manually.
The operator indicated that the
valve felt like it was backseated. The valve was then successfully stroked
from the control room and stroked again to time the stroke, and the engineered
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safety features actuation system relay test was completed. A precursor t
trending program card was filled out to record the event.
On October 20, 1993, the inspectors interviewed operations personnel that were i
on duty during the event. These licensee personnel indicated that the
Technical Specification for containment isolation valves was not entered on October 11, 1993, because the problem with the valve was diagnosed and
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corrected immediately. They did not consider a CI necessary because there was
no longer anything wrong with the valve. This action was not in accordance
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with Site Directive W4.101, Revision 0, "Nonconformance/ Indeterminate Analysis j
Process," or Administrative Procedure UNT-005-002, Revision 10, " Condition
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Identification." Both of these documents require that a CI be written for a
nonconformance (in this case, a test failure).
In addition, Administrative
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Procedure OP-100-014, Revision-1, " Technical Specification Compliance,"
requires that the shift supervisor or control room supervisor make an
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operability determination based on the best available information at the time
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the component came into question and act in accordance with the applicable i
Technical Specification.
By this procedure, Technical Specification 3.6.3
should have been entered immediately after determining that the valve wouldn't i
stroke. This would have required that the valve be repaired or closed and deenergized within the following 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This action statement was complied i
with in that they were able to successfully complete the engineered safety i
features actuation system testing on the valve approximately 16 minutes after i
identifying the anomaly, but they failed to declare the valve inoperable or formally enter the action statement.
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~1 In addition, the inspectors determined, through discussion with licensee personnel that operations personnel had also not fully utilized the resources available to them when they failed to have on-shift maintenance personnel assist with the evaluation of the cause for the motor overload actuation or determine if there were incipient electrical problems. The failure to fully utilize all available resources was considered a poor practice.
R The inspectors considered that the failure to write a CI and thus enter the corrective actions system to assure proper resolution of the Valve MS-120B
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failure to be a second example of the apparent violation identified in NRC Inspection Report 50-382/93-33. This apparent violation involved the failure to promptly identify and correct the inoperability of the containment spray
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system as required by 10 CFR Part 50, Appendix B, Criterion XVI.
2.3 Low Level in Both Wet Cooling Tower Basins On the evening of October 19, 1993, licensee personnel contacted the inspectors after entering Technical Specification 3.0.3.
During shift turnover, the oncoming shift discovered that the hi/ low level alarms for the wet cooling towers were illuminated for low rather than high level. The water levels in the basins were approximately 92 percent instead of the Technical
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Specification minimum required level of 97 percent.
The operators immediately
secured both auxiliary component cooling water pumps to prevent further. loss
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of inventory and entered Technical Specification 3.7.4.b, which required that
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one of the ultimate heat sinks be restored to operable status within I hour.
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They then entered cascading Technical Specifications in accordance with Administrative Procedure OP-100-014, Revision 1, " Technical Specification
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Compliance." Several of those Technical Specifications did not allow both train: to be inoperable, causing them to enter Technical Specification 3.0.3.
P The operators started the condensate transfer pump to increase make-up flow to the wet cooling tower. Operators were dispatched to verify make-up flow and to complete a walkdown of the system. Calculations were completed to verify
that one train would be operable within 30 minutes of the start of the event,-
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so a plant shutdown was not required.
Discussions with the shift supervisor the following day revealed that work was
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being performed on the annunciator cabinets to isolate grounds. The i
annunciator horn for Control Panel CP-1 had gone off continuously for a period of time and several rows of lights on CP-8 (where the wet cooling tower annunciators are located) were illuminated intermittently while the search for 9 rounds took place.
The control room supervisor stated that he had last verified the level in the basins at 3 p.m. when he noted the alarms. The
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high/ low level alarms for the wet cooling tower basins were normally lit due i
to a high level condition (99 percent) when the auxiliary component cooling water system was running because the automatic makeup system kept up with the losses and maintained the levels high. The ground isolation ' activity was started at approximately 3 p.m.
An operator was specifically assigned to monitor Panel CP-1 after the audible alarm was inactivated at approximately 6 p.m.
Each time the alarm went off, whether caused by troubleshooting or an -
actual alarm, an operator had to acknowledge and reset the alarm.
Similar actions were not taken for Panel CP-8 as the audible' alarm was still functioning.
Through troubleshooting, the licensee determined that the most probable cause of the loss of automatic makeup was the loss of a loop seal in the condensate makeup line. Apparently, a low level (60 percent) in the demineralized storage tank allowed normal nitrogen overpressure from the condensate storage tank to leak back via open Valve CMU-1131 (on the condensate transfer pump
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-7-recirculation line to the condensate storage tank). The nitrogen formed a pocket at the high point of the loop seal, preventing makeup from gravity feeding to the wet cooling tower basins. Valve CMU-1131, normally locked closed, was deviated in the open position on August 17, 1993, to fill the condensate storage tank and was not closed until October 19, 1993, after it was discovered to be a possible cause for the failure of the automatic makeup system.
The licensee stated that it was not closed because filling the condensate storage tank from the demineralized water storage tank is a procedure which occurs over a period of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> nearly every day during hot weather.
The procedure used to fill the condensate storage tank, System Operation Procedure OP-003-004, Revision 6, " Condensate Makeup," required that Valve CMU-ll31 be closed after the condensate storage tank was filled.
Administrative Procedure OP-100-009, Revision 11, " Control of Valves and Breakers," required that a locked valve deviation sheet be completed each time the valve was manipulated.
The deviation sheet was filled out and filed in the deviation log on August 17, 1993. The procedure also required that the position of this valve be checked quarterly. The position of this valve had been verified on July 30, 1993, and the next check was performed on October 23, 1993.
Thus, the valve position was not programmatically detected.
Failure to follow the requirements of Procedure OP-003-004 to close Valve CMU-ll31 following the filling of the condensate storage tank was a violation of NRC regulations (VIO 9332-01).
The oncoming shift which discovered the discrepancy also noted that failure of the wet cooling tower n.akeup had occurred on previous occasions and that they believed that it had been due to leaving Valve CMU-ll31 open. -This apparent failure to have a questioning attitude and to challenge the cause of previous problems in this area suggests a. willingness to tolerate problems rather than correct them. The licensee was investigating the issue further through a condition report to determine the root cause and the corrective actions required. The licensee identified inattention to detail in failing to follow the procedure and a possible mindset in the operating crews as the preliminary root cause for this event.
A design change to disable the wet cooling tower basin high level alarm was approved by the plant operations review committee prior to the end of the report period to eliminate the constant illumination of the alarm with the auxiliary component cooling water system running. The licensee also plans to brief all operations shifts on the event, add the wet cooling tower basin level alarm to the computer log, and identify another flow path to fill the condensate storage tank.
2.4 Contaminated Nitrogen Bottle On October 22, 1993, the licensee identified-a nitrogen bottle in the services building outside of the radiologically controlled area with a fixed
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contamination of 50,000 DPM of beta-gamma.
The bottle was identified by-a health physics technician routinely performing a contamination survey on gas
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-8-I bottles scheduled to leave the protected area. A dose-rate survey of the
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affected bottle revealed 0.8 mrem /hr. The bottle was immediately marked as
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radioactive material and moved into a radiological controlled area.
l A prompt analysis showed that the level of radioactivity was due to the
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radioactive gases xenon and krypton in the bottle and not due to fixed
contamination.
They determined that the bottle had been connected to the i
waste gas analyzer panel and was located on the +15-foot level of the turbine
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building until October 22, 1993, when it was moved to the service building for
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removal off-site. Health physics and chemistry theorized that the bottle
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received the radioactive gases from the waste gas analyzer panel when it ran out of nitrogen. All of the other bottles in the turbine building were i
surveyed with negative results and a condition report was written to document
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the incident.
i 2.5 Conclusions
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The licensee reacted quickly to eliminate an industrial safety concern.
A violation was identified for failure to follow procedures. A system operating
procedure step requiring Valve CMU-ll31 to be returned to its locked-closed
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position was not adhered to for 2 months and resulted in the failure of the
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automatic makeup system for the ultimate heat sink, allowing its water level
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to decrease below the Technical Specification required level. There was also J
a failure to challenge the cause of previous probiems in this area. A second example of the apparent violation identified in NRC Inspection
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Report 50-382/93-33 was identified for the failure of a shift supervisor to
write 4 condition identification for a valve that failed to stroke as requ, red. The conservative health physics practice of surveying all material
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before it was removed from the site allowed a bottle of radioactive gas to be i
identified and prevented from leaving the site.
i 3 MONTHLY MAINTENANCE OBSERVATION (62703)
The station maintenance activities affecting safety-related systems and
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components listed below were observed and documentation reviewed to ascertain
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that the activities were conducted in accordance with approved work authorizations, procedures, Technical Specifications, and appropriate industry codes or standards.
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3.1 VOTES Testing of Valve MS-120B On October 14, 1993, the inspector observed a portion of the VOTES testing on Valve MS-120B.
The testing was performed in accordance with Testing Procedure ME-007-047, Revision 0, " VOTES Testing of MOVs," and Work i
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Authorization 01114186.
The inspectors noted that the tednicians maintained good communication with the control room. A maintenance engineer observed the j
data collected at the site and requested that the valve be stroked again to
verify that there was no problem with relay contacts. After the testing was j
complete, operations tagged the valve out again to allow the valve cover to be l
replaced and to ensure it was in the position required by the Technical
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Independent verification of the valve position following the tagging was performed correctly.
o 3.2 Conclusions Routine maintenance activities were properly performed using appropriate procedural controls. Good communications between maintenance and operations cere noted.
4 BIMONTHLY SURVEILLANCE OBSERVATION (61726)
The inspectors observed the surveillance testing of safety-related systems and components listed below to verify that the activities were being performed in accordance with the licensee's programs and the Technical Specifications.
4.1 Special Test of Containment Spray On September 27, 1993, the inspectors observed as operators completed Change 1 to Special Test Procedure STP-01113735, " Test of Containment Spray Header."
Operators were knowledgeable of the system and the procedure. The procedure provided for the venting of the containment spray header to try to remove suspected trapped air. A small amount of air was vented. The air had caused a pressure build-up in the header when the containment spray pump started sufficient to prevent System Isolation Valve CS-125A from opening. Ultrasonic testing was then performed and a pocket of air was found along the top of a 29-foot run of pipe.
The licensee reviewed and modified their special test procedure to allow greater venting with a larger flow downstream of the air pocket. This revision was reviewed and approved by the plant operations review committee.
The inspectors observed the preparations for the performance of this procedure. A tygon tube was attached to High Point Vent CS-122A and directed to a floor drain.
The inspector observed as the licensee performed the test again. They vented to the low pressure safety injection header, then proceeded to start the containment spray pump and open Vent CS-122A. The high flow caused the fitting to blow off of Vent CS-122A and the area around the vent was sprayed down with potentially contaminated water. The valve was closed immediately. Twelve personnel in the area were wetted down and potentially contaminated. The inspectors observed health physics' response in the area and at the control point. The area was immediately roped-off and posted as a contaminated area.
The potentially contaminated personnel donned shoe covers and were escorted by a health physics technician to the control point. The technicians frisked the individuals and observed good health physics practices.
Although one individual was wetted from the waist up, there were no personnel contaminations.
Several shoes and one shirt were-contaminated.
Subsequently, the tygon tubing was reconnected and the operators vented air from the piping.
This issue is further addressed in NRC Inspection Report 50-382/93-3.
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On October 28, 1993, the inspectors observed a portion of the operability.
check of the Control Room Emergency Filtration Unit B.
An auxiliary operator performed the procedure under the close observation of a licensed operator.
The check was performed in accordance with Surveillance Procedure OP-903-051, Revision 7, " Control Room Emergency Filtration Unit Operability Check." The
inspector noted good communications within the control room and with the field.
4.3 Turbine Valve Testinq On October 28, 1993, the inspectors observed a portion of the turbine valve testing performed by an auxiliary operator in reactor operator license
training under the observation of a licensed operator.
The operator was i
following S); tem Operating Procedure OP-005-007, Revision 8, " Main Turbine Generator," and Surveillance Procedure OP-903-007, Revision 6, " Turbine Inlet
Valve Cycling Test." Activity in the control room was at an expected reduced
t level with technicians standing by to collect data. The inspectors noted that the two groups worked well together.
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t 4.4 Conclusions
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Health physics technicians were found to react quickly and by procedure to the inadvertent potential contamination of individuals during the special test of I
containment spray. Routine surveillances observed were performed according to i
procedure and good communications were noted between the different departments
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5 ONSITE REVIEW OF LICENSEE EVENT REPORTS (92700)
5.1 (Closed) Licensee Event Report 382/92-016: Administrative Weakness i
Results in Valve Out of Position and Inoperable Eouipment On December 1,1992, operators determined that Nitrogen System Valve NG-627-C l
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was closed when it was required to be open. The closed valve isolated motive gas to Auxiliary Component Cooling Water Valve ACC-Il2A, preventing it from
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performing its automatic function, if called upon.
Disabling ACC-112A in turn
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made Essential Chiller A inoperable because the unit would not have been
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available without manual operator action under certain accident conditions.
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The licensee suspected that the valve position was not checked following
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maintenance on the valve between October 29 and November 5, 1992. The root
cause identified was a weakness in the mechanism by which operators ensure
components being worked on are properly aligned after maintenance is l
completed.
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The licensee's immediate corrective actions were to open Valve NG-627C and l
test Valve ACC-ll2A, verify the alignment of the nitrogen manifold isolation i
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valves on the eight nitrogen accumulators, and complete partial valve lineups on safety-related portions of the nitrogen, primary make-up water, chilled
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I water, station air, containment atmosphere release, and instrument air systems. To prevent recurrence, the event was added to the operations
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department required reading program and discussed during maintenance departmental meetings. Administrative Procedure UNT-005-003, Revision 12, j
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" Clearance Requests, Approval and Release," was changed to allow the shift supervisor or control room shift supervisor to add valves to the clearance valve lineup, as they feel necessary, and Operations Group Administrative
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Procedure OP-100-010, Revision 7, " Equipment Out of Service," was changed to i
provide additional guidance on system restoration.
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The inspectors reviewed the licensee's corrective actions and determined that the licensee satisfactorily completed the corrective actions as stated in the l
licensee event report.
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ATTACHMENT 1 PERSONS CONTACTED 1.1 Licensee Personnel
- R. E. Allen, Security and General Support Manager
- R. F. Burski, Director, Nuclear Safety T. J. Gaudet, Operational Licensing Supervisor
- J. D. Hologa, Mechanical / Civil Engineering Manager L. W. Leaghlin, Licensing Manager
- A. S. Lockhart, Quality Assurance Manager
- B. R. Loetzerich, Licensing Engineer
- D. F. Packer, General Manager, Plant Operations
- R. D. Peters, Electrical Maintenance Superintendent
- J. A. Ridgel, Radiation Protection Superintendent
- D. L. Shipman, Planning and Scheduling Manager
- D. W. Vinci, Operations Superintendent
- Denotes personnel that attended the exit meeting.
In addition to the above personnel, the inspectors contacted other personnel during this inspection period.
2 EXIT MEETING An exit meeting was conducted on November 5, 1993. During this meeting, the inspectors reviewed the scope and findings of the report. The licensee acknowledged the inspection findings documented in this report. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.