IR 05000528/1987018
| ML17303A533 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/27/1987 |
| From: | Cicotte G, North H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17303A531 | List: |
| References | |
| 50-528-87-18, 50-529-87-19, 50-530-87-20, NUDOCS 8708170199 | |
| Download: ML17303A533 (20) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-528/87-18, 50-529/87-19 and 50-530/87-20 Docket No. 50-528, 50-529 and 50-530 License No.
NPF-41, NPF-51 and NPF-65 Licensee:
Arizona Pub 1 ic Servi ce Company P.
0.
Box 21666 Phoenix, Arizona 85836 Facility Name:
Palo Verde Nuclear Generating Station - Units 1, 2 and
Inspection at:
Palo Verde Site - Mintersburg, Arizona Inspection Conducted:
May 26-29 and June 22-26, 1987 Inspectors:
Approved by H.
S. North, Senior Rad tion Specialist G.
R.
Cicotte, Radi ati on Specs a G.
P.
Yuha
, Chief Facilities Radiological Protection Section 7 sr S7 Date igned 0~!v!S~
Date Signed 7 xp Y7 Date Signed
~Summa r Ins ection durin the eriod of Ma 26-29 and June 22-26 1987 Re ort No.
50-528/87-18 50-529/87-19 and 50-530 87-20 previous inspection findings, low level radioactive waste storage facilities, Unit 1 and 2 training and qualification, Unit 1, 2 and 3 control of radioactive materials and contamination, surveys and monitoring, Unit 1 and
facilities and equipment, Unit 2 onsite followup of events at operating reactors, review of licensee reports, in office review of periodic and special reports and plant tours.
Inspection procedures 65051, 83723, 83726, 83727, 90712, 92700, 92701, 92702 and 93702 were addressed.
Results:
In the 9 areas addressed, no violations. or deviations were identitied in 8 areas.
In one area, one apparent violation of Technical Specification 6.8. 1 related to tagging control during maintenance on the PASS was identified (Report section 6).
8708l70199 870730 PDR ADOCN 05000528 Q
DETAILS 1.
Persons Contacted
- J.
R.
Bynum, Plant Manager
+ J.
M. Allen, Manager Operations
+ R.
R. Baron, Commitment Supervisor, Compliance
- D.
W. Bland, Compliance Engineer
"T.
R. Bradish, Compliance Supervisor
"L.
E.
Brown, Manager, Radiation Protection and Chemistry
"J.
B. Cederquist',
Manager, Chemical Services
+ W.
H. Doyle,-Jr., Unit 2 Radiation Protection Supervisor
+ R. Fullmer, Audits Supervisor
+ L. 0. Johnson, Senior Nuclear Safety Engineer
, "R.
G. Johnson, Unit 2, Chemistry Supervisor
- M. Lantz, Radiation Scientist, Corporate Health Physics and Chemistry
+~J.
Mann, Supervisor, Corporate Health Physics and Chemistry
+~G. Perkins, Manager, Radiological Services
+ J.
M. Sills, Senior Compliance Engineer
"L. Souza, Assistant Director, Corporate QA/QC
"0. J. Zeringue, Manager, Technical Support
+ R.
Zimmerman, NRC Resident Inspector
- Denotes individuals attending the exit interview on May 29, 1987.
+ Denotes individuals attending the exit interview on June 26, 1987.
In addition to the individuals identified above, the inspector met and held discussions with other members of the licensee's staff and contractor personnel.
2.
Licensee Action on Previous Ins ection Findin s
(Closed)
Enforcement 50-528/87-03-03 92702 The licensee's timely response to the Notice of Violation related to a shipment not meeting the requirements of 49 CFR 173.425 was reviewed.
The licensee's corrective actions were confirmed and discussed.
No deficiencies were identified.
Closed Fo1 l owu 50-528/86-08-01 92701 The licensee's
'records of E calculations required by Technical Specification (T.S.) 3.4.7 were examined.
The reactor was first made critical on May 25, 1985.
Reactor operation first satisfied the criterion identified in the footnote to T.S. Table 4.4-4 on June 12, 1986.
E calculations were performed on June 1 and 30 and December 15, 1986.
Primary coolant activities were less than 100/E.
The calculated 100/E values were 136.03, 90.43 and 121.78 microcuries/ml respectively.
The licensee was performing an E calculation at the time of the inspectio en Fo1 1 owu 50-528/86-08-03 92701 The status of the hydrogen - oxygen monitors was discussed.
Unit 1 - The licensee believed that all mechanical problems had been resolved.
Successful completion of surveillance testing would permit placing the monitor in operation in early June, 1987.
Unit 2 - Approximately 10X of the preoperational testing was incomplete.
The licensee was preparing plans to address known mechanical proble'ms.
No schedule for placing the monitor in service was provided (50-529/87-19-01).
Unit 3 - The system was being calibrated as part of the preoperational test.
Following preoperational testing the system was to be backfitted to Unit-1 configuration, e.g. addition of water collection pots.
The licensee planned to have the system in operation before the gaseous radwaste system is placed in service (50-530/87-20-01).
0 en Followu 50-528/86-28-02 92701 The licensee was expecting the factory acceptance tests of the RACCS (Radiological Access Control Computer System) to begin at CE (Combustion Engineering) shortly.
The system using a relational data base will incorporate the dosimetry records and access control data, (e. g. training and qualification status),
and provide for REP generation.
A total of 17 terminals will be provided, two per unit with printers and one with a high speed printer in dosimetry.
The NVLAP cer tified dosimetry program will continue to use the personal computer based data reduction and processing system.
The licensee will attempt to have the system operational in time for the Unit 1 refueling outage presently scheduled for September 1987.
Closed Followu 50-528/86-36-02 92701 The licensee's Laboratory Analytical Control (LAC) program was examined over an extended period by a chemistry supervisor and lead technicians from each unit.
The LAC program was requiring approximately a 20-25K increase in the number of analyses performed.
The LAC procedures were modified using the guidance provided by INPO Good Practice guidelines.
The revised LAC procedures which had been submitted for review would reduce the LAC analytical load to approximately 10-15K of the annual 60-70,000 analyses performed at an operating unit.
Based on discussions with some of the individuals involved in the LAC program changes, no concerns were'identified.
Closed Followu 50-528/87-15-01 93702 The licensee's report of this matter, Interde artmental Investi ation
PVNGS Unit 1 Contamination of the Chemistr Hot Lab Ar on S stem, was reviewed.
The facts contained in the investigation report were substantially as reported in Inspection Report 50-528/87-15 section 7.
Matters not addressed in that Inspection Report or otherwise revised by the Interde artmental Investi ation were:
1.
Delay in identifying that a spill of reactor coolant had occurred.
On returning from the accountability drill, the chemistry technician working on the PASS, reported to the chemistry lead technician, the discovery of a puddle under the argon system regulator.
The lead technician, assuming that the chemistry technician had almost completed the PASS sampling, instructed him to check the Auxiliary building roof for possible leakage from the argon relief valve.
The actual case was that the chemistry technician was required to restart the sampling procedure since the delay introduced by the accountability drill had exceeded the window for an acceptable sample.
The sampling procedure required approximately.two hours.
The lead technician did not pursue the matter either with the technician or on the Auxiliary Building roof.
The contamination was subsequently discovered by another chemistry technician.
2.
The licensee identified as a root cause,.the PASS chemistry technicians failure to fully close valve SSV-827 which isolated the argon system from the reactor coolant pressure boundary.
This was determined by a test of the valve which was found to be operable.
The licensee's report noted that a similar event had occurred on May 13, 1985, prior to contamination of the PASS.
As a result of that event a Plant Change Request (PCR) was initiated.
However, the PCR committee assigned a low priority, (plant betterment)
to the PCR and corrective action had not been completed by the date of the second event.
The licensee's report identified five concerns:
Concern 1:
Identify cause of the leak to the argon system, and correct the design.
A leak test on valve SSV-827 was completed.
A site modification was prepared to add a second isolation valve and a check valve in the argon supply line.
Concern 2:
Decontaminate the argon supply system and return to service.
A work order was written and an alternate argon supply system was to be provided until work was complete.
Concern 3:
Determine the extent of personnel contamination and extent of the release.
A release permit was prepared and whole body counts were performed.
Compliance performed a review concerning reportability pursuant to 10 CFR 20.403.
It was determined that the event was not reportable and that equipment damage was less than
$2000.
Concern 4:
The argon system modification proposed in 1985, and
Concern 5:
delayed as a plant betterment item was identified as
"safety significant" by the licensee's investigators.
The investigators proposed the possibility that other
"safety significant" modification items associated with the nuclear sampling system were also designated as plant betterment items.
Action was to be taken to review all such proposed modifications and to revise priorities as appropriate.
The review was to be completed by May 29, 1987.
The substantial delay between the discovery of a possible spill and the action taken to investigate the possible consequences of the spill and a release from the argon system relief valve.
Chemistry technicians were to be informed of the importance of prompt reporting of possible events and potential releases to the radiation protection staff.
The licensee's Interdepartmental Investigation Report was to be reviewed by the chemistry technicians during their next shift.
The licensee had attempted to decontaminate the roof area using strippable paint.
The results were only partially successful.
The residual contamination was to be fixed in place with paint.
0 en Fo 1 1 owu 50-529/01-28-87 92701)
The licensee provided information related to evaluation of auxiliary building air flow.
Contractor tracer gas testing to identify air flows was expected to begin approximately June 8, 1987.
The work was to be performed due to indications that airborne activity may be moving through drain lines not fitted with traps.
In addition the operation of five chemical fume hoods on the 140 ft. elevation, rather that the two which were considered when the ventilation system was designed, may have changed the air flow patterns.
The licensee had developed a design for a gastight insertable trap which could be used to limit gas flow through or out of the drain system.
Closed Followu 50-529/87-16-01 93702 Licensee identified release of 90,000 gallons of Unit 2 condensate to the site storm drain system addressed in guality Monitoring Report SM-87-0529.
The release was contrary to the commitment contained in sections 3.3.3 and 3.6.2 of the Environmental Report Operating License Stage.
Licensee followup addressed actions by the Environmental Licensing, ANPP Operations Administration, Nuclear Operations Outage NSSS, PVNGS Maintenance Administration and ANPP Construction staffs to prevent recurrence.
The corrective action addressed the appropriate application of procedure 7N408.01.00 Environmental Review and Evaluation to the release of liquids to the site storm drain syste en Fo1 1 owu 50-530/87-17-01 92701 Low Level Radioactive Waste Stora e Facilities 65051 The low level radioactive waste storage facility under construction was inspected.
Fence boundaries to the protected area had been modified to allow contractor access to the work site without allowing access to the protected area.
Foundations, flooring and basic service lines had been installed.
Structural steel was in place and installation of the metal side walls was essentially complete.
The progress of construction will be observed during subsequent inspections.
Closed Followu 50-528 529 and 530/87-06-CO 90712 Related to a reported potential
CFR 50. 55(e) deficiency concerning Kaman radiation monitor display cabinets and the associated possibly defective welded studs.
The licensee had implemented a program to test the studs in accordance with Kaman Specification No. N997-532-1.
In the event of stud weld failure repairs were effected in accordance with Kaman instructions using Kaman Instrument Co. Part No.
91337-001.
Closed Fol l owu (50-528 529 and 530/86-04-Pl 92700 Potential
CFR 50.55(e) reportable deficiency related to the maximum range of Kaman, high range, noble gas monitors.
The monitors affected included Condenser Vacuum System Exhaust (RU-142), Plant Vent (RU-144)
and Fuel Building (RU-146).
The licensee verified that the Unit 1 and
monitors saturated at 1.3 E4 pCi/cc.
The FSAR Table 11.5 specified range was 1E5 pCi/cc.
The cause was identified as the manufacturer's failure to supply the correct software changes when enhancement modifications were performed on the detector.
The corrective action was the replacement of appropriate EPROM's with vendor supplied replacements.
Review of work orders and gA/gC Monitoring Reports verified completion of corrective actions and testing for all Units as of May 19, 1987.
Trainin and ualifications:
General Em lo ee Trainin Radiation Safet Plant Chemistr Radwaste and Trans ortation Units 1 and
83723 Two recent events were reviewed for potential training deficiencies.
Classroom training was not applicable to either incident, though some very specific on-the-job maintenance training, outside the scope of this portion of the inspection (see Report section 6) might have mitigated or prevented the effects of one incident.
Individuals involved were well-qualified and trained in the procedures used.
Training responsibilities were clearly defined.
Though training was initially identified by the licensee as a root cause, the incidents appeared to have more programmatic problems.
Several persons were questioned on various aspects of administrative controls, industrial safety, security, emergencies, and quality assurance.
Knowledge of radiological health and safety appeared consistent with 10 CFR 19. 1 Various work activities were observed and interviews conducted with several radiation protection and chemistry technicians and non-licensed operators in radwaste and transportation.
Classroom training was provided and individuals demonstrated proficiency in the topics discussed, including radiological incidents, shipment manifests, and sampling/analysis.
gualifications of personnel in the categories inspected were in accordance with regulatory requirements and Institute of Nuclear Power Operations (INPO) guidelines.
Records were reviewed for two personnel involved in the incidents noted above, nine recently hired personnel, and
,several others from the various disciplines inspected.
All records were observed to be complete and available except that those in the process of being converted to microfiche form were not readily available.
Training and qualifications were complete for replacement personnel inspected.
A total of three chemistry technicians',
two radiation protection technicians',
four non-licensed operators in radwaste, two staff/supervisory person's and one quality assurance person's records were reviewed.
The licensee's INPO accreditation was proceeding on schedule, with a site visit by INPO scheduled for July 1987, to evaluate the remaining unaccredited disciplines.
The licensee had just completed an internal quality assurance audit
¹87-014 of all aspects of training and qualifications in May 1987 which was reviewed.
Deficiencies identified by the licensee were addressed adequately and a followup audit was scheduled by the licensee for July 1987, to assure implementation of corrective actions.
Site access, radiological work practices, and respiratory protection training had all been recently updated by the licensee and training materials were being produced to reflect these changes.
The inspector expressed concern that some aspects of industrial safety were only slightly addressed in site access training, and was informed by the licensee that such training was conducted on a departmental basis.
No violations or deviations were identified.
Control of Radioactive Materials and Contamination Surve s and Monitorin 83726 Facilit Tours During the inspection, Units 1 and 2 were in operation.
During the first portion of the inspection the Unit 3 containment was open.
Two inspectors toured Units 1 and 2 extensively, including the Unit 1 waste and boric acid evaporator rooms, laundry facilities and the respirator cleaning, maintenance and testing facility.
Also, a tour of Unit 3 containment was made on all accessible levels during the first inspection.
During the tours, surveys were performed using ion chamber survey meter NRC-015843, due for calibration on July 21, 1987.
No
significant variance between licensee survey results and NRC instrument readings was observed.
Area postings, boundaries, stepoff pads and other access controls were observed to be consistent with plant Technical Specifications and licensee procedures.
All three plants appeared to be exercising good housekeeping practices, though some stray equipment and protective clothing were observed at active wor ksites within Unit 1.
During the second inspection, some degradation in the quality of housekeeping was noted when compared with the first visit in both Units 1 and 2.
The method used to secure postings had improved.
In Unit 1, ongoing modifications of radiological controls offices and facilities were observed.
Demolition and dust-creating activities were curtained off from other areas, and actions had been taken to minimize disruption of plant activities.
The licensee had established a committee, including representatives from the Units, training, radioactive materials control, and radiological engineering, to evaluate methods for handling problems associated with radioactive particles.
Early measures included a change from all cotton to blend fabrics for protective clothing (PC) and the use of paper PCs in high radiation areas.
The committee's objective was to develop procedures related to hot particles addressing all aspects of the problem which provide the best guidance available.
The results of the committee's activities will be reviewed during subsequent inspections (50-528/87-18-01).
The licensee had completed installation of a Bauer, 5000 psi compressor for filling SCBA and nominal 282 scf, 2250 psi air bottles to be used to supply local breathing air.
The licensee reported that a Unit 1 breathing air distribution system was essentially complete requiring only receipt and installation of a compressor.
No violations or deviations were identified.
Units 1 and 2 - Facilities and E ui ment 83727 The radiation protection and chemistry laboratory areas of both facilities were toured during the inspection.
No deficiencies in the availability of laboratory, air sampling, personnel monitoring, portable and fixed (frisker) radiation protection instrumentation, protective clothing and equipment including respiratory protective equipment were identified.
Special attention was directed to verification of current calibration and performance of source checks on portable instruments, friskers and air samplers both available for use and in use.
No violations or deviations were identified.
Onsite Followu of Events at 0 eratin Reactors 93702 On Hay 21, 1987, a plant maintenance mechanic was inadvertently sprayed with reactor coolant while replacing lead shielding around the Unit 2 Post Accident Sampling System (PASS).
The event followed an extended
effort to return the PASS to operable status which began when a portion of the PASS was unable to maintain a vacuum on May 6, 1987 during performance of the Post Accident Sam lin S stem Surveillance Test (74ST-2SS04)..
The licensee conducted an extensive investigation, documented in a draft report, Unit 2 - Post Accident Sam lin S stem Leak -
Ma
1987 -
S ecial Re ort ¹87-02-008, which was reviewed.
The portion of the PASS involved in this event consisted of two sample volumes, isolable from each other by a remotely operable ball valve (HV-23).
The lower volume was designed to isolate a sample of primary coolant at full reactor coolant system (RCS) pressure and a temperature of approximately 100 F.
The upper volume, provided with a rubber septum port, for removal of a gas sample with a hypodermic syringe, was required to maintain a vacuum to receive gases evolved from the isolated, pressurized RCS sample volume.
Dissolved gases in the isolated primary coolant sample were evolved into the evacuated upper container when HV-23 was positioned to connect the two volumes.
The gas sample volume was provided with a pressure sensing device (PE-53).
Initially a chemistry technician replaced the rubber septum on the gas sample volume, several times, in an effort to correct the gas volume's inability to maintain a vacuum.
When the septum replacement failed to correct the problem, a work order to troubleshoot and repair the system was generated.
A work order was approved on May 8, 1987, following discussion between the PASS system engineer, chemistry technicians, mechanical planner/coordinator and design engineer on vacuum leak identification methods, troubleshooting techniques and repair methods.
On May 11, 1987, mechanical maintenance personnel began work on the system.
The licensee stated that since the PASS system was classified as an "R" (important to safety) rather than a "g" (safety related)
system, therefore a detailed procedure for the work was not required.
Work Order No.
00224484, described the work as,
"TROUBLESHOOT PRESSURIZED SAMPLE PORTION OF PASS SYSTEM TO FIND REASON FOR LOSS OF VACUUM.
SEE ATTACHMENT.
CONTACT MCC IF MATERIAL REQUIRED."
Instructions were general in nature and specific only in regard to replacement of the septum and contacts to be made with staff prior to the start of work.
The work order contained no instructions concerning the testing of replaced components.
With regard to PASS operability the licensee had entered a 7 day Action Statement, Technical Specification 3. 3. 3. 1, on May 4, 1987, when the PASS was declared inoperable.
On May 11, 1987, Unit 2 entered Mode 4 and exited the Action Statement, which was reentered on May 15, 1987, when the Unit entered Mode 3.
The reinstituted Action Statement would have expired at 0320 on May 22, 1987.
Between May 15 and May 21, 1987, several valves were replaced including HV-23.
The inspectors interviewed the mechanics who replaced valve HV-23.
They stated that on two days they worked with chemistry technicians in troubleshooting, valve replacement and'vacuum testing and on the third day with the system engineer.
The replacement valve for
HV-23 was supplied with an air operator.
Rather than replacing the complete valve/operator unit the installed valve was removed from the air operator and the replacement valve was installed as a subcomponent part of the previously installed valve operator.
The mechanics stated that they did not change either the position of the valve or the operator during the replacement.
They also stated that they were not familiar with the manufacturer's method of identifying valve position by markings on the valve stem.
They stated that following the event they learned of the marking method from other members of the maintenance staff.
The-removable coupling on the valve stem contained cruciform slots which mated with a single tang on the operator.
The combination permitted installation with the valve either open or closed depending on which of the cruciform slots engaged the operator tang.
The mechanics stated that as they ended their shift they questioned the valve position and expressed concern as to methods to be used to test the position of valve HV-23.
The system was subsequently vacuum tested and found to be vacuum tight.
No test was performed to assure proper positioning of the valve with respect to the operator.
While a maintenance mechanic was installing lead shielding around the PASS, the chemistry staff recommenced surveillance test 74ST-2SS04 at 1747 on May 21, 1987.
When valve V-22 was changed from the bypass position to the sample position, permitting reactor coolant at approximately 2200 psi to enter the lower sample volume, the maintenance mechanic was sprayed with reactor coolant from the ruptured septum on the upper gas sample volume.
The chemistry technician, noting a rapid pressure rise indication from pressure element PE-53, isolated the sample volumes by returning valve V-22 to the recirculate position.
Due to improper positioning of HV-23, reactor coolant was introduced into both the lower and upper sample volumes at the same time.
The initial contamination of the mechanic ranged from 3E3 to 2.5E5 dpm on the right leg and arm.
Contamination on the individual's mustache and eyebrow was 3E5 dpm and 1. 1E6 dpm on the right sideburn respectively.
Following six showers, shaving the mustache and trimming the eyebrow and sideburn the facial contamination was reduced to 2.3E4 dpm.
By 2245 on May 21, 1987, the individual had been whole body counted using lung geometry which showed the presence of 18.44 nCi of I-131 and 47.55 nCi of I-133.
The results of subsequent whole body counts and urine analysis were:
Date May 22 May 23 May 26 9.9 11. 9 2.8 MDA Whole Body Count (nCi)
I-131 I-133 2. 75 3. 93 0. 154 MDA MDA MDA Urine Analysis (nCi/1)
I-131 I-133
The initial skin exposure was estimated at 418 mrad.
The calculated thyroid dose was 78 mrad.
An exposure of 5.7 MPC-HRS as of May 28, 1987, was calculated.
The draft report 'of the licensee's investigation identified four c'oncerns:
Concerns 1 and 2, related to the delay in correcting the problems with the PASS and to whether sufficient supervisory attention and/or resources had been devoted to the work to prevent the apparently rushed effort to declare the PASS operable before exceeding the second seven day action statement.
Concern 3, related to the lack of awareness of the incompletely tested status of valves HV-2l and HV-23.
Concern 4, related to the chemistry staff's restart of the surveillance test prior to completion of the work order.
Work order number (WO¹) 00224484, which specified,
"TROUBLESHOOT PRESSURIZED SAMPLE PORTION OF PASS SYSTEM....," noted that the entry
"Clear Rqrd:" (Clearance Required)
was marked "Y", indicating, "yes".
However no clearance numbers were entered on the form.
Subsequent attachments,
"Work Performed Sheets",
were marked as indicating no clearance required.
Discussion with Tagging Office personnel established that, while a requirement for clearance was indicated by the work order the result of the system walkdown was that no tagging was required.
Based on discussions it was established that this decision was reached, apparently because the PASS was nominally assigned to I8C which normally worked on energized and pressurized systems.
It was noted however that the work covered by WO¹ 00224484 was limited to mechanical maintenance.
License procedure 40AC-9ZZ15, Rev.
1, Station Ta in and Clearance 0 eratin License),
states in part,
"3. 1 PVNGS Clearance A clearance is an official permission or approval by the Responsible Supervisor to take a component of plant equipment out of service for inspection, maintenance, repair wor k, or because a hazardous condition exists, and to make all necessary preparations so that work ma be done with safet to ersonnel and e ui ment.
A clearance is issued whenever Red Danger, Yellow Caution, or Blue Men at Work tags are required....
3.4 Red Danger Tag (Appendix D)
A red danger tag shall be placed on equipment (mechanical or electrical) which, if the equipment was operated, would endanger personnel or damage equipment."
The portion of the PASS on which work was performed was isolated from the RCS only by remotely operable valve V-22.
The switch operating V-22 was not located in the room where the work was performed.
Valve V-22 was an air operated valve.
The Station Ta in and Clearance procedure on page
I 25 makes the following statements with respect to remotely operated valves:
"NOTE Air operated valves being tagged and/or repositioned should have the air isolation valve isolated and/or tagged prior to using the manual operator.
The air operated valve should be placed in the appropriate position, if necessary, prior to removing the tag and opening the air isolation valve.
5.5.2. 16 Clearance boundaries in mechanical systems that require the valves to be closed should be provided by valves that ensure positive isolation, for example, motor operated valves, manually operated valves, and air operated valves that have a
manual hand jack.
Valves that do not provide positive isolation such as air operated valves or solenoid valves should not be used unless they can be positively blocked."
Based on the circumstances of the event and the noted excerpts from the licensee's procedures, it appears that the licensee failed to fully adhere to the intent of the procedures in that:
1.
Work was performed on a system, isolated from full RCS pressure, by a single, air operated, remotely operable valve which had not been positively blocked; and 2.
The system under repair and the remote valve (V-22) operator had not been tagged.
This is an apparent violation of the requirements of Technical Specification 6.8. 1 which requires that, "Written procedures shall be established, implemented and maintained covering the activities referenced below:
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978,...."
Regulatory Guide 1.33, Revision 2, states in Appendix A section 9.
Procedures for Performing Maintenance.
"e.
General procedures for the control of maintenance, repair, replacement, and modification work should be prepared before reactor operation is begun.
These procedures should include information on areas such as the following:
(1)
Method for obtaining permission and clearance for operation personnel work and for logging such work and (2)
Factors to be taken into account, including the necessity for minimizing radiation exposure to workmen, in preparing the detailed work procedures."
7.
Review of Licensee Re orts 90712 and 92700 Licensee records related to completed actions on Special Reports and Licensee Event Reports (LERs) examined onsite included:
Unit 1:
1-SR-85-030 1-SR-85-035 1-SR-86-087 1-SR-86-089 Unit 2:
2"SR-86-030 2-SR-86-031 2-SR-86-036 2-SR-86-037 1-SR-86-097 1"SR-87-013 1-SR-87-014 2-SR-86-039 2-SR-87"002 LER 87-009 Special Reports and LERs reviewed and closed without onsite followup included:
Unit 1:
LER 86-058 LER 87-001 LER 87-004 Unit 2:
LER 87-010 LER 87-020 1-SR-87-017 2-SR-86-032 2-SR-87-004 2-SR-87-005 2-SR-87"008 Unit 3.
2-SR-87-012 2"SR"87-018 LER-87-07 8.
3-SR-87-001 No concerns were identified.
No violations or deviations were identified.
In-Office Review of Periodic and S ecial Re orts 90713 The following timely reports were reviewed:
Annual Radiolo ical Environmental 0 eratin Re ort for 1986; (T.S.
6. 9. 1. 7) (87-04-EO);
Annual Environmental 0 eratin Re ort for 1986 (87-04-El),
Com arison Re ort of 1984 and 1985 Anal tical Results for the PVNGS Salt Monitorin Pro ram - NUS-4897 (87-04-E2);
and Annual Re ort for the PVNGS Salt De osition Monitorin Pro ram - Januar
- December 1986 -
NUS - 4999 (T.S.
Appendix B 5.4) (87-04-E3).
No onsite followup was required.
No violations or deviations were identified.
9.
Exit Interview The scope and findings of the inspection were discussed with the individuals denoted in report section 1 on May 29 and June 26, 1987.
The licensee was informed of the inspectors concerns related to the PASS maintenance event addressed in report section 6.
The licensee was initially informed that the matter would be considered as unresolved pending review in the Regional Office.
The inspector agreed to inform the licensee by telephone should the Regional office review of the matter result in enforcement action.
The licensee was informed during an onsite discussion on July 17, 1987, that a Notice of Violation was to be issued concerning this matter.
The licensee was also informed that the matter related to testing repaired or replaced component parts of systems,
"important to safety" was to be addressed in the letter to the licensee.