IR 05000397/1989022
| ML17285A652 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/21/1989 |
| From: | Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17285A651 | List: |
| References | |
| 50-397-89-22-EC, NUDOCS 8908110326 | |
| Download: ML17285A652 (7) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION REGION V
Report No.:
Docket No.:
License No.:
Licensee:
50-397/89-22 50-397 NPF-21 Washington Public Power Supply System P. 0.
Box 968 Richland, Washington 99352 Facility Name:
Washington Nuclear Project No.
2 (WNP-2)
Meeting Location:
Region V Office, Walnut Creek, California Meeting Date:
June 28, 1989 Prepared by:
W. J.
Wagner, Reactor Inspector Approved by:
P.
H o nson, hse Rea r Projects Section
v(~ /p ate
>gne Meetin on June 28, 1989 Re ort No. 50-397/89-22 An enforcement conference was held to discuss potential enforcement issues related to environmental qualification of electrical equipment and the commercial grade procurement process.
Concerns regarding shutdown cooling isolations and other current issues were discussed following the enforcement conference.
89081 2 032h 890721 PDR ADQCK 05000397 G
PNU
DETAILS 1.
Meetin Partici ants Licensee Attendees A. L. Oxsen, Assistant Managing Director Operations G.
D. Bouchey, Director, Licensing and Assurance J.
P. Burn, Director of Engineering L. J. Garvin, Manager, Programs and Audits
'. L. McKay, WNP-2 Operations Manager G. C. Sorensen, Manager, Regulatory Programs R. L. Koenigs, WNP-2 Technical Manager J.
E. Rhoads, Manager, Equipment Engineering C.
R. Noyes, Manager, Engineering Systems Support K. R. Wise, Supervisor of Engineering S.
H. Peck, Plant Technical Supervisor Nuclear Re ulator Commission J.
B. Martin, Regional Administrator B. H. Faulkenberry, Deputy Regional Administrator R. P.
Zimmerman, Acting Director, Division Reactor Safety and Projects A. E. Chaffee, Deputy Director, Division Reactor Safety and Projects H. J.
Wong, Deputy Director, Office of Enforcement A. D. Johnson, Enforcement Officer M. B. Blume, Regional Attorney D. F. Kirsch, Chief, Reactor Safety Branch R. J.
Pate, Chief, Nuclear Materials Safety and Safeguards Branch P.
H. Johnson, Chief, Reactor Projects Section
U. Potapovs, Section Chief, Vendor Inspection Branch C. J. Bosted, Senior Resident Inspector R. C. Wilson, Senior Reactor Engineer, Vendor Inspection Branch W. J.
Wagner, Reactor Inspector D. M. Kunihiro, State Liaison Officer T. R. Meadows, Licensing Examiner Bonneville Power Administration D. L. Williams, Nuclear Engineer 2.
Enforcement Conference Mr. Faulkenberry opened the enforcement conference by explaining the purpose of the conference and briefly discussing the agenda for the meeting.
The scope of the enforcement conference was stated to include two issue's:
environmental qualification of Limitorque motor operators and commercial grade procurement and dedication of safety-related equipmen a.
Environmental Oualification Issue Mr. Wilson provided an overview of NRC inspection activities and technical issues regarding environmental qualification of Limitorque motor operators, with emphasis on T-drains, splices, the licensee's timeliness in performing inspections, and the number of Limitorque operators located in containment and in the steam tunnel.
The licensee indicated that they were not prepared to discuss splices during this meeting.
Mr. Oxsen began the Supply System's presentation by reviewing the licensee's planned agenda.
Specific issues were discussed with various members of the Supply System staff.
The licensee's position regarding the environmental qualification (Eg) of the Limitorque motor operators and the supportive facts considered to be significant in this issue were:
1.
Discrepancies were the result of a configuration/design control oversight - not a flawed EO program.
2.
Documents and instructions in existence at the time should have prevented the deficiencies.
3.
The deficiencies were self-identified.
4.
During subsequent audit, information reflected qualifiability and operability - i.e., the issues were not safety significant.
5.
Additional information requested by the staff confirmed opera bi 1 ity.
6.
Accordingly, escalated enforcement is not warranted.
The licensee presented a viewgraph illustrating a chronological
"WNP-2 Limitorque Timeline," or history of events from the initial licensee concern (January 16, 1982) through the recent request for expanded technical analysis of qualification basis for motor operators without T-drains.
The licensee stated that during the 1982 walkdowns it was difficult to get configuration information, therefore T-drain installation was not examined.
Licensee representatives stated that when the NRC issued IE Notice 83-72 in October 1983, they believed that the configuration of the Limitorque motor operators was satisfactory based on the 1982 walkdown, so another walkdown was not necessary.
However, in October 1985, the licensee internally committed to do another walkdown to add further assurance of configuration details; this walkdown was performed during 1985-1986.
Mr. Potapovs stated that the installation gC inspections did not address all the items required to be covered for the qualification package, such as T-drains.
The licensee responded by saying that these were new items and that inspections were not performed to a
level of detail that addressed T-drain Mr. Kirsch asked why, when the T-drains were received in bags with instructions, was it not flagged that these T-drains should be installed and verified so.
That is, did the work traveler have T-drain installation instructions specified?
The licensee responded that they felt comfortable all this work (like T-drain installation)
was done, and therefore did not see a
need to verify during OC walkdowns that they were installed.
Mr. Hong pointed out that Eg is required to provide assurance that the installed equipment is what is required to be there.
He also.
noted that the licensee was aware of the T-drain concerns prior to startup and could have performed a walkdown with the checklist in effect at the time.
That is, it was not necessary to wait for development of a new checklist, which took approximately 1 to 1$
years.
Mr. Faulkenberry asked if the motor operators were qualified as of today.
The licensee responded that those in containment are, because the T-drains are installed, but that they were not sure about the operators in the steam tunnel.
During this conference, Mr. Rhoads confirmed by telephoning the plant that the motor operators in the steam tunnel have T-drains installed, according to documentation on file for the 1986 walkdown.
The licensee acknowledged that the T-drains were not installed on the eight operators inside containment until the first refueling outage.
Licensee representatives suomarized the Supply System's position by stating that the Limitorque operators are environmentally qualified
'ither with or without the T-drains installed.
Further, the issue is a minor configuration deficiency versus a qualification documentation deficiency.
Therefore, escalated enforcement is not appropriate.
However, the licensee stated that, if escalated enforcement action is taken, full mitigation of the base civil penalty is warranted because:
1.
The Supply System identified the deficiencies and reported them to the NRC staff.
2.
The licensee made best efforts, gave early directions, and had a well staffed EO internal program.
3.
Prompt corrective actions were taken.
4.
The issue was fully resolved shortly after the deadline.
5.
The issue involved a limited number of components.
Mr. Potapovs stated that the licensee had still not provided sufficient basis to support the conclusion that the Limitorque operators were qualifiable without the T-drains installed.
Also,
whether it is a minor configuration deficiency is not the issue; the issue is whether an apparent violation of 10 CFR 50.49 is involved.
He further pointed out that the plant did operate for 104 days in an unqualified status.
b.
Commercial Grade Procurement Mr. Kirsch opened the discussion on commercial grade procurement by expressing concerns regarding the dedication process.
In question was the dedication of 10 items, 5 of which are installed in the plant, whose critical characteristics necessary for proper dedication did not appear to have been fully identified or verified by testing or inspection.
Specific examples were provided by Mr.
Kirsch, and were discussed in NRC Inspection Report 50-397/89-21.
Mr. Oxsen stated in his introduction to the procurement issue that the Supply System staff was going to discuss changes to improve the procurement program, especially the dedication process.
He concluded by stating that there are no hardware safety issues.
He agreed that documentation of the Supply System's evaluations and dedications could have been stronger, but stated that a violation of NRC requirements was not believed to have occurred.
The licensee's discussion then covered the following topics, presented with the aid of viewgraphs:
procurement document review, vendor qualification/audits, vendor inspection, receipt inspection, and future actions to upgrade the procurement program.
Mr. Faulkenberry asked if the engineers performing the dedication process were qualified to identify the critical characteristics; the licensee responded that they were.
In regards to the ten items addressed in NRC Inspection Report 50-397/89-21, the licensee said that Potter-Brumfield had not been audited, but since they have no history of problems, they have confidence that this vendor will supply a quality product.
The licensee also pointed out that the spare pump shaft for the residual heat removal (RHR)
pump was procured from Ingersoll-Rand, not Baxter Air Engineering.
Ingersoll-Rand is on the approved vendors'ist for purchasing safety-related items.
Mr. Potapovs asked if the audit of Ingersoll-Rand which qualified them to supply safety-related items also qualified them to supply commercial grade items, such as the pump shaft, for a safety-related application.
The licensee indicated that they did not know at that time.
The licensee indicated that additional audits are being performed on previous commercial grade procured items to determine whether today's requirements for identifying critical characteristics are being met.
The enforcement conference concluded with the licensee agreeing to reevaluate the 10 items identified by the NRC, based on their current
program, to determine whether they are suitable for safety-related application.
The licensee stated that this could be completed in 30 to 45 days.
3.
Mana ement Discussion Following completion of the enforcement conference, shutdown cooling isolations and other issues of recent NRC interest were discussed.
Mr. Faulkenberry opened this portion of the meeting by noting that a
total of 11 shutdown coo'ling (SDC) isolations had occurred during the 1989 refueling outage.
Mr. Johnson noted that this compared with 4 and
isolations during the 1987 and 1988 refueling outages, respectively.
Mr.
Zimmerman recognized that the SDC isolations were individually of minimal safety significance, but clearly indicated a need for improved control of plant activities.
Mr. Oxsen responded that the Supply System was very disappointed with the series of isolations after a good operating record during the past year, including only one reactor scram.
He noted that the previous cycle had also included five forced outages, although the associated plant shutdowns and restarts were executed smoothly.
In further discussion of the events, licensee representatives made the following additional points:
SDC isolations early in the refueling outage included three which involved personnel performance.
These were addressed by aggressive management, and a smooth period followed.
- The three events which occurred on June 17 - 18, including two SDC isolations and a high pressure core spray (HPCS) actuation, were of significant additional concern to management, in that they all involved poor procedure controls and/or personnel performance.
In response to these events, the licensee initiated actions as follows:
Experiences of other domestic boiling water reactors were evaluated, with the conclusion that others nominally encoun-tered fewer SDC isolations.
Discussions were held to increase the sensitivity of the plant staff to the concern.
- Root cause assessments were being performed for each individual event (including the
SDC isolations and the HPCS actuation),
and a collective assessment was being performed to assess the significance of the events as a whole.
Mr. Martin questioned whether the Generation Engineering organization felt a sense of ownership for the SDC isolations, stating that the issue appeared to need more engineering involvement.
Supply System represen-tatives responded that Generation Engineering was actively involved in day-to-day plant activities, including representation at the daily morning meeting and problem review meeting.
Mr. McKay stated that of the
12 issues (ll SOC isolations and one HPCS actuation),
about a third involved hardware, 30% involved personnel performance, and about 25K involved procedure problems.
He added that an extra control room super-visor (CRS, a licensee senior operator)
had been placed in the control room to coordinate work activity.
Mr. Johnson questioned the licensee's intentions with regard to the inclusion of instrument valve numbers in the excess flow check valve surveillance procedure, which was governing the activities in progress on June 17 - 18 when the last three actuations occurred.
Supply System management committed to revise the procedure to include valve numbers before it is used for the 1990 refueling outage.
(Followup Item 89-22-01)
The licensee's reporting of events to the NRC, as required by 10 CFR 50.72 and 50.73, was briefly discussed.
NRC representatives noted that five violations involving these requirements had occurred during the past year.
Supply System representatives acknowledged the concern, and stated that additional assistance on assessment of potentially reportable events was being provided by the compliance organization.
The final topic discussed was the scheduling of surveillance tests.
This was prompted by the licensee's discovery after plant startup from the refueling outage that a 5-year surveillance test of the containment spray headers would be overdue in December 1989.
This test was scheduled for performance during the refueling outage but was inadvertently missed.
The licensee responded that the surveillance scheduling program normally works effectively, but that this test had not been performed since initial plant startup, and had been omitted from the restart schedule as a result of personnel error.
They stated that surveillance requirements and the scheduling system were being reviewed to ensure that all required tests are included in the program.