ML14191B028
| ML14191B028 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/09/1988 |
| From: | Garner L, Latta R, Starkey R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14191B024 | List: |
| References | |
| 50-261-88-28, NUDOCS 8811280096 | |
| Download: ML14191B028 (17) | |
See also: IR 05000261/1988028
Text
. '
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION il
101 MARIETTA ST., N.W.
ATLANTA, GEORGIA 30323
Report No.:
50-261/88-28
Licensee:
Carolina- Power and Light Company
P. 0. Box 1551
Raleigh, NC 27602
Docket No.:
50-261
License No.: DPR-23
Facility Name: H. B. Robinson
Inspection Conducted: September 11 -
October 10, 1988
Inspectors:
L. W. Garner, Senior
dent Inspector
DaTe Signed
R. M. Lata, Res1 en
spector
Date Signed
R. D. Starkey, R actor Inspector
Uste Signed
C. .
ass~e
,Radiation
Spefialis t
att bigned
Approved by:
P. E Fredrickson, Chief, Section 1A
Date'SigneT
Division of Reactor Projects
SUMMARY
Scope:
This routine, announced inspection was conducted in the areas of
followup on previous inspection items, operational safety verifica
tion, physical protection, surveillance observation, maintenance
observation, onsite followup of events at operating power reactors,
onsite review committee, solid radioactive waste, and transportation.
Results:
Three violations were identified:
Failure to Have a Program To Use
Calibrated Stop Watches For Required TS and ASME Section XI Testing,
Paragraph 6; Failure to Correct Sump Pump Controls Which Resulted in
Radioactive Releases to the Storm Drain System, Paragraph 10; and
Failure to Indicate Proper Physical Form of Material on Shipping
Papers, Paragraph 11.
8811280096 881110
0
ADOCK 05000261
PNU
REPORT DETAILS
1. Licensee Employees Contacted
R. Barnett, Maintenance Supervisor, Electrical
- D. Baur, Supervisor, Quality Assurance
- J. Benjamin, Unit Head, Systems Engineering
C. Bethea, Manager Training
H. Bryon, Instructor
R. Chambers, Engineering Supervisor, Performance
- S. Clark, Project Engineer, Design Engineering
D. Crocker, Supervisor, Radiation Control
- J. Curley, Director, Regulatory Compliance
- C. Dietz, Manager, Robinson Nuclear Project Department
J. Eaddy, Supervisor, Environmental and Chemistry
R. Femal, Shift Foreman, Operations
W. Flanagan, Manager, Design Engineering
W. Gainey, Support Supervisor, Operations
- S. Griggs, Aide, Regulatory Compliance
P. Harding, Project Specialist, Radiation Control
- E. Harris, Director, Onsite Nuclear Safety
- M. Heath, Project Engineer, Technical Support
R. Johnson, Manager, Control and Administration
D. Knight, Shift Foreman, Operations
E. Lee, Shift Foreman, Operations
D. McCaskill, Shift Foreman, Operations
R. Miller, Maintenance Supervisor, Mechanical
R. Moore, Shift Foreman, Operations
- R. Morgan, Plant General Manager
D. Myers, Shift Foreman, Operations
D. Nelson, Operating Supervisor, Operations
- M. Page, Engineering Supervisor,.Plant Systems
- D. Quick, Manager, Maintenance
- D. Sayre, Acting Director, Regulatory Compliance
D. Seagle, Shift Foreman, Operations
J. Sheppard, Manager, Operations
R. Steele, Shift Foreman, Operations
- H. Young, Director, Quality Assurance/Quality Control
Other licensee employees contacted included technicians, operators,
mechanics, security force members, and office personnel.
NRC Resident Inspectors
- L. Garner
- R. Latta
- Attended exit interview on October 19, 1988.
- Attended exit interview on October 26, 1988.
2
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2. Licensee Action on Previous .Enforcement Matters (92702)
This area was not inspected.
3. Licensee Action on Previously Identified Inspection Items (92701)
(Closed) IFI 261/08-01, Implementation of the LER Writer's Guide.
During
a previous inspection, the licensee committed that a LER Writer's Guide,
with particular attention paid to corrective actions to prevent recur
rence, would be completed and implemented.
That Writer's Guide entitled
LER Handbook, was completed and implemented on June 15, 1988.
This item
is considered closed.
(Closed)
IFI 261/88-08-03, Track Commitments Made to the NRC in LERs
Through the RAIL Commitment Tracking System.
Examples were identified of
corrective action commitments made in LERs to the NRC, but which were not
tracked in the licensee's RAIL commitment tracking system. A review of
all LERs issued since that time indicated that all corrective action
commitments to the NRC as described in LERs have been entered into the
RAIL commitment tracking system. This item is considered closed.
No violations or deviations were identified within the areas inspected.
4. Operational Safety Verification (71707)
The inspectors observed licensee activities to confirm that the facility
was being operated safely and in conformance with regulatory requirements,
and that the licensee management control system was effectively dis
charging its responsibilities for continued safe operation.
These
activities were confirmed by direct observations, tours of the facility,
interviews and discussions with licensee management
and personnel,
independent verifications of safety system status and limiting conditions
for operation, and reviews of facility records.
Periodically, the inspectors reviewed shift logs, operations records, data
sheets, instrument traces, and records of equipment malfunctions to verify
operability of safety related equipment and compliance with TS.
Specific
items reviewed include control room logs, maintenance work requests,
auxiliary logs, operating orders, standing orders, and equipment tagout
records. Through periodic observations of work in progress and discus
sions with operations staff members,
the inspectors verified that the
staff was knowledgeable of plant conditions; responding properly to alarm
conditions; adhering to procedures and applicable administrative controls;
and aware of equipment out of service, surveillance testing, and mainte
nance activities in progress.
The inspectors routinely observed shift
3
changes to verify that continuity of system status was maintained and that
proper control room-staffing existed.
The inspectors also observed that
access to the control room was controlled and operations personnel were
carrying out their assigned duties in an attentive and professional
manner. The control room was observed to be free of unnecessary distrac
tions. The inspectors performed channel checks, reviewed component status
and safety related parameters,
including SPDS information, to verify
conformance with the TS.
During .this reporting interval, the inspectors verified compliance with
selected LCOs.
This verification was accomplished by direct observation
of monitoring instrumentation, valve positions, switch positions, and
review of completed logs and records.
The inspectors verified the axial
flux difference was within the values required by the TS.
Plant tours were routinely conducted to verify the operability of standby
equipment; assess the general condition of plant equipment; and verify
that radiological controls, fire protection controls and equipment tag out
procedures were being properly implemented.
These tours verified the
absence of unusual fluid leaks; the lack of visual degradation of pipe,
conduit and seismic supports; the proper positions and indications of
important valves and circuit breakers; the lack of conditions which could
invalidate EQ; the operability of safety related instrumentation; the.
calibration of safety related and control instrumentation including area
radiation monitors, friskers and portal monitors; the operability of fire
suppression and fire fighting equipment; and the operability of emergency
lighting equipment. The inspectors also verified that housekeeping was
adequate and areas were free of unnecessary fire hazards and combustible
materials.
a. CV Temperature Distribution (TI 2515/98)
The inspectors reviewed the results of SP-797, Special Procedure For
Monitoring CV Temperature.
This procedure measured temperatures
at different elevations adjacent to EQ equipment installed inside
containment. Temperatures were taken on all three major operating.
levels (e.g., first level, second level, and operating deck, as well
as in the seal table room,
PZR cubicle and CV sump entrance).
The
temperatures taken were compared to the average CV temperature as
indicated on the RTGB.
Data was taken weekly from March 10 to
August 31,
1988,
while the reactor was operating.
Preliminary
engineering review has revealed that the PZR cubicle routinely
operates above the 120 degrees F maximum operating temperature
assumed in the EQ program.
EQ components in the PZR cubicle are
ASCO solenoid valves, NAMCO limit switches, conduit seals and valve
position indication accelerometers.
These components are all
associated with the PZR PORV equipment.
An analysis was performed
which demonstrated that these components had not exceeded their
4
lifetime rating at the higher temperatures. The licensee is in the
process of factoring this higher PZR cubicle temperature into their
EQ program. Analysis of approximately four months'of data, March 3
through June 29, 1988, showed the following:
AREA
>120F
.<110F
FIRST LEVEL
1 WK
10 WKS
SECOND LEVEL
4 WKS
11 WKS
OPS DECK
4 WKS
10 WKS
SEAL TABLE
1 WK
11 WKS
SUMP ENTRANCE
3 WKS
10 WKS
CV AVERAGE
5 WKS
6 WKS
It is indeterminate at this time if the above data is representative
of the percent of time temperatures may be in excess of 120 degrees
F.
For example, reactor power was limited to 60% of full power from
February to June 20,
1988.
In addition, some data was taken during
or immediately following CV purges. A review of average CV tempera
ture during the hottest months, after June 30 to September 30, 1987,
indicated that the average temperature had exceeded 120 degrees F for
every week except one week which was associated with a shutdown. The
need to provide a more representative data base than presented by
SP-797 in order to establish EQ equipment lifetimes inside contain
ment was discussed with plant management.
This is an IFI:
Estab
lishment of EQ Lifetimes Inside CV Based Upon Actual Temperature
Conditions (261/88-28-01).
No violations or deviations were identified within the areas inspected.
5. Physical Protection (71707)
In the course of the monthly activities, the inspectors included a review
of the licensee's physical security program. The inspectors verified by
general observation, perimeter walkdowns and interviews that measures
taken to assure the physical protection of the facility met current
requirements.
The performance of various shifts of the security force was observed
to verify that daily activities were conducted in accordance with the
requirements of the security plan.
Activities inspected included
protected and vital areas,
access controls, searching of personnel,
packages and vehicles, badge issuance and retrieval, patrols, escorting
of visitors, and compensatory measures.
In addition, the inspectors
routinely observed protected and vital area lighting and barrier
integrity.
5
No violations or deviations were identified within the areas inspected.
6. Monthly Surveillance Observation (61726)
The inspectors observed certain surveillance related activities of safety
related systems and components to ascertain that these activities were
conducted in accordance with license requirements.
For the surveillance
test procedures listed below, the inspectors determined that precautions
and LCOs were met, the tests were completed at the required frequency, the
tests conformed to TS requirements, the required administrative approvals
and tagouts were obtained prior to initiating the tests, the testing was
accomplished by qualified personnel in accordance with an approved test
procedure, and the required test instrumentation was properly calibrated.
Upon completion of the testing, the inspectors observed that the recorded
test data was accurate, complete, met TS requirements, and test discrep
ancies were properly rectified.
The inspectors independently verified
that the systems were properly returned to service.
Specifically, the
inspectors witnessed/reviewed portions of the following test activities:
a.
OST-202 (revision
13),
Steam Driven Auxiliary Feedwater System
Component Test.
During the performance of this surveillance, the
acceptance criteria for pump horizontal vibration was exceeded,
causing the pump to be declared inoperable and a 7 day LCO to be
entered. A work request was written and an engineering evaluation
was initiated to determine the cause of the vibration.
The inspector observed that during the stroke timing of SDAFW Pump
Temperature Control Valve SW-TCV-1902A that the operators conducting
the surveillance used an uhcalibrated watch to stroke time the valve.
Upon further inquiry the inspector discovered that the licensee does
not use, nor have available for use, calibrated stop watches for the
purpose of timing equipment which has safety significance.
Failure
to assure that measuring and testing devices affecting quality,
specifically stop watches, are properly controlled and calibrated
is identified as a violation:
Failure To Have A Program To Use
Calibrated Stop Watches For Required TS and ASME Section Testing
(261/88-28-02).
b.
PLP-006 (revision 6), Containment Vessel Inspection/Closeout. The
inspectors observed completion of PLP-006 attachment 6.3, Auxiliary
Operator Weekly Checks, on September 21, 1988. This procedure had
been modified to incorporate performance measurements of HVH 4 as
described in paragraph 8.b.
One violation was identified within the areas inspected.
7. Monthly Maintenance Observation (62703)
The inspectors observed several maintenance related activities of safety
related systems and components to ascertain that these activities were
6
conducted in accordance with approved procedures,
TS and appropriate
industry codes and standards.
The- inspectors determined that these
activities were -not violating LCOs and that redundant components were
The inspectors also determined that activities were accom
plished by qualified personnel using approved procedures, QC hold points
were established where required, required administrative approvals and
tagouts were obtained prior to work initiation, proper radiological
controls were adhered to, appropriate ignition and fire prevention
controls were implemented,
replacement parts and materials used were
properly certified and the effected equipment was properly tested before
being returned to service.
In particular, the inspectors observed/
reviewed the following maintenance activities:
WR/JO 88-AEUJI Inspection and Cleaning of HVH 1-4 Units
'0
WR/JO 88-AIQW1 Repair CV Purge Exhaust Valve V12-9
o
WR/JO 88-AJYG1 Repair CV Purge Exhaust Valve V12-8
WR/JO 88-BEF535 Inspection of HVH 1-4 and Motor Coolers per CM-201
No violations or deviations were identified within the areas inspected.
8. Onsite Followup of Events at Operating Power Reactors (93702)
a. Rx Head Vent Valves Not in EQ Program
On September 14, 1988, with Unit 2 in cold shutdown, the inspectors
were advised of a reportable event involving the licensee's determi
nation that the reactor head vent valves were not environmentally
qualified. Subsequent to this determination the subject valves and
their associated containment penetration splices were repaired, EQ
packages were developed, and the system was returned to service on
September 16, 1988.
The determination that the reactor head vent system, which utilized
Target Rock solenoid operated valves, were not qualified was made
following a notification to the site on September 9, 1988, that
similar valves utilized at the Shearon Harris site were found to
have degraded reed switch wires and unidentified terminal blocks
installed. An evaluation of the reactor head vent valves at Robinson
indicated that although the RCS and reactor vessel head vent system
had been installed in 1984 as a seismically qualified and EQ system,
they had been omitted from the licensee's EQ file inventory.
The
failure to have vent valves in the EQ Program is an UNR:
Failure to
Have Rx Head Vents Environmentally Qualified (261/88-28-03).
The inspectors witnessed portions of the valve disassembly and repair
efforts conducted in accordance with WR/JO 88-AJRY1 and determined
that the manufacturer had provided reed switches and terminal blocks
.7
of a different configuration than had been originally qualified and
certified by Target Rock. These components along with the internal
jumper wiring were replaced with qualified materials. Additionally,
Patel conduit seals not specified in the original installation were
installed and the penetration splices originally configured as butt
splices with Ray-Chem sleeves were replaced with qualified penetra
tion splices.
b. Containment Fan Cooler Biological Fouling
As described in Inspection Report 261/88-23, the licensee took the
unit to cold shutdown because of reduced heat removal capability of
containment fan coolers HVH 3 and 4.
The licensee's inspection of
HVH Units 1, 2, 3 and 4 and subsequent determination of fouling and
pitting due to biological growth are the subject of Inspection Report
261/88-27. This writeup provides an update on inspection activities
associated with restart on September 19, 1988.
The licensee performed cleaning of HVH 1, 2, 3 and 4 to remove
the fouling.
In addition, an inspection was conducted of other
potentially susceptible safety related heat exchanges.
No other
degraded conditions were found.
The inspectors examined the tube
bundles of selected heat exchangers, including at least one of each
pair of ESF pump room coolers (e.g. , SI pump room,
RHR pump room and
MDAFW pump room coolers), as well as the containment fan coolers. No
adverse conditions which would render the subject coolers inoperable
were observed.
As described in Inspection Report 261/88-27, a hydrostatic test was
performed on the containment coolers and associated service water
piping. This hydrostatic test provides confidence that the pitting
observed in the HVH units had not progressed to through-wall leaks.
The licensee is in the process of contracting with Westinghouse to
perform eddy current testing of 12% of the tubes in HVH 4. during the
refueling outage which is scheduled to begin November 12, 1988.
In
addition, the licensee, is planning to visually inspect the contain
ment fan coolers for indication of resumption of biological growth
during the refueling outage.
These items are considered an IFI:
Review Visual and Eddy Current Testing of HVH 1-4 During November
1988 Refueling Outage (261/88-28-04).
Between resumption of power operation on September 19,
and the
refueling outage, the licensee has initiated temporary monitoring
of the performance of HVH 4 by trending differential service water
pressure across the unit, service water discharge pressure from the
unit and inlet and outlet air temperatures.
The inspectors observed
the taking of baseline data and has reviewed subsequent data.
To
date, adverse trends have been observed. However, the inspectors are
.8
concerned that these methods will not provide early detection of
biological fouling prior to significant fouling occurring. This has
been expressed to the licensee. The licensee had already been in the
process of evaluating options to provide some means of detecting
the onset of biological fouling in the coolers.
This is an IFI:
Licensee to Develop Methodology to Detect Biological Growth in HVH
1-4 (261/88-28-05).
c. Shutdown and Unusual Event Due To Loss of Containment Integrity
On September 22,
1988, the licensee determined that a leakage path
existed from containment via the 42" diameter series purge exhaust
valves V12-8 and V12-9.
Because- the leak path could not be isolated
within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the initial discovery, an unusual event was
declared in accordance with the licensee's emergency plan.
In
accordance with TS 3.0 the reactor was placed in hot shutdown for.
repairs of the subject valves. The sequence of events and subsequent
repair activities are described below.
On September 19,
1988, at 4:50 a.m.,
the Unit was taken critical
after the HVH 1-4 outage described in paragraph 8.b above.
During
this forced outage, the CV purge exhaust inboard and outboard valves,
V12-8 and V12-9 respectively, had been opened for CV cooling and
routing of power cables to support CV work.
Prior to startup the
valves had been closed to establish containment integrity.
However,
on the afternoon of September 19,
these valves were reopened, as
allowed by TS 3.6.4.1, to support a routine CV entry on September 21.
Due to the relatively long period of time required to pressurize this
large penetration, PPS, which is used to maintain a pressure greater
than accident pressure on select penetrations during operation, was
not placed in service for this penetration during this time. It was
only after the CV entry on September 21 was completed that the CV
purge exhaust penetration was pressurized.
After approximately
eight hours, the time allowed by procedure to fully pressurize the
the RTGB instrumentation indicated a high PPS header
flow rate. With the reactor at 89% power, at 3:20 a.m., the licensee,
observed that V12-8 was leaking. A CV entry subsequently determined
that V12-9 was also leaking.
Attempts to stop the leakage were
unsuccessful.
Consequently, at 7:21 a.m.,
an unusual event was
declared in accordance with PEP-101, item 6, which requires declara
tion of an unusual event if
one or more automatic CV isolation
valve(s)
is (are)
inoperable for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and not isolated or
repaired.
Because repair of the valves required the valves to be
fully opened,
the licensee elected to work one valve at a time,
thereby minimizing the leak path out of containment as much as
possible while the reactor was above 200 degrees F. At 9:08 a.m., a
post repair test on V12-9 proved unsuccessful.
Consequently, at
9:52 a.m., the licensee began reducing load to remove the unit from
9
service in accordance with TS 3.0.
At 11:54 a.m., the Unit was in
hot shutdown.
The V12-8 butterfly type valve was subsequently
repaired by replacing the seal and was successfully tested at 9:45
p.m. The conditions to exit the unusual event were met at that time
and the unusual event was terminated. By 1:50 p.m., on September 23,
the V12-9 valve was repaired, tested and returned to service.
The
reactor was taken critical at 4:10 a.m., on September 24.
Preliminary investigation by the licensee indicated that hard foreign
material had been embedded in the soft sealing surfaces of each
valve. In addition, the leakage by V12-9 may have been compounded by
a partial separation of the sealing material from its backing ring.
The licensee plans to document their final determinations, root
causes, and corrective actions in LER 88-022. The NRC review of this
LER and the circumstances surrounding the failure to ensure that
these valves would tightly close after being used as a service route
for cables is considered an UNR:
Review LER 88-022 and CV Oper
ability Requirements After Opening of CV Purge Exhaust Valves
(261/88-28-06).
d. Motor Driven Feedpump A Trip
On September 27,
1988, .while at -88% power, the A motor driven.
feedwater pump tripped on low oil pressure.
Reactor power was
stabilized at 47% power in accordance with abnormal operating
procedures by manually reducing turbine load and placing control rods
in automatic control.
Fourteen minutes prior to the trip, the
auxiliary oil pump had begun to cycle on and off every 2-3 seconds.
Subsequent investigation indicated that the oil system relief valve
was partially open due to trash under its seat and an oil pressure
switch was malfunctioning.
The repairs were completed and power
ascension commenced at 4:45 a.m., on September 29, 1988.
e. Dedicated Shutdown RCS Th and Tc Instruments Routed Through Fire Area
Review of plant modification M-896 revealed that RCS Th and Tc
circuits, TE-410 and TE-413 loops respectively, had been routed
through Appendix R Fire Area A. These instruments are used per
DSP-002,
Hot Shutdown Using The Dedicated/Alternate Shutdown System,
to stabilize the plant in hot shutdown via natural circulation if a
fire occurs in Fire Area A. Per modification M-445, these circuits
had been routed outside of the fire area.
However, modification
M-896, which isolated these instrument loops from class IE equipment
per R.G. 1.97, resulted in the circuits being rerouted back into Fire
Area A.
On October 5, 1988,
the licensee issued engineering evaluation 88-128, JCO 88-008, to address this issue.
In summary, the licensee
concluded that the likelihood of cable damage sufficient to disable
10
these ,instrument loops is extremely low because of the low combus
tible loading and the automatic capability to rapidly detect and
suppress fires which may occur in the area.
Furthermore, if these
loops are disabled by a fire, an indirect means of obtaining RCS
temperature is available from a S/G Pressure - RCS Temperature graph.
The inspectors verified that the applicable DSPs contain this
graph, that operating personnel are aware of how to utilize it (if
necessary), and that the appropriate S/G pressure instruments are in
service and are operable.
The licensee is planning to implement a design change to comply with
both Appendix R and R.G.
1.97 commitments.
Implementation of a
modification to correct the TE-410 and TE-413 problem created by
plant M-896 is an IFI:
Inspect PM to Establish Isolation as Required
by Appendix R for TE-410 and TE-413 (261/88-28-07).
f. CV Equipment Not EQ Because of Submergence
On October 6, 1988, the licensee discovered that the calculated CV
fluid level of 3.2 ft was non-conservative.
A new value of 6 feet 1
inch has be calculated.
On October 7, 1988, the licensee issued
engineering evaluation 88-132,
JCO 88-009, to address the equipment
which would be affected by the increased submergence level.
The
evaluation concluded that the effected equipment would either remain
operable, have had achieved its function or has backup capability.
Equipment which will not perform its functions are instruments
associated with penetration F01; one channel of the exit thermo
couples, RVLIS and the Gamma-Metrics neutron flux detectors.
has not yet been declared operable after installation.
The neutron
detectors are already inoperable due to a generic problem addressed
in a Part 21 notice concerning potential moisture intrusion into
soldered and threaded connections. The exit thermocouple channel has
a redundant channel and may be inoperable indefinitely per TS Table
3.5-5, note 2.
The licensee's actions to address the long term *i.ssues associated
with the additional equipment which would be submerged following a
worst case design basis CV flood level is an UNR:
Followup on
Actions to Address Equipment Effected by an Increased CV.Submergence
Level (261/88-28-08).
No violations or deviations were identified within the areas inspected.
9. Onsite Review Committee (40700)
The inspectors evaluated certain activities of the PNSC to determine
whether the onsite review functions were conducted in accordance with TS
and other regulatory requirements. In particular, the inspectors attended
the September 14, 1988 PNSC meeting involving operability of the HVH
units.
It was ascertained that provisions of the TS dealing with member
ship,- review process,
frequency,
and qualifications were satisfied.
Previous meeting minutes were reviewed to confirm that decisions and
recommendations were accurately reflected in the minutes. The inspectors
also followed up on selected previously identified PNSC activities to
independently confirm that corrective actions were :progressing satis
factorily.
No violations or deviations were identified within the areas inspected.
10. Solid Radioactive Waste (84722)
The inspector reviewed the details of an event which involved contaminated
water being detected in the plant storm drains.
At approximately
5:00 p.m., on August 8, 1988, a contract worker informed her supervisor of
the presence of cloudy water in the storm drain on the south side of the
E&RC building.
Upon analyzing a water sample from the storm drain, the
licensee determined that the water was contaminated. An isotop.ic analysis
indicated that the radioactivity found was similar to that found in a
sample of primary coolant.
Water samples were collectedand analysed from other storm drains in-the
vicinity of the E&RC building and throughout the site, as well as from the,
west settling basin where these storm drains empty.
Contamination was
detected in the water samples from two other storm drains that are nearest
the.E&RC building.
There was none found in storm drain samples from the
remainder of the site nor. in samples from the waste settling basin.
Because the licensee suspected that the contaminated waste was coming from
the E&RC laboratory sump (the receptacle for primary coolant samples
following analysis,), the contents of the sump were pumped to the Auxiliary
Building #2 sump tank for processing as radioactive waste (radwaste).
The
licensee also collected air samples above the storm drain covers and
performed contamination surveys of the areas around the drains.
No
airborne or surface contamination was detected.
The contaminated water
from the three storm drains was also pumped to the #2 sump tank in the
Auxiliary building for future processing.
The licensee estimated that
approximately 200 gallons of contaminated liquid were pumped into the #2
sump tank.
The licensee indicated that the 200 gallons included ground
seepage water, as well as contaminated water.
The exact quantity of
ground seepage water could not be determined.
Following the immediate corrective actions to stop the release of
contaminated water, the licensee performed an investigation of the event
and a walkdown of the E&RC building waste drainage system to determine the
source of the problem. The licensee discovered that the E&RC laboratory
sump had apparently been filled beyond its capacity.
This resulted in
contaminated liquid-backing up into the floor drains in the chemistry
laboratory. The contaminated liquid then flowed through bolt holes in the
12
flange pipe of the floor drains and through voids around the drain piping
to a French Drain installed under the E&RC building.
The French Drain.
subsequently discharged into the storm drain by means of a four-inch line.
The investigation also revealed that the level probes (installed in the
E&RC building sump to automatically control the level of liquid in the
sump) and the alarm (installed to indicate when the sump was full) were
not operating properly.
Through discussions with licensee representatives and records review, the
inspector determined. that the sump pump controls, including the alarm and
the level probes, had not worked properly since being installed in 1985.
A work request was eventually submitted in September 1987, to initiate
repair of the controls. Although repairs were completed in January 1988,
and the automatic actuation of the sump pump and the alarm verified,
licensee representatives indicated that the controls still did not
function properly.
No further work requests were initiated until the
contaminated liquid was discovered in the storm drains.
The licensee is required by 10 CFR 50,
Appendix B, Criterion XVI, to
establish measures to assure that conditions adverse to quality, such as
failures, malfunctions, deficiencies, deviations, defective material and
equipment, and nonconformances are promptly identified and corrected.
Failure of the licensee to promptly correct identified problems associated
with the E&RC building sump pump controls which led to the introduction
of radioactive water into the storm drainage system is identified as
violation of 10 CFR 50, Appendix B, Criterion XVI:
Failure to Correct
Sump Pump Controls Which Resulted in Radioactive Releases to the Storm
Drain System (50-261/88-28-09).
On violation was identified within the areas inspected.
11. Transportation (86721)
The inspector reviewed selected records of radioactive waste and radio
active material shipments performed during 1988.
The inspector also
reviewed the records of the circumstances surrounding the shipment of
contaminated liquid contained inside a tank and inside a piece of
shielding to a recycling vendor.
On February 24, .1988,
the licensee made a shipment of two Sea/Land
Containers to the Quadrex Recycle Center in Oak Ridge, Tennessee.
The
containers were filled with material to be decontaminated or disposed of
as radioactive waste. The shipping papers identified the physical form of
the material as solid; no liquid was indicated on the shipping papers. In
March,
as the vendor was processing the material from the two containers,
a RCP decontamination tank was found to have about six to seven gallons
of liquid inside.
In addition, a support structure containing lead
13
shielding, which was included in the shipment, was found to have about two
gallons of liquid inside.
The vendor collected, analyzed, processed,
and disposed of the water, and decontaminated the tank and the shield.
Isotopes in the water recovered from the tank and the shield were
identified as Cobalt-57, Cobalt-60, and Manganese-54.
The tank and
shield, with fixed contamination remaining,
were sent back to the
licensee.
Following an investigation of the incident, the licensee determined that
the tank and the shield had been in storage for approximately fifteen
months prior to being shipped to the vendor. When placed in storage, the
tank had been wiped dry and -wrapped with herculite, while the shield,
which appeared to be solid, was stored without being wrapped.
The items
had been stored in a contaminated warehouse which had a leaking roof.
Apparently, the liquid discovered by the vendor was the result of rain
water leaking on and into the items.
The licensee also determined that a
second root cause of the problem was personnel error in judgement.
The
same individual who had wiped the tank and placed it in storage was the
one who checked it and prepared it for shipment.
Since it had been wiped
dry and wrapped previously, the person assumed that no water was in the
'tank and that no further inspection was necessary. The shield was assumed
to be solid and was not inspected or tapped to check for liquid.
The licensee implemented corrective actions to prevent future events of
this nature. The individual involved in the event wrote a lesson plan
describing what happened and instructed other HP personnel concerning the
circumstances of the shipment. This instruction was provided during plant
safety meetings held during April 1988.
A new procedure, HPP-201, Code
of conduct for Radioactive Material Shipment, Revision 1, dated June 24,
1988,
was developed to discuss the various aspects of shipping and
receiving radioactive material.
The new procedure was also written to
ensure that double verification of the physical aspects of the shipments,
such as the presence of liquid, was performed. The licensee also issued a
job request to repair and seal the roof of the contaminated warehouse. As
a final measure , the licensee issued a POER detailing the event, the root
causes, and the corrective actions taken.
10 CFR 71.5 requires that licensees who transport licensed material.
outside the confines of their plant or other place of use, or who deliver
licensed material to a carrier for transport, shall comply with the
applicable requirements of the regulations appropriate to the mode of
transport of the DOT in 49 CFR 170 through 189.
49 CFR 172.203(d)(1)(ii) requires that a description of the physical and
chemical form of the material being shipped and radioactive material be
included on the shipping papers which accompany the shipment.
14
Failure of the licensee to indicate the proper physical form of the
material listed on the shipping papers was identified as a violation of
10 CFR 71.5:
Failure to Indicate Proper Physical Form of Material on
Shipping Papers (50-261/88-28-10). As this is a violation of minor safety
or environmental concern for which, by the end of the inspection, the
licensee had already taken or was in the process of taking adequate
corrective actions to prevent recurrence, no response will be required.
One violation was identified within the area inspected.
12.
Exit Interview (30703)
The inspection scope and findings were summarized on October 19 and 26,
1988,. with those persons indicated in paragraph 1.
The inspectors
described the areas inspected and discussed in detail the inspection
findings listed below.
Dissenting comments were not received from the
licensee. Proprietary information is not contained in this report.
No
written material was given to the licensee by the Resident Inspectors
during this report period.
Item Number
Status
Description/Reference Paragraph
88-08-01
Closed
IFI -
Implementation of the LER
Writer's Guide (paragraph 3).
88-08-03
Closed
IFI
Track Commitments Made to
NRC in LERs Through the RAIL
Commitment Tracking System (para
graph 3).
88-28-01
Open
IFI -
Establishment-of EQ Lifetimes
Inside CV Based Upon Actual Tempera-.
ture Conditions (Paragraph 4).
88-28-02
Open
VIO -
Failure to Have a Program To
-
Use Calibrated Stop Watches For
Required TS and ASME Section XI
Testing (paragraph 6.a).
88-28-03
Open
UNR -
Failure To Have Rx Head Vent
Valves Environmentally Qualified
(paragraph 8.a).
88-28-04
Open
IFI - Review Visual and Eddy
Current Testing of HVH 1-4 Dring
November 1988 Refuel Outage (paragraph
8.b).
UN0
alr oHaeR edVn
15
Item Number
Status
Description/Reference Paragraph
88-28-05
Open
IFI - Licensee To Develop Methodology
to Detect Biological Growth in HVH 1-4
(paragraph 8.b).
88-28-06
Open
UNR - Review LER 88-022 and CV
Operability Requirements After Opening
of CV Purge Exhaust Valves (paragraph
8.b).
88-28-07
Open
IFI - Inspect PM to Establish
Isolation as Required by Appendix R for
TE-410 and TE-413 (paragraph
8.e).
88-28-08
Open
UNR - Followup on Actions to Address
Equipment Affected by an Increased CV
Submergence Level (paragraph 8.f).
88-28-09
Open
VIO - Failure to Correct Sump Pump
Controls Which Resulted in Radioactive
Releases to the Storm Drain System
(paragraph 10).
88-28-10
Closed,
VIO - Failure to Indicate Proper
Physical Form of Material on Shipping
Papers (paragraph 11).
13.
List of Abbreviations
American Society of Mechanical Engineers
CFR
Code of Federal Regulations
Corrective Maintenance
CV
Containment Vessel
Department of Transportation
DSP
Dedicated Shutdown Procedure
E&RC
Environmental and Radiation Control
Environmental Qualification
Engineered Safety Feature
F
Fahrenheit
Health Physics
HVH
Heating Ventilation Handling
IFI
Inspector Followup Item
JCO
Justification For Continued Operation
LCO
Limiting Condition for Operation
LER
Licensee Event Report
Motor Driven Auxiliary Feed Water
16
NRC
Nuclear Regulatory Commission
OST
Operations Surveillance Test
PEP
Plant Emergency Procedure
PLP
Plant Program
Plant Modification
PNSC
Plant Nuclear Safety Committee
POER
Plant Operating Experience Report
Penetration Pressurization System
PZR
Pressurizer
RAIL
Regulatory Action Item List
Reactor Coolant Pump
REV
Revision
R.G.
Regulatory Guide
Reactor Turbine Generator Board
Reactor Vessel Level Indicating System
System Driven.Auxiliary Feedwater
S/G
Special Procedure
SPODS
Safety Parameter Display System
Tc
Cold Leg Temperature
Temperature Control Valve
Th
Hot Leg Temperature
TI
Temporary Instruction
TS
Technical Specification
- UNR
Unresolved Item
WR/JO
Work Request/Job Order
.^UNRs
are matters about which more information is required to determine
whether they are acceptable or may involve violations or deviations.