ML16341E694
| ML16341E694 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/14/1988 |
| From: | Dennig R NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Narbut P NRC |
| References | |
| NUDOCS 8806210233 | |
| Download: ML16341E694 (24) | |
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STATES NUCLEAR REGUL47ORY COMMISSI WASHINGTON, D. C. 20555
~~g g4,')988 MEMORANDUM FOR:
Paul P. Narbut Senior Resident Inspector Diablo Canyon FROM:
'Robert L. Dennig, Chief Trends and Patterns Section Office for Analysis and Evaluation of Operational Data
SUBJECT:
INTERPRETATION OF REPORTING VIOLATIONS OF HIGH RADIATION AREA TECHNICAL SPECIFICATION II Mr. M. Hug of the Diablo Canyon l.icensing staff requested by telephone and with a 'followup note on March 24, 1988, clarification of the reportability of Administrative Technical Specification violations related to events that involve,acc'ess to high radiation areas.
Mr. Hug based his request on an event at the Diablo. Canyon Station 'that involved a door to a high radiation area that should hav'e been locked but was found open.
This letter supplements our verbal response, of April 7, 1988.
Based on the information iriitiallyreceived from Mr. Hug and subsequent followup questions, we concluded, that the particular event referenced by Mr.
Hug was a reportable'vent in accordance with the requirements of 10 CFR 50.73 (a)(2)(i)(B).
Oq'.'g lfJg ee Robert L. Dennig, Chief Trends and Patterns Section Office for Analysis and Evaluation of Operational Data 8806210233 880414
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Attached is a list of administrative technical specification violations reported by licensees for the period 1984 through 1986.
Note that the marked events are similar to or the same as the particular case in question at Diablo Canyon.
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Table A-1 TS Violations During 1984:
TS Category=Administrative PAGE A-2 PLANT NhNE CRYSTAL RIVER 3 DRESDEN 2
DRESDEN 3
GINNA GRAND GULF GRAND GULF HADDAM NECK HATCH 2 LASALLE 1 LASALLE 1 LER NO.
30284018 23764006 24984005 24484013 41684025 41684025 21384020 36684030 37384025 37384034 EVENT DATE 01/05/84 02/08/84 07/18/84 10/15/84 05/01/84 05/01/84 10/13/84 11/15/84 05/17/84 06/17/84 EVENT DESCRIPTION Utility error:
Battery specific gravity was not within test limits.
LER was generated because event was not initially repoxted.
Utility error:
LPCI corner room submarine door to the torus basement was found open and unattended.
Utility exror:
Submarine doox between torus and low pressure coolant in)ection pump room was open and unattended.
Utility error:
Procedural change to surveillance test allowed omission of a particular rod bank test that should not have been omitted.
Utility error:
A superceded procedure was used to test drywall purge system flow prior to startup on occasions.
Utility error:
A superceded procedure was used to test drywall purge system flow prior to startup on occasions.
Utility error:
Unqualified health physics technician given tha responsibility to record employee dose readings in a high exposure area.
Utility error:
A Tech Spao change in frequency of test (18 months to 30 days) was not incorporated into procedures, resulting in 2 missed main steam line temperature channel tests.
Utility error:
A trapdoor on the auxiliary building roof, which allows entry into a high radiation area (radwaste pipe tunnel),
was neither posted as a high radiation area nor secured in any manner, Utility error:
A high radiation area door, which leads to the URC tank room of tha turbine building was found open with no positive access control.
Table A-1 TS Violations During 1984:
TS Category=Administrative PAGE A-3 PLANT NAME LASALLE 1 LASALLE 1 LASALLE 1 LASALLE 1 LASALLE 1 LASALLE 1 LASALLE 2 LASALLE.2 LASALLE 2 LASALLE 2 QASALLE 2 LER NO.
37384036 37384070 37304079 37384083 37384093 37384092 37484022 37484034 37484038 37484049 37484070 EVENT DATE 06/14/84 10/25/84 11/14/04 11/24/84 12/19/84 12/30/84 05/21/84 07/03/84 07/17/84 08/01/84 10/09/84 EVENT DESCRIPTION Utilityerror:
Entrance to the Unit 2 reactor water cleanup hold pump room was found to be closed but not latched.
The electrical strike mechanism on the locking device was sticking in the open position.
Utility error:
Area including RHR pump room initially not classified as a high radiation area for maintenance.
Latex classified as a
Utility orror:
Door to a high radiation area (MSIV room) was not posted dua to management confusion over which door actually needed posting.
Utility error:
There was no barrier on an alternate (although unlikely) entrance to W high radiation area in the reactor building.
Technician found radioactive debris bag in an area not marked as a high radiation area.
Room was unattended and unsecured.
Utility error:
Positive control not maintained on an entrance to a temporary high radiation area.
Utility erxor:
Door to a high radiation area was left open and unattended.
Utility error:
Area known to be a high radiation area when reactor power is above 50K was not posted as such until reactor power reached 70%.
Door to reactor water cleanup heat exchanger room (hi radiation axea) was ajar for 16
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hrs.
One attempt to close door failed because technician checked wrong door.
Utility error:
3 areas with controlled access were rated as high radiation areas.~
- However, computer controlled access status was not updated allowing normal access.
Utility error:
Contractor employee left main team tunnel door (high radiation area barrier) unlatched and open.
Table A-1 TS Violation" During 1984:
TS Category=Administrative PAGE A-4 PLANT NAME LASALLE 2 LER NO.
37484082 EVENT DATE 12/07/84 EVENT DESCRIPTION A rectangular hole was discovered in the top of the entrance way to the Unit 2 condenser water box which is posted as a high rad area.
LIMERICK 35284004 ll/06/84 4 fire hose stations were left off a surveillance procedure and therefore not tested.
NINE MILE PT.
1 22085008 10/16/84 On June 10, 1985 it was discovered that the temporary jumper block log had not been reviewed per T.S. 6.8.3.C after leads were lifted on October 02, 1984.
NORTH ANNA 4 NORTH ANNA 1 POINT BEACH 1 RANCHO SECO 33884017 33884024 26685005 31284002 10/05/84 12/06/84 02/07/84 01/09/84 Utility error:
Technician assigned to provide continuous health physics coverage to workers was found asleep, therefore continuous coverage not provided.
Utilityerror:
5 periodic tests were not performed within the required surveillance.
The procedures are:
heat detector functional test, smoke detectors, degraded voltage/loss of voltage 1H bus, P-4 permissive verification Bc heat tracing.
On July 26,1985 it was discovered that three spent fuel assemblies,subcritical for less than one year, had been stored next to the east spent fuel pool wall. this was a
violation of T.S. 15.5.4.4 Utility error:
The results of the inservice inspection were not submitted to the NRC within 3 months of completion of inspection as required by Tech Specs.
RANCHO SECO RANCHd SECO 31284006 31284011 01/31/84 03/06/84 It was discovered that 23 operators and 16 ecurity personnel dedicated to the on-site fire brigade did not attend a quarterly classroom training as required by Tech Specs.
It was discovered that the configuration tables for crosstie isolation valves in surveillance procedures for high pressure injection loops A and B were misleading and incorrect.
Table A-1 TS Violations During 1984:
TS Category=Administrative PAGE A-5 PLANT NAME RANCHO SECO SALEM 1 SAN ONOFRE 1
SAN ONOFRE 1
SAN ONOFRE 2
SAN ONOFRE 3
SURRY 2 LER NO.
31284014 27284016 20684011 20684007 36184075 36284028 28184017 EVENT DATE 03/12/84 06/13/84 10/02/84 07/03/84 11/30/84 06/14/84 12/07/84 EVENT DESCRIPTION Utilityerror:
During a refueling outage 8
electrical penetrations and 1 mechanical modification to an existing penetration were performed.
Surveillance procedure for the local component leak rate was not revised to include these penetrations.
Utility error:
A temporary change in a procedure was not reviewed by the station Operations Review Committee and approved by the station manager within the 14 days of implementation as required by Tech Specs.
Utility error:
Four Temporary Change Notices were not approved within 14 days as required.
It was found that a procedural change for in-service valve testing during cold shutdown was not approved by station manager or his designee within 14 days of implementation.
Utility error:
One (of 2) fire pump was removed from service.
Procedure to supply alternate pump did not properly align system.
Utility error:
Procedures to process overtime request forms were not properly evaluated against Tech Specs prior to approval.
Due to a drawing error, aux feedwater crosstie capability between the 2 units was not available during power operation.
THREE MILE ISL.
2 32084013 06/09/84 Utility error:
A temporary change notice for the operation of the react.
bldg airlock doors which was approved by the site operations director was not submitted to NRC within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required.
TROJAN 34484013 09/07/84 Use of incorrect scaling factors lead to lower than actual (by up to 10K,) pressurizer level indications.
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Table A-1 TS Violations During 1984:
TS Category=Administrative PAGE A"8 PLANT NAME ZION 1 ZION 1
ZION 1 LER NO.
29584019 29584033 29584028 EVENT DATE 07/06/84 10/04/84 09/10/84 EVENT DESCRIPTION Utilityerror:
A required Tech Spec startup report was submitted late to the NRC.
Type B test of air locks not performed in accordance with 10 CFR 50 App. J due to failure to incorporate changes in App J into procedures.
Utilityerror:
A temporary procedure change was not completely reviewed within the 14 days required by Tech Specs.
Table A-2 TS Violations During 1985:
TS Category=Administrative PAGE A-7 PLANT NAME LER NO.
CALVERT CLIFFS 1
31785006 EVENT DATE 04/06/85 EVENT DESCRIPTION Maintenance personnel removed the upper guide structure from the reactor vessel (coupled with control element assemblies) without a fuel handling supervisor present.
COOK 1
COOK 2 CRYSTAL RIVER 3 DIABLO CANYON 1 DIABLO CANYON 1 DIABLO CANYON 1 DIABLO CANYON 2 HADDAM NECK KEWAUNEE LASALLE 1 LASALLE 1
'LASALLE 1 31585048 31585048 30285021 27585004 27585027 27585023 27585024 21385020 30585014 37385027 37385019 37385020 09/17/85 09/17/85 10/06/85 01/04/85 07/12/85 07/02/85 07/12/85 08/03/85 06/15/85 03/13/85 02/12/85 02/14/85 The turbine driven auxiliary feedwater pump trip and throttle valve solenoid was neither reviewed nor certified per T.S.
The turbine driven auxiliary feedwater pump trip and throttle valve solenoid was neither reviewed nor certified per T.S.
Health Physics Technicians misinterpreted the criteria for posting a high radiation area which resulted in a T.S. violation.
Two fire barrier penetrations became inoperable and were not reported within Tech.
Spec.
time limit.
Safety related procedures were not reviewed within T.S.6.8.3 time limits.
After an ESF actuation occurred, the time requirement for submitting a 4-hour significant event report was exceeded.
Safety related procedures were not reviewed within T.S.6.8.3 time limits.
Due to maintenance activity, a high radiation area was left unrestricted. P The spent resin storage tank room was not maintained under the administrative control of the shift supervisor per Tech.
Spec.
Gate that secures radwaste field aisle found unsecured in violation of T.S. 6.1.1.
Entrance door to radwaste pump aisle was held ajar when radiation sign fell and blocked door during use.
Violation of T.S.
6.1.1.
Gate to radwaste area found unlocked and unattended.
Violation of T.S. 6.1.1.
Table A-2 TS Violations During 1985:
TS Category=Administrative PAGE A-8 Pl ANT NAME LASALLE 1 LASALLE 1 LASALLE 1 LASALLE 1 LER NO.
37385023 37385021 37385004 37385016 EVENT DATE 02/23/85 02/20/85 01/12/85 02/08/85 EVENT DESCRIPTION Door to Condensate Polisher Regeneration Tank Room was found unsecured in violation of T.S. 6.1.1.
Gate to Solid Radwaste Pump Room in Turbine Building found propped open and unattended in violation of T.S. 6.1.1.
Reactor Building Equipment Drain Pump Room high radiation door not secured per T.S.
6.1.1
- broken latch.
Door to Reactor Water Cleanup Heat Exchange Room found unsecured for 5 minutes in violation of T.S. 6.1.1.
MAINE YANKEE MCGUIRE 1
NORTH ANNA 1 PALISADES PILGRIM 1 RIVER BEND 1
. 'SEQUOYAH 1
30985001 36986039 33885018 25585021 29385031 45885054 32785019 02/11/85 12/10/85 09/17/85 10/09/85 10/29/85 11/27/85 05/24/85 A low pressure safety inJection header stop valve handwheel was not locked open per Tech.
Spec.
3.6.A.2 as required.
Valve was electrically disabled one hour and 23 minutes.
The spent fuel pool ventilation performance test was not performed within T.S. 4.9.11.2 time requirements.
Reactor Operator's license expired but he performed licensed duties for two weeks due to plant administration error.
Violation of T.S. 6.2.2.
No licensed senior operator was in the control room for approximately five minutes.
One individual served as Shift Technical Advisor and Reactor Operator for four hours contrary to T.S.6.2-1.
Shift crew composition not met.
The standby service water pumps and the low pressure core spray pumps, with vibration in the alert range, were not surveyed per T.S.
4.0.5 frequency.
Fire header and one-inch demineralizer water pipe not supported for seismic event.
Water could spray electrical components.
Table A-2 TS Violations During 1985:
TS Category=Administrative PAGE A-9 PLANT NAME SEQUOYAH 1 SEQUOYAH 1
SKQUOYAH 2 SHOREHAM 1-SHOREHAM 1 LER NO.
32785047 32785048 32785048 32285019 32285053 EVENT DATE 12/05/85 12/08/85 12/06/85 05/16/85 11/07/85 EVENT DESCRIPTION Approximately 8 to 10 employees were believed to have keys that could open locks for high radiation areas that must be controlled administratively.
Violation of T.S. 6.12.2.
Maintenance management system and preventative maintenance program was not reviewed per T.S. 6.8.2.
Maintenance management system and preventative maintenance program was not reviewed per T.S. 6.8.2.
A procedure change notice was not reviewed within Tech.
Spec.
time limits.
A temporary procedure change was not approved by the plant manager within T.S.6.8.3.C time limits.
ZION 1
29585006 WASH.
NUCLEAR 2 39785039 06/06/85 02/07/85 The Tech.
Spec.
requirements for fuses were incorrect and subsequently changed.
Due to procedural inadequacy, a crane operator moved a heavy load over the spent fuel pool.
ZION 1 ZION 1
ZION 1
29585023 29585034 29585027 06/17/85 09/20/85 07/26/85 A procedure change for the steam generator steam flow troubleshoot was not reviewed within Tech.
Spec.
time limit.
The change was only for cold shutdown.
A temporary procedure change was not reviewed per T.S. time limits.
A feedwater instrument sensing line procedure was not reviewed per T.S.6.2.a and 6.2.c.
Table A-3 TS Violations During 1986:
TS Category=Administrative PAGE A-10 PLANT NAME CALLAWAY CATAWBA 1 COOPER STATION FORT ST.
VRAIN HADDAM HECK KEWAUNEE NINE MILE PT.
1 NINE MILE PT.
1 NORTH ANNA 2
-OCOHEE 1
LER NO.
48386028 41386001 29886034 26786019 21388010 30586013 22086012 22086027 33986004 26986013 EVENT DATE 08/18/86 01/06/86 11/18/86 05/06/86 02/26/86 10/30/86 05/17/86 09/09/86 03/14/86 11/21/86 EVENT DESCRIPTION A HIGH RADIATION AREA DOOR WAS NOT LOCKED AS REQUIRED BY T.S.6.12.2.
LATCHING MECHANISM WAS BENT.
WHICH WAS NOT ALLOWIHG DEAD BOLT TO EXTEND PROPERLY.
A CABRON SAMPLE WAS NOT TAKEN FROM THE CONTROL ROOM VEHTILATION SYSTEM PER T.S.
4.7.6D TIME LIMITS.
PROCEDURE DID NOT ACCOUNT FOR TECH.
SPEC.
TIME LIMITS.
GENERAL ELECTRIC DETERMINED THAT NEW FUEL STORED IH THE SPENT FUEL STORAGE POOL FOR 3 DIFFERENT CYCLES COHTAINED A U"235 LOADING IN EXCESS OF TECH.
SPECS.
FUEL REACTIVITY HAD NOT CHANGED AND CRITICALITY CALCULATIONS WERE STILL APPLICABLE.
AN UNPLANNED TRANSIENT CAUSED REACTOR POWER TO INCREASE PAST THE 34.2X POWER LIMIT.
CAUSE WAS LEAKAGE PAST A MAIN STEAM BYPASS PRESSURE CONTROL VALVE.
AN ELECTRICIAN ENTERED h HIGH RADIATION AREA WITHOUT THE PROPER TECH.
SPEC.
REQUIREMENTS, OHE OF THESE REQUIREMENTS BEING A RADIATION MONITORING DEVICE.
A GATE TO A HIGH RADIATION AREA WAS LEFT UHSECURED AHD UNATTENDED IH VIOLATION OF T.S. 6.13.1.8.
FIRE PUMPS WERE TAKEN OUT OF SERVICE FOR MAINTENANCE AHD THE NRC WAS NOT PHONED PER T.S. 6.9.2.A.
BLOCK WAS INSTALLED ON SHUTDOWN COOLING PUMP LOW SUCTION PRESSURE TRIP AND PROCEDURE TEMPORARY CHANGE NOTICE WRITTEN AS REQUIRED.
CHANGE NOTICE WAS NOT REVIEWED AND APPROVED BY THE STATION SUPERINTENDENT WITHIN PERIOD SPECIFIED IN TECH.
SPEC.
6.8.3.
THE SURVEILLANCE REQUIREMEHT FOR INSPECTING SHUBBERS WAS EXCEEDED DUE TO A COMPUTER PROGRAM ERROR.
VIOLATION OF T.S. 6.8.1.
THE REVIEW AND APPROVAL OF PROCEDURES FOR KEOWEE HYDRO STATION (EK)
WERE NOT PERFORMED PER T.S.6.1.2.'1 SINCE 19'77.
Table A-3 TS Violations During 1986:
TS Category=Administrative PAGE A-11 PLANT NAME OCONEE 2
OCONEE 3
SEQUOYAH 1
SEQUOYAH 1
SEQUOYAH 1
SEQUOYAH 1
SEQUOYAH 2 SEQUOYAH 2 SEQUOYAH 2 TURKEY POINT 3
,.'ANKEE-ROWE LER NO.
26986013 26986013 32786036 32786052 32786042 32786004 32786036 32786042 32786052 25086018 02986002 EVENT DATE 11/21/86 11/21/86 08/20/86 11/04/86 09/08/86 02/18/86 08/20/86 09/08/86 11/04/86 04/16/86 03/11/86 EVENT DESCRIPTION THE REVIEW AND APPROVAL OF PROCEDURES FOR KEOWEE HYDRO STATION (EK)
WERE NOT PERFORMED PER T.S.6.1.2.1 SINCE 1977.
THE REVIEW AND APPROVAL OF PROCEDURES FOR KEOWEE HYDRO STATION (EK) WERE NOT PERFORMED PER T.S.6.1.2.1 SINCE 1977.
A QUORUM WAS NOT DOCUMENTED AND WAS THUS INADEQUATE AS REQUIRED BY T.S. 6.5.1.5.
THE ADMINISTRATIVECONTROL OF A HIGH RADIATION AREA, T.S.6.12.2, WAS NOT COMPLIED~
WITH.
CALIBRATION OF TEMPERATURE SENSORS WAS NOT PERFORMED AS REQUIRED BY TECH SPEC DEFINITION 1.3 FOR CHANNEL CALIBRATION.
SYSTEMS INVOLVED WERE (EIIS) BP, AB.
AND IG.
A PERSON ENTERED A HIGH RADIATION AREA WITHOUT SIGNING AND COMPLYING WITH THE APPROPRIATE WORK PERNIT.
VIOLATION OF T.R.
6.12.1.
A QUORUM WAS NOT DOCUMENTED AND WAS THUS INADEQUATE AS REQUIRED BY T.S. 6.5.1.5.
CALIBRATION OF TEMPERATURE SENSORS WAS NOT PERFORMED AS REQUIRED BY TECH SPEC DEFINITION 1.3 FOR CHANNEL CALIBRATION.
SYSTEMS INVOLVED WERE (EIIS) BP, AB AND IG.
THE ADMINISTRATIVECONTROL OF A HIGH RADIATION AREA, T.ST 6.12.2, WAS NOT COMPLIED WITH.
A COMPONENT COOLING WATER HEAT EXCHANGER WAS OUT OF SERVICE FOR GASKET REPLACEMENT AND CLEANING.
INTAKE COOLING WATER TEMPERATURE ROSE SO THAT THE SERVICE HX WAS NEEDED AND RESULTED IN A VIOLATION OF T.S.
1.16.
THE OFFSITE DOSE CALCUIATION MANUAL WAS BEING IMPLEMENTED BY INSUFFICIENT PROCEDURES PER T.S. 6.8.1.C.
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Table A"3 TS Violations During 1986:
TS Category=Administ,rative PAGE A-12 PLANT NAME YANKEE"ROWE ZION 1
ZION 1
ZION 2 ZION 2 LER NO.
02986001 29586019 29586031 30486003 29586019 EVENT DATE 03/11/86 05/14/86 09/02/86 02/03/86 05/14/86 EVENT DESCRIPTION A CHANGE HAD BEEN ISSUED TO THE EMERGENCY PLAN WITHOUT PORC REVIEW PER T.S. 6.5.1.6.J.
PLANT PROCEDURE CHANGE WAS APPROVED FOR PERMANENT USE WITHOUT TECHNICAL STAFF SUPERVISOR APPROVAL.
VIOLATION OF TECH.
SPEC.
6.2.B.1.
A CHANGE IN THE METHOD OF CALIBRATING A CS 137 SOURCE WAS NOT REVIEWED PER T.S. 6.2.4.
TEMPORARY CHANGE FOR REACTOR TRIP BREAKER MAINTENANCE PROCEDURE WAS NOT FULLY APPROVED WITH THE 14 DAYS REQUIRED BY TECH.
SPECS.
STATION MANAGER APPROVAL.
PLANT PROCEDURE CHANGE WAS APPROVED FOR PERMANENT USE WITHOUT TECHNICAL STAFF SUPERVISOR APPROVAL.
VIOLATION OF TECH.
SPEC.
6.2.B.1.
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