ML17290A976
| ML17290A976 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/04/1994 |
| From: | Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17290A974 | List: |
| References | |
| 50-397-93-50, NUDOCS 9402230090 | |
| Download: ML17290A976 (24) | |
See also: IR 05000397/1993050
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report
No:
Docket No:
License
No:
Licensee:
Facility Name:
Inspection at:
Inspection
Conducted:
Inspectors:
50-397/93-50
50-397
Washington Public Power Supply System
P. 0.
Box 968
Richland,
WA 99352
Nuclear Project
No.
2
(WNP-2)
WNP-2 site near Richland,
November 30,
1993
January
10,
1994
R.
C. Barr, Senior Resident
Inspector
D. L. Proulx, Resident
Inspector
S.
P.
Sanchez,
Resident
Intern
D.
E. Corporandy,
Project Inspector
(December
13-17)
Approved by:
~Summer:
P.
H
ohnson,
Chief
React
Projects
Branch
1
Date Signed
Ins ection
on November
30
1993
Januar
10
1994
Re ort No. 50-397 93-50
Areas
Ins ected:
Routine,
announced
inspection
by the resident
inspectors
and
project inspector of control
room operations,
licensee
action
on previous
inspection findings, operational
safety verification, surveillance
program,
maintenance
program,
licensee
event reports,
special
inspection topics,
and
procedure
adherence.
During this inspection,
Inspection
Procedures
61726,
62703,
71707,
90712,
92700,
92701,
92702
and 93702 were used.
Safet
Issues
Mana ement
S stem
SIMS
Items:
None.
Results:
General
Conclusions
and
S ecific Findin
s
~Stree ths:
None .noted. within the
scope of this
inspection
.
Weaknesses:
Inadequate
management
controls
and chemistry evaluations
resulted
in a
chemical spill and Unusual
Event due to noxious gases
in the radwaste building
(Paragraph
4.a).
9402230090
940208
ADOCK 05000397
Q
Operator reasoning
in determining the operability of a containment isolation
valve was poor and untimely.
In addition,
the operators'ubsequent
actions
in responding to the inoperable
valve were weak due to
a poor shift turnover
(Paragraph
4.b).
Licensee
personnel left an unrestrained
compressed
gas cylinder (without a
protective
cap)
near safety related
equipment
and did not properly restrain
several
other compressed
gas cylinders,
which could have resulted
in missile
hazards
(Paragraph
5.b(10)).
The licensee violated
10 CFR 19. 11 by failing to properly post two Notices of
Violation'nvolving radiological working conditions
(Paragraph
5.b(12)).
Contrary to'the vendor manual, electricians
assembled
several
battery racks
with gaps left between the brackets
and cells
(Paragraph
5.c).
The Plant Operations
Committee review of. proposed on-line leak sealing of
valve HS-V-20 was weak.
The licensee failed to perform
an
ASME Section
XI
repair work plan for the on-line leak sealing.
Mechanical
maintenance
personnel's
understanding
of the construction of HS-V-20 was weak.
The
licensee
also did not initiate
a problem evaluation request
when discrepancies
were noted in the closeout of the HS-V-20 repair work procedure.
Weak
vertical
communications
were also evident in the MS-V-20 leak repair,
because
management
was misinformed of the location of the original leak and the
location of the leak sealant
adapters
(Paragraph
7.a).
Weak work coordination
among work control personnel
resulted
in extra outage
time for an emergency diesel
generator
(Paragraph
7.b).
Si nificant Safet
Matters:
None.
Summar
of Violations:
Two violations were identified involving the failure
to initiate
a
PER for
a maintenance
discrepancy
(Paragraph
7.a)',
and two
examples of failure to restrain
compressed
gas cylinders
(Paragraph
5.b(10)).
Four non-cited violations were also noted
(Paragraphs
4.a,
5.b(12),
and 7.a).
DETAILS
Persons
Contacted
V. Parrish,
Assistant
Hanaging Director for Op'erations
- J. Gearhart,
guality Assurance
Director
- H. Flasch,
Engineering Director
- J. Streeter,
Executive Assistant
- J. Swailes,
Plant Hanager
- G. Smith, Operations Division Hanager
- R. Webring, Technical
Services
Manager
- H. Monopoli, Haintenance
Division Manager
.
- D. Coleman,
Acting Regulatory
Programs
Manager
- W. Barley, Radiation Protection
Manager
- J. Albers, Corporate Radiological
Health Officer
- H. Kook, Licensing Manager
- D. Larkin, Engineering
Services
Manager
- J. Benjamin, guality Assessments
Manager
- S. Davison,
Plant Support Assessments
Manager
- J. Peters,
Administrative Manager
- J. Rhoads,
Acting guality Support
Manager
- W. Shaeffer,
Operations
Manager
- T. Hessersmith,
Maintenance
Support
Manager
- J. Sampson,
Maintenance
Production
Manager
- B. Hugo, Licensing Engineer
The inspectors
also interviewed various control
room operators,
shift
supervisors
and shift managery,
maintenance,
engineering,
quality
assurance,
and management
personnel.
- Attended the Exit Meeting
on January
31,
1994.
Plant Status
1
At the start of the inspection period,
the plant was operating at
100%
power.
On December
1,
1993, the licensee
declared
an Unusual
Event
(UE)
(Paragraph
4.a)
due to
a spill of liquid used for the processing of
glycol, which resulted
in the release
of noxious
fumes in the radwaste
building.
The Shift Manager
suspended
operator
rounds
and fire tours in
the radwaste
building for four hours.
The licensee
contained
the spill
and exited the
UE.
The plant continued to operate
at full power (except
for momentary
downpowers to support weekly bypass
valve testing
and
control rod exercises)
until the end of the inspection period.
Previou'sl
Identified
NRC Ins ection
Items
92701
92702
The inspectors
reviewed records,
interviewed personnel,
and inspected
plant conditions relative to licensee
actions
on previously identified
inspection findings:
a.
Closed
Violation 50-397 92-37-05
I
Violation 50-397/92-'7-05 identified that
as of August 15,
1992, the
licensee's
Nuclear Safety Assurance
Group
(NSAG) had not reviewed
'the industry advisory contained
in a March 18,
1992,
Owners'roup
(BWROG) letter
and
had not made
any recommendations
for
revising procedures,
training, operating activities, or
otherwise'mproving
unit safety associated
with core stability and the
advisory.
The inspector
reviewed the licensee'.s
assessment
of the
problem
and subsequent
corrective actions.
The inspector
noted that
the corrective actions
appeared
appropriate to the circumstances
and
that they had
been
completed.
Corrective actions
included revision
of plant procedure
PPH 1. 10.4,
"External Operational
Experience
Review," to add
BWROG documents
containing
recommendations
or
guidelines for plant issues
to the list of documents
requiring
review.
Also, the Supply System
now issues
correspondence
every six
months to all
WNP-2 employees
reminding them of their responsibility
to forward pertinent information to the licensee's
Nuclear Safety
Engineering
group.
This item is closed.
4.
Event Followu
93702
92701
a 0
Unusual
Event Associated with
S ill of Gl col
On December
1,
1993,
the licensee
declared
an Unusual
Event due to
noxious
fumes in the radwaste building.
The licensee
reported this
event to the
NRC pursuant to
10 CfR 50.72.
The noxious
fumes were
caused
by an exothermic reaction
and hazardous spill in the Ozonator
skid which was
used for special
processing
of liquid waste.
The
exothermic reaction
and spill of 100 gallons of liquid were created
by mixing a glycol-water solution with 50% hydrogen peroxide
(H,O,)
solution
and then exposing this mixture to ultraviolet light and
ozone.
The foam that was created
as
a result of this reaction
blocked the air vent on the top of the tank and caused
the tank to
pressurize
and overflow.
Operations
personnel
contained
the spill,
and all personnel
evacuated
the radwaste building.
Approximately four hours later,
a tank containing
an additional
amount of the
H,O, and glycol mixture underwent
a similar foaming
and exothermic reaction, spilling an additional
200 gallons of
solution.
No personnel
were injured and
no safety
systems
were
affected.
However, the Shift Hanager
suspended
equipment operator
rounds
and fire tours for the radwaste building for approximately
four hours.
The Supply System root cause
team found that personnel
had bypassed
several
important processes
and management
directives
that
may have precluded this event.
d
k
d
'
The General Electric Organic Reduction
(GEOR) skid was obtained
by
the Supply System to reduce organic
compounds
in liquid waste to
ionic compounds
and carbon dioxide.
The
GEOR system
uses
ultraviolet light and ozone for this process.
GE designed this
system for use with low concentrations
of organic
compounds.
On
-3-
October 5,
1993, the Plant Operations
Committee
(POC)
approved
Plant
Procedures
Manual
(PPM) 11.2.23,30,
"Operation of the Organic
Reduction System," for implementation to process
100 drums of
glycol.
This procedure
did not discuss
the use of H,O, to
facilitate the processing.
The licensee
did not verify or validate
PPM 11.2.23.30 prior to its use,
as
was the licensee's
practice.
Initial
S stem Startu
The licensee first used the
GEOR system
on October
18,
1993, to
process
the water-glycol mixture.
The individual who wrote
11.2.23.30
made the final connections for use of the
GEOR system
without procedural
direction.
This individual was the only person
trained to operate
the system.
The processing
was not reducing the
glycol mixture at the desired rate,
and the licensee
was concerned
that they would not meet their commitment date of November
10,
1993,
to the Washington State
Ecology Department for completion of the
processing.
Use of H dro en Peroxide
In early November of 1993,
the licensee
discussed
with a vendor the
use" of H,O, to expedite
the process
and drive the reaction to
completion.
The licensee satisfactorily performed small-scale
laboratory tests with 5% glycol and
5% H,O, .solutions.
The licensee
performed
a second laboratory test using the
same concentrations
of
solution but with heat
added.
The licensee
also considered this
test to be satisfactory,
despite
the release
of a small
amount of
foam.
Licensee
personnel
did not evaluate
the effects'of this
reaction
on
a larger scale operation,
or one using stronger
chemical
concentrations,
and believed the potential
hazards
were minimal.
When purchasing
H,O the licensee
purchased
50% solution to
minimize the
amount of waste generated.
The licensee
did not dilute
this solution prior to its use or revise the procedure to indicate
that the Ozonator would be used with 50% H,O, solution.
Also, the
licensee
did not evaluate
the effect that the ultraviolet light and
the ozone would have
on the process with the addition of H,O,.
These errors led to the event of December
1,
1993.
Licensee
Investi ation
The licensee
formed,a root cause
team to investigate
the event
and.
recommend corrective actions.
The root cause
team determined that
several
Supply System
management
processes
and procedures
were not
followed leading
up to the event.
A general list of the weaknesses
noted included:
~
The Plant Operation
Committee
(POC) did not perform
a
10 CFR 50.59 safety evaluation for installation
and
use of the
GEOR
system.
~
The licensee
did not develop
a formal work plan that detailed
'he glycol processing
from beginning to end,
and
no support
from other departments
was delineated.
~
The author/user
did not perform
a verification and validation
of the procedure.
~
The licensee
did not provide
a method of measuring glycol
concentration
during the process.
Licensee
personnel
brought
a solution of 50% H,O, onsite with a
chemical
permit for only 3% H,O,.
The licensee
did not perform
an Industrial Safety
and Fire
Protection evaluation of bringing H,O, onsite per
PPH ).9. 1,
"Plant Safety Program."
The licensee
did not revise
PPH 11.2.23.30 to reflect the
use
of H,O, in the process.
Hanagement
did not assign. supervisory oversight for the
GEOR
process.
Health Physics
(HP) did not evaluate
the hazards
of using
H,O,
in the radiologically controlled area.
~
Personnel
performing the glycol processing
did not submit
an
ALARA scope
sheet;
therefore,
HP did not assign
a radiation
work permit
(RWP) for the glycol processing.
The inspector
concluded that the licensee
had done
a thorough
investigation
and
had identified the root causes
and initiated
effective corrective actions for the event.
The licensee's
,corrective actions
included procedure
enhancements
and disciplinary
action for the individuals and management
personnel
who were
directly involved.
However,
some of the procedure
adherence
issues
noted'during this event
appeared
to violate
NRC requirements.
The inspector
noted that Section
11.2 of the
FSAR describes
in some
detail the licensee's
methods for processing
radwaste
and does
not
discuss
the method being used
when this event occurred.
The failure
to perform
a
10 CFR 50.59 evaluation for the change in the method
of processing liquid r adwaste
is
a violation of NRC requirements.
However,
because
the criteria of Section VII.B(2) of the
NRC
Enforcement Policy were met, this violation is not being cited
(Non-cited violation
(NCV) 50-397/93-50-01,
Closed).
The licensee
performed the glycol processing
evolution in
a
radiation
area
on the 437-foot elevation of the radwaste building.
The individual performing the setup
and operation of the
GEOR system
signed in on
RWP 2-93-00028 "Supervisory
and Hanagement
Field
Inspections."
The 'scope of this
RWP does
not allow work or other
operations to be performed.
PPH 1. 11.8,
Revision 4, "Radiation Work
Permit," requires in Paragraph
6.4 that if work is to be
added to
an
existing
RWP, the pre-job planning process
must
be followed,
including submitting
an
ALARA scope
sheet.
These
requirements
in
PPH 1. 11.8 were apparently not followed.
HP personnel
stated that
if an
ALARA scope
sheet
had
been submitted,
a new
RWP would have
b.
been
issued.
In addition, the work would have
been
processed
through work control, which would have involved other licensee
groups in the planning
and implementation of the glycol processing.
The failure to follow PPH 1. 11.8 was
a violation of Technical Specification (TS) 6.8. 1.
However,
because
the criteria of Section
VII.B(2) of the
NRC Enforcement Policy were met, this violation is
not being cited
(NCV 50-397/93-50-02,
Closed).
I
The inspector
concluded that other weaknesses
existed that were not
addressed
in significant detail in the root cause
evaluation.
Licensee
managers
were
aware that the glycol processing
evolution
was to take place.
Hanagement
also discussed
the use of a
50% H,O,
solution in this process
during
a morning meeting the week the event
took place.
Although management
appeared
to be knowledgeable of the
glycol processing,
they did not appear to sufficiently question
whether the evolution had
been properly analyzed.
In addition, the inspector
concluded that the controls of PPM
1. 16.6C,
"Conduct of Infrequently Performed
Tests or Evolutions,"
may have
been applied.
PPH 1. 16.6C controls included assigning
a
line manager to ensure that
an unusual
evolution proceeds
smoothly
and in accordance
with Supply System procedures
and policies.
PPH
1; 16.6C also included criteria (e.g. first time tasks,
work done
under
a Technical Specification action statement)
to be used to
determine if the controls for infrequently performed evolutions
apply to any particular task.
The processing
of glycol in the
GEOR
system with H,O, was a'irst-time evolution.
Although the criteria
governing the applicability o'f 1. 16.6C
may not have
been clearly
met, the Plant Hanager stated that the 1. 16.6C process
has suffi-
cient flexibilitythat management
may direct the use of the
PPH
1. 16.6C controls at any time.
The inspector discussed
the above evaluation with the Plant Manager,
who acknowledged
the
NRC comments.
Test Failure of RCIC-V-63
On December
2,
1993,
the licensee
performed surveillance test
PPH
7.4.7.3.3.C,
"Reactor
Core Isolation Cooling
(RCIC) quarterly Valve
Test," for RCIC-V-63.
The valve failed its stroke time test.
At
1815 hours0.021 days <br />0.504 hours <br />0.003 weeks <br />6.906075e-4 months <br />
on December
2,
1993,
the operators
noted that RCIC-V-63
exceeded
the closing time (action range)
prescribed
in the
procedure,
but they did not immediately declare
the valve
Instead,
the operators
repeatedly
cycled RCIC-V-63
until they obtained
a satisfactory closing, time.
The inspector
concluded that the operators
performed poorly in responding to this
failed surveillance.
PPH 7.4.7.3.3.C specified
an action range for RCIC-V-63 closing time
of 10 seconds.
This 10-second limit was based
on adequate
isolation
time for environmental qualification of equipment in the reactor,
building.
However, the
TS lists the containment isolation time of
RCIC-V-63 as
16 seconds.
The operators,
at the advice of the system
engineer,
continued to stroke the valve to get decreased
stroke
times.
At 2210 hours0.0256 days <br />0.614 hours <br />0.00365 weeks <br />8.40905e-4 months <br />
on December
2,
1993, the Shift Hanager
contacted
the Operations
Hanager.
The Operations
Hanager directed
the Shift Hanager to declare
RCIC-V-63 inoperable.
The operators
then shut RCIC-V-63 and declared
the valve inoperable.
The licensee
initiated
PER 293-1378 to document this problem
and entered
TS
action statement
(TSAS) 3.6.3.a.2,
which states
that if a contain-
ment isolation valve is inoperable,
the affected penetration
must
be
isolated within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />
by use of at least
one closed
and deacti-
vated valve, or the plant must
be placed in hot shutdown within the
next
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
A shift turnover
had occurred prior to the swing shift operating
crew deactivating
RCIC-V-63.
Due to
an apparently
inadequate shift
turnover between
the swing and graveyard
crews,
the graveyard
crew
did not deactivate
RCIC-V-63 either.
At 0743 hours0.0086 days <br />0.206 hours <br />0.00123 weeks <br />2.827115e-4 months <br />
on December 3,
1993, the day shift crew discovered
the discrepancy
in following
TSAS 3.6.3.a.2.
and subsequently
deactivated
RCIC-V-63.
Approxi-
mately 13.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />
had elapsed
before the action prescribed
in TS 3.6.3.a.2
was met.
Although the licensee
did not violate the
TS (16
hours total time are allowed for a shutdown), this event indicated
the need for more thorough turnovers
and more timely and appropriate
Following the event of December
2,
1993, the licensee
reanalyzed
the
isolation time for RCIC-V-63 based
on environmental qualification.
Using
a more up-to-date
and realistic computer
code,
the licensee
determined that for environmental qualification, the maximum isola-
tion time would be
26 seconds.
Because this number
was in excess of
the containment isolation time in the TS, the licensee
modified the
acceptance
criterion for closure of RCIC-V-63 to
16 seconds,
as is
listed in the TS.
PPH 1.5. 1, "Technical Specifications
Surveillance Testing Program,"
required that if components
exceed their action range during
testing,
the component shall
be declared
at the time
personnel
recognize that the data
are outside the action range.
In
addition,
Paragraph
4.0.5 of the basis for the
WNP-2 TS states
that
the
ASHE Section
XI "24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> grace period" prior to declaring
a
valve inoperable is not allowed.
This requirement
was clarified in
"Resolution of Degraded
and Nonconforming
Conditions."
Despite the
NRC and 'licensee
procedural direction, the
licensee
personnel
believed that they had
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to make
an
PPH 1.3. 12B, "Operability Evaluations,"
allowed
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for opera-
bility determinations,
without exempting instances
.when equipment is
obviously inoperable
and should
be declared
immediately.
GL 91-18 states that in most cases operability determinations
can
be
made immediately,
but there could be cases
in which additional
information would be necessary
to make the determination within 24
hours.
The
GL noted that in a few exceptional
cases,
more than
24
hours would be required.
PPH 1.3. 12B appeared
to imply that
24
hours (or more)
are allowed for all operability evaluations.
This
apparent
discrepancy
between
PPHs 1.3. 12B and 1.5. 1 led licensee
personne1
to believe that they were not required to act
upon the
degraded
condition immediately.
The inspectors
discussed
the
above
comments with the Plant Hanager,
who acknowledged
the
inspectors'omments.
The licensee
was concurrently reviewing the Supply
System's original actions
taken in response
to
Two non-cited violations were noted.
5.
0 erational
Safet
Verification
71707
a.
Plant Tours
The inspectors
toure'd the following plant areas:
Reactor Building
Control
Room
Diesel
Generator Building
Radwaste
Building
Service Water Buildings
Technical
Support Center
Turbine Generator Building
Yard Area and Perimeter
i
b.
The inspectors
observed
the following items during the tours:
(I)
. 0 eratin
Lo
s
and Records.
The inspectors
reviewed records
against Technical Specification
and administrative control
procedure
requirements.
(2)
Honitorin
Instrumentation.
The inspectors
observed
process
instruments for correlation
between
channels
and for
conformance with Technical Specification requirements.
(3) ~hit'l
i
.
Th
i
p t
b
d
t
1
d hift
manning for conformance with 10 CFR 50.54(k), Technical
Speci-
fications,
and admini'strative procedures.
The inspectors
also
- observed
the attentiveness
of the operators
in the execution of
their duties,
and the control
room was observed
to be free of
distractions
such
as non-work related radios
and reading
materials.
(4)
E ui ment Lineu s.
The inspectors verified valves
and
electrical
breakers
to be in the position or condition required
by Technical Specifications
and administrative
procedures
for
the applicable plant mode.
This verification included routine.
control board indication reviews
and conduct of partial
system
lineups.
Technical Specification limiting conditions for
operation
were verified by direct observation.-
(5)
E ui ment
Ta
in
.
Selected
equipment, for which tagging
requests
had
been initiated,
was observed to verify that tags
were in place
and the equipment
was in the condition specified.
(6)
General
Plant
E ui ment Conditions.
Plant equipment
was
(8)
observed for indications of system leakage,
improper lubrica-
tion, or other conditions that would prevent the system
from
fulfillingits functional requirements.
were
observed to ascertain their status
and operability.
'ire
Protection.
The inspectors
observed fire fighting
equipment
and controls for conformance with administrative
procedures.
On January
3,
1994,
the inspector
noted that untreated
wood was
left near the high pressure
(HPCS)
pump.
Chemistry
personnel
had
assembled
a temporary sampling rig out of two
wooden
mop handles
and
a metal jar for sampling the floor
drains.
The inspector contacted
the Shift Hanager,
who then
directed
an equipment operator to remove the wood.
The Shift
Hanager also contacted
the Fire Harshall,
who determined that
the small
amount of wood (even untreated)
would not pose
a
threat to the overall fire loading of the
pump 'room.
The
licensee
contacted
the chemistry personnel
involved and
.emphasized
that untreated. wood is not allowed in vital areas.
Plant Chemistr
.
The inspectors
reviewed chemical
analyses
and
trend results for conformance with Technical Specifications
and
administrative control procedures.
During this inspection period, reactor water conductivity
slowly increased
from about 0. 12 umhos/cm to
a maximum of 0. 19
umhos/cm.
The licensee
determined that
a small tube leak
existed in the main condenser.
The licensee
stated that they
would attempt to perform on-line tube plugging of the leak in
the near future.
The inspectors will follow the issue of
elevated conductivity in subsequent
inspection periods.
Radiation Protection Controls.
The inspectors periodically
observed radiological protection practices
to determine whether
the licensee's
program was'eing
implemented in conformance
with facility policies
and procedures
and in compliance with
regulatory requirements.
The inspectors
also observed
compliance with Radiation
Work Permits,
proper wearing of
protective equipment
and personnel
monitoring devices,
and
personnel
frisking practices.
Radiation monitoring equipment
was frequently monitored to verify operability and adherence
to
calibration frequency.
On January
1,
1994, the licensee
implemented
the
new
10 CFR Part 20 regulations recently issued
by the
NRC.
The inspectors
noted that the
new regulations
(and the revised licensee
procedures)
define .radiation,
high radiation,
and high-high
radiation areas
at 30 centimeters
(or approximately
12 inches)
from the source.
Previously,
the licensee
defined these
areas
at
18 inches
from the source.
On January
3,
1994, the
inspectors
noted that
a hot spot
was labeled
as
80 rem/hour
on
contact
and
600 millirem/hr at
18 inches.
The inspectors
were
concerned that if the radiation levels. were measured
at 30
-9-
(10)
centimeters
from the source,
the radiation level
may be greater
than
1 rem/hour,
which would invoke high-high radiation
controls.
The licensee
measured
the radiation levels at 30
centimeters
from the source
and determined
the radiation level
to be 700 millirem/hour.
The inspectors
discussed, this
observation with the Radiation Protection
(RP) Manager.
The
manager stated that the Supply System would continue to ensure
that all of the
new 10 CFR 20 regulations
were properly
implemented
and
any posting discrepancies
would be corrected.
Plant Housekee
in
.
The inspectors
observed
plant conditions
and material/equipment
storage to determine
the general
state
of cleanliness
and housekeeping.
Housekeeping
in the radio-
logically controlled area
was evaluated with respect to-
controlling the spread of surface
and airborne contamination.
On December
22,
1993, the inspectors
noticed that
an unsecured
nitrogen,gas
cylinder was lying on the floor next to the "A"
standby
gas treatment train on the
572 foot level of the
'eactor
building.
The cylinder had
no protective valve cap
and
was not restrained
in any way.
The license initiated
PER
293-1430 to document the finding.
During the
same tour, the
inspectors
found the. nitrogen bottles for the containment
atmosphere
control system loose in the restraining racks.
The
restraining bolts were not "snugtight"
as defined per Operator
Aid f89-0075.
The retaining bolts for these bottles
are of
various lengths,
therefore it is possible for the bolts to be
"snugtight" without the bottles being held tightly.
The
initiated
PER 293-1431 to document the finding.
The licensee
replaced
the restraining bolts with'olts of sufficient length
for proper bottle restraint.
This was verified by the
inspector during subsequent
tours.
The inspectors
were concerned that the inadequately
restrained
compressed
gas cylinders noted in these
two examples
could
become
a missile hazard during
a seismic event
and
damage
the
'afety related
equipment
near these cylinders.
PPM 1.3. 19, Revision
15, "Plant Material Condition Inspection
Program,"
Section 4. 1.5.a,
Paragraph
8, requires
compressed
gas bottles to be properly secured
against
a substantial
structural
member in such
a manner
as to preclude
them from
falling over.
In 'addition, the procedure
requires bottles to
be removed at the end of the work function if not properly
secured
in bottle racks.
The failure to restrain the
com-
pressed
gas bottles
as required
by
PPM 1.3. 19 is
a violation of
10 CFR 50, Appendix B, Criterion
V (Violation 50-397/93-50-03).
(11).~Securit
.
The inspectors
periodically observed
security
practices
to ascertain
that the licensee's
implementation of
the security plan was in accordance
with site procedures,
that
the search
equipment at the access
control points
was opera-
tional, the vital area portals were kept locked
and alarmed,
that personnel
allowed access
to the protected
area
were
badged
-10-
and monitored,
and that monitoring equipment
was functional.
(12)
.
As one of the quarterly inspection
items,
,the inspectors
reviewed the notices to the workers posted
pursuant to
10 CFR 19. 11.
The inspectors
determined that
some
of the licensee's
postings
were out of date
and others did not
comply with 10 CFR 19. 11.
On December
14,
1993,
the inspectors
examined
the licensee's
postings
per Part
19. 11.
WNP-2 has three controlled posting
areas for compliance with 10 CFR 19.
The inspectors
noted that
the licensee
posted
references
to where Notices of Violation
(NOVs) could be found for several
NRC inspection reports rather
than directly posting the
NOVs.
10 CFR 19. 11 requires that all
NOVs (and licensee
responses)
involving radiological working
conditions
be conspicuously
posted within two working days of
receipt.
Paragraph
19. 11(b)
exempts other items (e.g.,
the
regulations of 10 CFR 19 and 20, the facility license,
license
conditions,
and operating
procedures)
from posting if the
licensee
references
the location where these
documents
can
be
found.
However,
Paragraph
19. 11(b)
does not exempt
NOVs and
responses
from the conspicuous
posting requirement.
However, the inspectors
noted that the
NOVs and the responses
for NRC inspection reports
50-397/92-35
and 93-18 (which cited
violations concerning radiological working conditions)
were not
posted at the designated
locations.
The licensee
received the
NOV for 92-35
on December
1,
1992,
and the
NOV for 93-18
on
November
14,
1993.
Instead,
the licensee
posted
a note- stating
that these
items could
be found in the Plant Administration
office.
This indicated that licensee
management
was not keep-,
ing personnel fully informed of problems involving radiological
working conditions
one could encounter
upon entering the plant.
The inspectors
informed the Plant Administration Manager of
this discrepancy
on December
6,
1993.
Subsequent
to the
end of
the inspection period,
the Plant Hanager
acknowledged this
violation of the requirements
of 10 CFR 19. 11.
He also stated
that existing
NOVs and responses
related to radiological
working conditions
had
been
posted
as required,
and would be
properly posted
in the future.
Because
the criteria of Section
VII.B(l) of the
NRC Enforcement Policy were met, this violation
is not being cited
(NCV 50-397/93-50-.04,
Closed).
En ineered
Safet
Features
Walkdown
The inspectors
walked
down selected
engineered
safety features
(and
- systems
important to safety) to confirm that the systems
were
aligned in accordance
with plant procedures.
During the walkdown of
the systems,
items such
as hangers,
supports,
electrical
power
supplies,
cabinets,
and cables
were inspected
to determine
whether
they are operable
and in a condition to perform their required
functions.
Proper lubrication and cooling of major components
were
also observed for adequacy.
The inspectors
also verified that
certain
system valves
were in the required position by both local
- 11-
and remote position indication,
as applicable.
The inspectors
walked
down accessible
portions of the following
systems
on the indicated dates:
~Sstem
Diesel
Generators
Divisions 1, 2,
and 3.
Hydrogen Recombiners
Low Pressure
Coolant Injection (LPCI)
Trains
"A"p "B"j and
"C"
Low Pressure
(LPCS)
High Pressure
(HPCS)
Reactor
Core Isolation Cooling
(RCIC)
Residual
Heat
Removal
(RHR), Trains
"A" and "B"
Scram Discharge
Volume
Standby
Gas Treatment
(SGT)
(SLC)
Standby Service
Water
125V
DC Electrical Distribution,
Divisions
1
and
2
250V
DC Electrical Distribution
Dates
January
6,
1994
November 30,
December
23,
1993
December
15, 23,
1993,
January
3,
1994
December
15,
23,
1993,
January
3,
1994
December
15,
1993,
January
3,
1994
December
15,
23,
1993,
January
4,
1994
December
15,
23,
1993,
January
3 1994
November 30,
December
23,
1993
November 30,
December
23,
1993
November 30,
1993
December
6,
1993
December
27,
1993
December
27,
1993
On December
27,
1993, during
a walkdown of 125V battery B1-2, the
inspectors
noted that
a 1/4-inch gap existed
between
the battery rack and
the end cell.
The inspectors
noted that Section
58. 10 of the Exide
Battery Vendor Manual states
that when replacing
a cell,
"Hake sure the
plastic channel
on the
end rail is in snug contact with the cell."
The
inspectors notified the Shift Manager,
who contacted
the available.
electric shop personnel.
Engineering
personnel
initiated
PER 293-1434 to
investigate this issue
and provide for corrective maintenance.
Electri-
cians wrote
an emergency
Maintenance
Work Request
(HWR) to eliminate the
gap between
the battery cell
and rack.
As
a result of the
inspectors'oncern,
the licensee
examined the other station batteries
and found that
12-
three other batteries
had gaps
between
the
end cells
and the battery
racks.
Engineering
personnel
performed
and determined
that despite
the batteries
not being in their intended configuration,
a
seismic event would not have impaired the function of the batteries.
The inspectors
noted that
a number of issues
concerning attention to
detail in the material condition of the safety-related
batteries
have
been identified by the
NRC in the past
two years.
The licensee
stated
that recent
improvements
made in the system engineer
walkdown would help
the licensee
to identify and correct their own problems.
The inspector
discussed
these
observations
with the Plant Manager.
One violation was identified.
Surveillance Testin
61726
The inspectors
reviewed surveillance tests
required to be performed
by
the
TS on
a sampling basis to verify that:
(1)
a technically adequate
procedure
existed for performance of the surveillance tests;
(2) the
surveillance tests
had
been
performed at the frequency specified in the
TS and in accordance
with the
TS surveillance
requirements;
and (3) test
results satisfied
acceptance
criteria or were properly dispositioned.
The inspector
observed
the following surveillance:
Procedure
0
Dates
Performed
7.4.6.I.O.I.a
Honthly Hain Steam Isolation
January
6,
1994
Valve
Leakage
Control
System Test, Division
1
No violations. or deviations
were identified.
Plant Maintenance
62703
During the inspection period,
the inspectors
observed
and reviewed
documentation
associated
with maintenance
and problem investigation
activities to verify compliance with regulatory requirements
and with
administrative
and maintenance
procedures,
required
gA/gC involvement,
proper use of clearance
tags,
proper equipment
alignment
and
use of
jumpers,
personnel
qualifications,
and proper retesting.
The inspector
verified that reportability for these
maintenance activities was correct.
The inspectors
witnessed
portions of the following maintenance
activities:
Descri tion
AP3789, Install Design
Change for Alternate
Local
Power
Range Honitor Inputs to
the
ANNA System
Dates
Performed
December
13,
1993
- 13-
AP5598,
Replace
Cell
11
on Battery Bl-2
DJ55,
Perform Furmanite Repair for HS-V-20
DL0301, Replace
Relay
DG-RLY-K16
CWA301; Repair Valve SW-V-2B
DJ5501,
Remove
and Replace
Main Steam Tunnel
Access
Hatch
December
1,
1993
December
16,
1993
December
16;
1993
December
16,
1993
January
6,
1994
a.
Furmanite
Re air of HS-V-20
On December
16,
1993; the inspector witnessed
the injection of
Furmapite,
a temporary sealant,
on HS-V-20.
HS-V-20 is: a safety-
related valve that is required to be closed
(
bl
f
or capa
e
o
being
o provi
e
a pressure
boundary for post-accident
operation
o t e main steam
leakage control
system.
The pressure
boundary
provided
by this valve is normally maintained
b
k 'h
in the
he closed position when the plant is greater
than
5%
ower.
HS-V-20 also
has
an emer
enc
o era
'
y
p
ting procedure
function, which is
an
o power.
on
e
-
esign basis,
to open
and allow for pressure
equalization
across
the main steam isolation valves (to permit their
being reopened
following an isolation).
This was the th'
tt
'
for this valve during this operating cycle.
at on-line leak sealin
is
eak appeared
to be associated
with the Furmanite adapter.
The
work on December
16,
1993,
was performed with li,ttle or no
However, there
was uncert
'
i,
e or no problem.
rtainty among licensee
management
regarding
e location of the leak
and the location of the Furmanite adapters.
Therefore,
the inspectors
performed
an in-depth followup of the
entire evolution associated
with HS-V-20.
Back round
, during
an inspection of the main steam tunnel,
the
On June
20
1993
d
bo
icensee
noted that there
was
a through-wall l
k
th
p cking chamber
on HS-V-20.
The licensee initiated
PER 293-
0909 following this discovery.
The
PER stated that the leak was in
the packing gland of the valve rather than the valve bonnet packin
chamber.
The individual that initiated the
PER did not.
e
observe
the location of the leak.
On June
20
1993 , the
POC reviewed
and approved
a proposal for a
temporary repair of the leak by injecting Furmanite sealant.
The
POC review was performed
by teleconference,
therefore the members
did not have the applicable repair procedures
or diagrams
available
or their review prior to approval of this repair.
Licensee
engineers
prepared
the work package
and
10 CFR 50.59 evaluation
based
on the belief that the leak was in the packing gland
and not
in several
the valve bonnet.
In addition,
the
10 CFR 50.59 eval t'
t d
II
leak."
It a
places that
The repair will seal
the associated
pa
k'peared
that licensee
personnel
had poorly communicated
pac ing
the planned
work to plant management.
First
Re air of Steam
Leak
The licensee initiated
HWR AP4260 to repair the leak in HS-V-20.
Step 4.A stated,
"Perform Furmanite repair to main steam valve
MS-V-20 packing gland per Furmanite procedure..."
The Furmanite
procedure
states
in Step
5. 1, "Drill and tap the valve bonnet wall,
adjacent to the packing chamber..."
When developing this
HWR and
obtaining approval
from the
POC, licensee
management
did not have
the Furmanite procedure
available for review.
This resulted in
licensee
management
being unaware that the furmanite adapters
were
being installed in the valve bonnet packing chamber.
Because
licensee
management
believed that the Furmanite adapters
were being installed in the valve packi'ng gland (this component,
as
identified in licensee
drawings,
is sometimes
called the packing
follower), an
ASHE Section
XI work plan was not developed for the
installation of the Furmanite adapters.
PPH 1.3.30,
"Repair,
Replacement,
and Alteration of ASHE Items," Paragraph
6.8,
"On-Line
Leak Sealing," states,
"Repair work plan is, required to drill and
tap hole size
one inch nominal
and smaller in valve bonnet packing
chamber."
The licensee's
installation of the Furmanite adapters
in
the valve bonnet
packing
chamber without the issuance
of an .ASME
Section
XI repair work plan was
a violation of PPH 1.3.30.
Because
the licensee
took appropriate
corrective actions for this licensee-
identified violation,
and because
the other criteria of Section
VII.B(2) of the
NRC Enforcement Policy were met, this violation is
not being cited
(NCV 50-397/93-50-05,
Closed).
The licensee first became
aware of the apparent
discrepancy
in the
location of the adapters
on September
7,
1993,
when
a maintenance
engineer
reviewed the completed
MWR package.
The engineer
noted
that the Supply System
had intended the adapters
to be put in the
valve packing gland,
but the Furmanite procedure
indicated that they
were installed in the valve bonnet.
Due to this discrepancy,
the
engineer
contacted
the Furmanite contractor
by telephone.
When
asked if he had installed the adapter
in the gland rather than the
the contractor stated that
he installed the Furmanite
adapter
in the gland.
The licensee
engineer
was satisfied with the
statement
of the contractor
and annotated
in the
comments
section of
the
MWR that the adapters
were installed
on the gland rather than
the bonnet wall
as stated
in the Furmanite procedure.
The licensee
did not enter the steam tunnel at that time to confirm the statement
of the contractor.
A PER was not initiated because
the licensee
believed that the issue
was resolved.
The. inspectors
concluded that
a
PER was necessary
at the time the
maintenance
engineer
completed his review because
either:
(1)
1.3.30 was=-violated because'n
ASHE Section
XI repair work plan was
not prepared;
or (2) the contractor personnel
violated the
HWR for
failing to install the adapters
per the work instructions.
The
failure to initiate
a
PER for the discrepancies
noted in closeout of,
the= HWR AP4260 is
a violation of PPM 1.3. 12,
"Problem Evaluation
Requests,"
and
10 CFR 50, Appendix B, Criterion
V (Violation
50-397/93-50-06).
-15-
Steam
Leak of November
10
1993
On November
10,
1993, the licensee
entered
the steam tunnel
due to
a
,high temperature
annunciator that
had
been received in the control
room on November 5,
1993.
One of the Furmanite
adapters
on MS-V-20
appeared
to be leaking.
The licensee initiated an
HWR to re-inject
the leak area to reseal
the steam leak.
In addition, the licensee
determined that the information obtained
on September
7,
1993,
regarding the location of the Furmanite adapters
was incorrect.
The
licensee
noted that the Furmanite adapters
were installed in the
valve bonnet packing
chamber versus
the previously documented
valve
packing gland.
The licensee
continued to evaluate this apparent
discrepancy,
and initiated
PER 293-1412
on December
16,
1993, to
document that
an
ASHE Section
XI work plan was not completed prior
to the leak repair
as required
by PPM,1.3.30.
The licensee's
failure to prepare
a work plan was identified earlier
as
an
NCV.
Additional Steam Tunnel Entr
On January
6,
1993, the inspector,
along with licensee
personnel,
entered
the main steam tunnel to inspect
HS-V-20 and look for
additional
steam leaks.
Licensee
personnel
pointed out to the
inspector the area that
had
been leaking.
The inspector
noted that
a threaded
plug was seal
welded into the side of the valve bonnet
packing chamber.
This was the location of the leak.
The licensee
had recently backseated
the valve to inhibit further leakage
through
the valve,
because
the Furmanite representative
stated that the
adapters
would soon leak following the repair performed
on
December
16,
1993.
Conclusions
The inspectors
concluded that several
weaknesses
were evident
concerning
the repair of HS-V-20.
Maintenance
personnel
did not
appear
to fully understand
the construction of the valve.
Several
conclusions
can
be reached
due to the m'isunderstanding
by Supply
System personnel
regarding the location of the Furmanite adapters:
the original
PER was incorrect;
most of the
POC reviews did not have
the correct information to make
a proper judgement;
Supply System
management
did not initially understand
the location of the steam
leak;
and Supply System
management
did not fully understand
the
location of the Furmanite adapters.
These
weaknesses
indicated
a
need for more strengthening
of vertical communications
at WNP-2.
The inspectors
also noted that the documentation
in the
HWR was weak
because
the initial HWR described
two different leak locations.
The
followup investigation during closeout
review of the initial MWR was
also weak because
the licensee's
conclusions
were based
upon
telephone
discussion
rather than direct observation.
Finally, the
=initial
POC review appeared
weak because
the repair of the steam
leak was approved
over the telephone with the individuals not having
the work instructions or valve diagrams
in hand.
-16-
The inspectors
discussed
these
conclusions with the Plant Manager.
The Plant Manager
acknowledged
the inspectors'omments
and stated
that the Supply System
was working diligently to improve in each of
the applicable
areas
of performance.
b.
Work Coordination for DG-RLY-K16
On December
16,
1993,
the licensee
took DG-2 out of service for
replacement
of a relay.
The licensee initially planned to replace
this relay and perform maintenance
work on valve SW-V-2B concur-
rently.
The isolation for work on SW-V-2B caused
the service water
system to be inoperable,
which also rendered
DG-2 inoperable. while-
this work in progress.
However,
due to poor work coordination,
the
repair of SW-V-2B and replacement
of the
DG relay were performed in
series,
unnecessarily
extending the outage time for DG-2.
The inspector
noted that
DG-2 was inoperable for a total time of 10
hours
on December
16,
1993.
Had the two jobs
been coordinated
and
worked concurrently,
the outage
time of DG-2 would have
been
7
hours.
The inspector
noted that the
TSAS allows
DG-2 to be out of
service for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before
a shutdown
must
be initiated,
and that
the licensee still had considerable
margin from the
TS limit.
However, the issue
indicated
a weakness
in work planning which had
unnecessari.ly
extended
the outage time for a safety
system
component.
The inspector discussed this issue with the Plant
Manager,
who acknowledged
the inspector's
comments.
One violation and
one non-cited violation were identified.
8.
Licensee
Event
Re ort
LER
Followu
90712
92700
The inspector
reviewed the following LER associated
with an operating
event.=
LER NUMBER
DESCRIPTION
93-30
Inadequate
Separation
between
Cable Trays
Based
on the information provided in the report it was concluded that
reporting requirements
had
been met, root causes
had
been identified,
and
corrective actions
were appropriate.
However, this
LER described
an
event in which li'censee
personnel
performing walkdowns of cable trays
identified
13 non-compli ances with General
Design Criterion 17.
As of
the date of the
LER, the walkdowns were about
50X complete.
The licensee
stated that other non-compliances
may be found upon completion of the
walkdowns.
LER 93-30 also states that one of the root causes for the discrepancies
was that personnel
who had performed previous cable tray walkdowns were
not trained,
and were not thoroughly familiar with the train separation
requirements.
The safety significance section of the
LER states
that
none of the
individual cable tray deficiencies
posed
a threat to reactor safety.
e
- 17-
However, the
LER states
that the large
number of deficiencie's
may
be
safety significant, or may indicate
a programmatic
problem with train
separation.
Because of the potential
safety significance or programmatic
nature of this event,
the inspector will perform
a detailed onsite
followup and evaluation of this
LER (LER 50-397/93-30,
Open).
No violations or deviations
were identified.
The inspectors
met with licensee
management
representatives
periodically
during the report period to discuss
inspection status,
and
an exit
meeting
was conducted with the indicated personnel
(refer to paragraph
1)
on January
31,
1994.
The scope of the inspection
and the
inspectors'indings,
as noted in this report,
were discussed
with and acknowledged
by the licensee
representatives.
The licensee
did not identify as proprietary
any of the information
reviewed
by or discussed
with the inspectors
during the inspection.