ML17291A869
| ML17291A869 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/15/1995 |
| From: | Powers D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17291A868 | List: |
| References | |
| 50-397-95-14, IEB-90-001, IEB-90-1, NUDOCS 9506230088 | |
| Download: ML17291A869 (30) | |
See also: IR 05000397/1995014
Text
ENCLOSURE
U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection
Report:
50-397/95-14
License:
Licensee:
Public Power Supply System
3000 George
Way
P.O.
Box 968,
MD 1023
Richland,
Facility Name:
Washington Nuclear Project-2
Inspection At:
Richland,
Inspection
Conducted:
April 24 through
May 23,
1995
Inspectors:
Lawrence
E. Ellershaw,
Reactor Inspector,
Maintenance
Branch
Division of Reactor Safety
Charles J.
Paulk,
Reactor
Inspector,
Maintenance
Branch
Division of Reactor Safety
John
E. Whittemore,
Reactor
Inspector,
Maintenance
Branch
Division of Reactor Safety
Approved:
r.
a
e
.
owers,
>e
,
a>ntenance
Branc
Division of Reactor Safety
oc/i~j'e ~
Date
Ins ection
Summar
Areas
Ins ected:
Routine,
announced
inspection of refueling
and inservice
inspection activities,
and licensee
response
to
Supplement
1,
"Loss of Fill-Oil in Transmitters
Manufactured
by Rosemount,"
in
accordance
with Temporary Instruction 2515/122,
"Evaluation of Rosemount
Pressure
Transmitter
Performance
and Licensee
Enhanced
Surveillance
Programs."
Also, followup was performed
on the securing of the residual
heat
removal
system while in the shutdown cooling mode.
Results:
Plant
0 erations
~
Excellent performance
was observed
during refueling operations.
Communications
were found to be effective
and very good
(Sections
2 and 3).
950b230088
950b19
ADOCK 05000397
9
~
The licensee
violated the Technical Specifications
by allowing shutdown
cooling to remain off for 25 minutes
more than permitted
by the
Technical Specifications.
This was
a noncited violation (Section 6.2).
Maintenance
~
Magnetic particle testing
was performed well by certified examiners
(Section 4,2).
~
A failure to implement procedures
for certifying qualification of
nondestructive
test personnel
was identified as
a noncited violation
(Section 4.3).
~
Procedures
for the performance of ultrasonic testing
were well written,
in general.
One example
was identified as
a noncited violation for not
adequately
addressing criteria for determining that important activities
had
been
accomplished
(Section 4.4).
With only one exception,
transmitter data
from calibrations required
by
the preventive
maintenance
program were found to be properly recorded
(Section 5.8).
En ineerin
~
There were strong technical
elements
in the
Rosemount transmitter
enhanced
surveillance
program (Section 5.3.2).
~
The transmitter trending program conservatively
exceeded
the scope
recommended
by the vendor
(Section 5.4).
~
The failure to question
or pursue missing or incomplete data for the
enhanced
surveillance
program
was
a weakness
(Section 5.7).
~
Licensee
actions related to the identification and disposition of failed
or failing transmitters
were conservative
(Section 5.9).
Plant
Su
ort
~
Foreign material controls
were good (Section 2).
~
Initial and continuing training provided to instrument
and control
technicians
regarding loss of fill-oil in Rosemount transmitters,
was
a
strength
(Section 5.3.2).
Mana ement Overview
~
The operations
manager
provided strong oversight
by his presence
on the
refueling bridge during refueling operations
and his guidance
given to
operators
during off-normal working hours
(Sections
2 and 3),
0
Summar
of Ins ection Findin s:
~
Three
examples of noncited violations were identified (Sections
4.3,
4.4,
and 6.2).
~
Inspection
Followup Item 397/9514-01
was opened
(Section 5.8).
Attachments:
~
Attachment
1
Persons
Contacted
and Exit Meeting
~
Attachment
2 - Data Required
by Temporary Instruction 2515/122
DETAILS
1
PLANT STATUS
During this inspection period,
the plant was
shutdown for the tenth refueling
outage.
2
REFUELING ACTIVITIES (60710)
The purpose of this part of the inspection
was to ascertain
whether refueling
activities were being controlled
and conducted
by operations
in accordance
with Technical Specifications,
approved
procedures,
and safe practices.
The inspectors
observed
on four different shifts of operators
during this inspection.
The inspectors
found that the required Technical
Specifications
and administrative
procedures
were followed.
Prior to the
commencement
of core alterations,
contractor-supplied
personnel
performed hydrolasing
on the feedwater
nozzles to reduce radiation levels.
The inspectors
observed this activity and noted that the procedure
was being
followed by the workers.
In order to ascertain
whether the procedures
were being properly implemented,
the inspectors
reviewed the fuel handling
and service
procedures,
and the
refueling operations
procedures.
The inspectors
also reviewed the procedure
for foreign material control.
The procedures
were:
Procedure
1.3.18
2.14.1
6.3.2
6.3.5
6.3.28
Title
Foreign Material Control Around the
Spent
Fuel
Pool, the Reactor Cavity
and the Dryer-Separator
Pit
Refueling Hridge Operation
Fuel Shuffling and/or Offloading and
Reloading
Full Core Verification
Nuclear
Component Transfer List
Preparation
Revision
Date of Issue
12
April 12,
1995
April 27,
1995
April 26,
1995
7
May 10,
1994
2
February
27,
1995
7.4.9.6
Refuel Platform Crane
and Hoist
Interlock Surveillance
13
April 27,
1995
The inspectors
observed
excellent
performance
by the operators
on the bridge
during core alterations.
The communications
were very good;
repeat
backs
were
used effectively.
Whenever
an operator
had
a question related to the core
alteration, activities stopped until the question
was resolved.
The
inspectors
observed
the operations
manager
inform the operators
that they
should ensure that they understood
exactly what was being done; if not, then
they were to stop
and resolve the issue.
The operations
manager told the
senior reactor operator not to worry about the schedule,
but ensure
the
activities were performed properly.
The inspectors
also observed
from the control
room.
The
operator
assigned
to the core alterations
had
no concurrent responsibilities
and
was keeping the control
room supervisor
informed.
At one point, the
control
room supervisor
stopped
because
the containment
pressure
had dropped
below the Technical Specification allowable for
approximately
30 seconds
while the ventilation was shifted from the standby
gas treatment
system to normal containment ventilation.
The control
room
supervisor did not allow core alterations
to restart until the ventilation
system
was returned to normal with acceptable
containment
pressure.
The
inspectors
considered
these
actions
proper
and conservative.
The inspectors
found the control of foreign material
to have
been very good in
spite of a procedure that was difficult to implement.
On April 27,
1995,
an
operator
on the refueling floor initiated
a problem evaluation
request that
identified components
that were not secured
on the bridge in accordance
with
Procedure
1.3. 18.
The inspectors
observed
the operator take the immediate
corrective actions
before bridge activities were allowed to continue.
The inspectors
discussed
the responsibilities
of the foreign material control
watch person with several
of the watch standers.
Host of the watch standers
were familiar with the intent of the procedure,
but stated that they had
questioned
how they were to implement portions of the procedure.
The areas of
most concern
were documenting
what material
was in the foreign material
control
zone
and
who was responsible
for it.
The inspectors
discussed
this
with the reactor engineering
manager
who was responsible for the refueling
activities.
The inspectors
found that the reactor engineering
manager
was
aware of the difficulties and that improvements
were being discussed
and
evaluated
as part of the response
to the problem evaluation request.
The
inspectors
considered this to have
been the proper approach to resolving the
difficulties experienced
by the watch standers.
3
SPENT
FUEL POOL ACTIVITIES (86700)
The purpose of this part of the inspection
was to ascertain
that the spent
fuel handling activities were performed in accordance
with Technical
Specifications,
regulatory requirements,
and safe practices.
The inspectors
observed
the manipulation of spent
and
new fuel in the spent
fuel pool.
In order to determine if the operation
was in accordance
with
procedures,
the inspectors
reviewed the following procedures
related to
handling fuel assemblies
in the spent fuel pool.
Procedure
No.
1.3.40
Title
WNP-2 Outage
Mode Change or
Refueling Activity Readiness
Evaluation
Revision
Date of Issue
6
April 24,
1995
2.8.5
6.3.10
6,3.16
6.3.23
Handling Irradiated
Fuel in the
Spent
Fuel
Pool
3
April 26,
1995
Fuel
Pool Cooling and Cleanup
System
19
January
10,
1995
Post Irradiated
Fuel Surveillance
4
May 10,
1994
Irradiated
Fuel
Channel
Inspection
2
June
15,
1993
The inspectors verified that the procedures
contained:
a limitation on the
number of fuel assemblies
that could
be out of safe
geometry locations
simultaneously
(Procedure
6.3.23); provisions for verifying that the spent
fuel storage
area
crane interlocks or physical
stops
prevented
the crane
from
passing
over fuel storage
positions
(Procedure 6.3.2); provisions for
verifying that the spent fuel pit hoist
and related
handling tools were
checked for proper operation
(Procedure 6.3.2); verification that procedures
did not rely on limit switches to function as normal stopping devices
(Procedure
2. 14
F 1); and, provisions to verify that the spent fuel area
ventilation system
was operating
as required, that the efficiency of the
absolute
and charcoal filter systems
had
been determined,
that secondary
containment
would isolate
on
a high radiation signal, that the minimum water
level requirements
were monitored,
and that radiation
and airborne
radioactivity monitors were operable
(Procedure
1.3.40).
The inspectors
noted
that the spent fuel pool cooling
and cleanup
system
was not
a system required
specifically by the Technical Specifications.
These
systems
were operated
in
accordance
with Procedure
2.8.5,
"Fuel
Pool Cooling and Cleanup
System,"
Revisibn
19,
issued
January
10,
1995.
The inspectors verified by direct observation that:
the spent fuel pool water
level
was higher than the minimum level established
in the Technical
Specifications;
the secondary
containment ventilation system maintained
the
building at the specified negative
pressure,
except
as discussed
above;
the
spent fuel pool cooling and cleanup
system
was maintaining pool temperature;
personnel
handling fuel were properly qualified and supervised;
fuel handling
activities received
reviews required
by the Technical Specifications;
an
accurate
record of the fuel location
was being maintained;
and,
spent fuel
pool activities were conducted
in accordance
with approved
procedures.
The inspectors
observed
the
same excellence,
noted
above,
in the handling of
fuel assemblies
in the spent fuel pool.
Communications
were very good
among
the operators.
On April 7,
1995,
the Washington Public Power Supply System sent
a letter of
notification of a change
in commitment to the
NRC.
The change
was to perform
visual inspection
only on discharged
fuel where there
was indication of either
actual
or suspected
gross cladding defects
or anomalies.
This differed from
the previous
commitment to perform
a visual inspection
on
5 to
10 percent of
the highest
burnup assemblies
of the discharged
fuel,
The inspectors
reviewed the last three reports for the inspections
and found
that
no problems
were identified.
A reactor engineer
informed the inspectors
that there
had not been
any fuel failures since the original (Cycle 1) fuel
had
been replaced.
The inspectors
also reviewed
Procedure
6.3. 10,
"Post Irradiated
Fuel
Surveillance,"
Revision 4,
issued
May 10,
1994,
and Procedure
6,3. 16,
" Irradiated
Fuel
Channel
Inspection,"
Revision 2,
issued
June
15,
1993.
The inspectors
found the procedures
provided adequate
instructions for the
inspection of the irradiated fuel assemblies
and channels.
The inspectors
inquired about the licensee
plans to change fuel vendors
and
how that could affect the change
in commitment.
The inspectors
were informed
that fuel from the
new vendor
had
been installed for several
operating cycles
and
had
been
inspected
during the refueling outages.
No indications of
excessive
crud or oxide layer buildup were found during any of the
inspections.
The reactor engineer
considered
those inspections
to have
been
adequate
to demonstrate
that there
should not be any problems
when
a full core
load of the
new fuel occurs,
therefore,
the change
in commitment should not
have
a negative effect
on safety.
The inspectors
found this deduction to be
reasonable.
4
INSERVICE INSPECTION (73753)
The objective of this part of the inspection
was to determine
whether
inservice inspection
examinations
were performed in accordance
with Technical
Specifications
and the American Society of Mechanical
Engineers
(ASME) Boiler
and Pressure
Vessel
Code.
The inspection
was primarily conducted with major emphasis
placed
on
observation of examination
performance,
nondestructive
examination
personnel
qualifications,
and evaluation of nondestructive
examination
procedures.
Minor emphasis
was placed
on the inservice inspection
program status.
4.1
Inservice
Ins ection
Pro
ram
The second
10-year interval inservice inspection
program plan, "ISI Program
Plan,
Interval
2," Revision 0, dated
December
1994,
in effect at the time of
this inspection,
was developed
to meet the
1989 Edition of Section
XI of the
ASME Code.
The inspectors
found that guidance for implementation of the
inservice inspection
program was provided in Nuclear Operating
Standards
NOS-33,
" Inservice Inspection,"
Revision 7;
and Engineering
Directorate
Procedure
EDP-4.4,
"Preparation of Inservice
Inspection
Program
Plans,"
Revision
5.
The inspectors
also noted that Section
2.0 of the
qualification and certification program, "gualification/Certification of
Examination
Personnel
in Accordance with SNT-TC-lA for Nondestructive
Examination," Revision 9, contained
the guidance
and responsibilities for
personnel
certifications,
and is discussed
in more detail
below (Section 4.3).
4.2
Observation of Nondestructive
Examinations
The inspectors
observed
the following weld examinations:
magnetic particle
examination of main steam line pipe to Elbow Weld 26HS(1)A-6 on April 28,
1995; magnetic particle examination of main steam line penetration
pipe to
Valve Weld 26MS(1)A-17,
on May 1,
1995;
two ultrasonic examinations
of reactor
feedwater line pipe to Elbow Weld 12RFW(1)AC-6 and elbow to Pipe
Weld,12RFW(1)AC-7,
on Hay 1,
1995; three ultrasonic examinations
of main steam
line penetration
pipe to Valve Weld 26MS(1)A-17, valve to Pipe
Weld 26HS(1)A-18,
and pipe to Pipe
Weld 26HS(1)A-19,
on Hay 2,
1995;
and,
three ultrasonic examinations
of reactor feedwater line pipe to Valve
Weld 24RFW(1)A-lA, valve to Pipe
Weld 24RFW(1)A-1,
and pipe to Weldolet
Weld 24RFW(1)A-1/5RFW(11)-4,
on Hay 2,
1995.
The observed
magnetic particle examinations
were performed well by certified
examiners
using qualified Nondestructive
Examination
& Inspection
Instruction gCI 4-3,
"Magnetic Particle
Examination
WNP-2," Revision
6 (see
Section 4.4 below).
The examiners verified the yoke-lifting capacity
and
established
the yoke-leg spacing at
6 inches.
Upon completion of the
examinations,
the examiners
properly documented
the results of the
examinations
in Examination Reports
2MSH-010 and
The eight observed ultrasonic examinations
were performed
by certified
examiners
using qualified Nondestructive
Examination
& Inspection
Instruction gCI 6-13, "Ultrasonic Examination of Ferritic Steel
Piping Welds,"
Revision
7
(See Section 4.4 below).
The inspectors verified that the
examiners
checked
surface
temperature
and assured
proper cleanliness
of the
area to be examined.
To the extent that geometry allowed, the examinations of
the circumferential
welds were conducted
in two directions for each of the
perpendicular
and parallel
scans
to the weld axis,
using
a 45~,
2.25
MHz shear
wave transducer.
The examiners
also performed
a calibration check at the
beginning
and
end of each examination.
Upon completion of the examination,
the examiners
properly documented
the results
in Examination
Reports
2-011
through 2-018.
Before the ultrasonic examinations
were conducted
on Hay 1,
1995,
the
inspectors
observed
the system calibration which included both axial
and
circumferential
scans.
The transducer
selection,
sensitivity calibration,
and
construction of the distance
amplitude correction curve were performed
appropriately in accordance
with the procedure.
The inspectors
also verified,
by review of the certified material test report, that the correct calibration
block was
used (i.e., similar to the component to be examined
in terms of
material,
diameter,
and wall thickness).
During observation of ultrasonic examinations,
two instances
arose
which
appeared
to indicate confusion
on the part of certain
examiners
regarding
what
constituted
a recordable
indication.
On two separate
occasions,
the
inspectors
questioned
the examiners
when it appeared
that indications of
approximately
50 percent of the distance
amplitude correction curve were
observed
on the scope without any apparent
actions
taken
by the examiners
to
determine
whether the indications
were of geometric or metallurgical origin.
Both examiners
stated that they considered
the indications to be geometric in
nature.
Upon questioning
by the inspectors
about the observations,
the
examiners
took appropriate
measurements/recordings
in order for the required
determinations
to be made.
The inspectors
reviewed the subsequent
evaluations
of the examiners'ata,
which included reexamination
using
a 60'ransducer.
The Level III examiner for the plant determined that the indications were of
geometric origin,
and validated the examiners'nderstandings.
Further review
of the procedure
by the inspectors
indicated
weaknesses
which are described
below (see Section 4.4,
below).
4.3
Personnel
ualifications
and Certifications
The inspectors
were informed that the licensee
had contracted with a vendor to
provide nondestructive
examination
personnel,
equipment,
and services,
in
order to perform the scheduled
inservice inspections.
The inspectors
reviewed
the qualification files of the five nondestructive
examination
personnel
who
performed the examinations
observed
by the inspectors.
The files contained
proper certifications for the examiners
in the examination
methods that the
inspectors
observed.
The inspectors
also noted that the examiners
had
been
certified in accordance
with American Society of Nondestructive
Testing
Recommended
Practice
SNT-TC-IA, 1984.
The inspectors verified that each of the examiners
had received
the
ASHE
Code-required
annual
near-distance
vision acuity and color vision
examinations.
The examinations,
all of which were current,
had
been
conducted
by the vendor.
Each of the examiners'ertification
packages
had
been
reviewed
and certified by the corporate certification examiner in accordance
with paragraph
3', "Responsibility," of the qualification and certification
program manual.
Paragraph
IWA-2321, in Section
XI of the
1989 Edition of the
ASHE Code,
stated
that personnel
shall
demonstrate
natural
or corrected
near-distance
acuity,
with at least
one eye,
by reading the Jaeger
No.
1 print on
a Jaeger test
chart at not less
than
12 inches.
Equivalent measures
of near-distance
acuity
may be used (e.g.,
Ortho-Rater test).
During review of the vision records,
the inspectors
noted that three records
were not consistent
with ASHE Code
requirements (i.e.,
they
showed results that did not demonstrate
Jaeger
No.
1
natural
or corrected
near-distance
acuity).
The inspectors,
in order to
-10-
determine
the review and acceptance
standards
associated
with contractor
personnel
certifications,
reviewed
paragraph
4.4, "Vision Examination," in the
qualification and certification program manual,
and found the vision
examination
requirements
to be different from the
1989 Edition of the
Code.
The inspectors
noted that the three vision records
mentioned
above
were
consistent with the requirements
of Paragraph
4.4 in the program manual,
which, during discussion
with the corporate certification examiner,
was found
to be the basis for his review and certification process.
The nondestructive
examination
supervisor
informed the inspectors
that
paragraph
4.4, "Vision Examination,"
was written to incorporate
ASME Code
Case
N-490-1, dated
Hay 13,
1991.
Review of the
Code
Case
showed that it provided
alternative vision test requirements
for nondestructive
examiners
in lieu of
Section
XI near-distance
acuity requirements.
The nondestructive
examination
supervisor stated that the code
case
was
supposed
to have
been
included in the
second
10-year interval inservice inspection
program at the time of submittal
to the
NRC; however,
the code
case
was inadvertently left out.
Since the
submitted inservice inspection
program
was developed
to meet the
1989 Edition
of the
ASHE Code,
any use of a code
case
not committed to in that submittal
has the potential to at least create
an administrative conflict.
Since the licensee
had established
and
implemented
a procedure that
incorporated
the
use of a code
case
not authorized
by their program,
indeterminate
vision examination results
were obtained
and accepted,
thus,
allowing examiners
who may not have
met the requirements
of the
1989 Edition
of the
ASHE Code to perform nondestructive
examinations.
The nondestructive
examination supervisor
on Hay 4,
1995, initiated the following two problem
evaluation requests.
Problem Evaluation
Request
295-0466
addressed
the issue of using
a code
case
that
had not been
committed to in the inservice inspection
program submitted
to the
NRC.
The corrective action
was to revise paragraph
4.4 Section
2.0 of
the qualification and certification program manual,
to remove the provisions
of Code
Case
N-490-1.
Problem Evaluation
Request
295-0467
addressed
the issue of the vendor's
use of
alternative vision examination
requirements
while testing the inservice
inspection
personnel,
and the failure to detect
the documented
use of the
alternative
requirements.
The nondestructive
examination
supervisor took
immediate corrective action
by stopping all nondestructive
examinations
and
administering
new vision examinations
to the affected personnel,
all of whom
passed.
The inspectors verified that the vision examinations
met the
requirements
of the
1989 Edition of the
ASHE Code.
The inspectors
informed the nondestructive
examination
supervisor that the use
of a procedure
not appropriate
to the circumstances
was
a violation of
Criterion
V to Appendix
B to
The violation, however, will not
be cited because
the criteria specified in Section VII.B.(l) of Appendix
C to
10 CFR Part 2 have
been met.
-11-
4.4
Inservice
Ins ection Procedures
The inspectors
reviewed the following nondestructive'examination
procedures,
including the two used during the performance of the observed
examinations,
to
verify that they were consistent
with the requirements
of the
1989 Edition of
the
ASME Code.
These
were:
Nondestructive
Examination
8 Inspection
Instructions
QCI 3-3, "Liquid Penetrant
Examination - WNP-2," Revision 5;
QCI 4-3,
"Magnetic Particle Examination - WNP-2," Revision 6;
and,
QCI 6-13,
"Ultrasonic Examination of Ferritic Steel
Piping Welds," Revision 7.
The
inspectors verified that the procedures
had
been
reviewed
and approved
by the
appropriate
licensee
personnel
and
by the authorized
nuclear inservice
inspector.
In general,
the procedures
were found to be well written and contained
sufficient detail
and instructions to perform the intended
examinations.
One
exception
was identified; it pertained
to ultrasonic examination
Procedure
QCI 6-13.
Mandatory Appendix III to Section
XI specified
minimum
information requirements
that must
be included in written ultrasonic
examination
procedures.
One of those
requirements
(Article III-2300 (g))
dealt with the data to be recorded,
the method of recording,
and,
by reference
( III-4510) the methodology to be used
in determining whether indications
were
of geometric or metallurgical origin.
The inspectors'eview
of
Procedure
QCI 6-13 revealed that Step 6.2. 1 required the recording of
geometric or metallurgical indications if they were
50 percent of distance
amplitude correction curve, or greater.
Step
6. 1.3 required the recording of
any other indications which were determined
not to be of geometrical
or
metallurgical origin, if they were
20 percent of distance
amplitude correction
curve, or greater.
However,
the procedure
was silent regarding
the
Code-required
methodology to make the determination
regarding geometric
or
metallurgical indications.
Upon informing the nondestructive
examination
supervisor of the apparent
procedural
deficiency,
the supervisor
immediately held
a documented training
session
with all of the inservice inspection
personnel
performing ultrasonic
examinations.
This session,
held
on May 2,
1995,
was devoted'o
the steps
in
Section 6.0 of Procedure
QCI 6-13, regarding clarification of recording
requirements
for consistent
application.
In addition,
a procedural
change
was
initiated to clarify the recording requirements
and to address
the
Code-required
indication interpretation
methodology.
The initiated procedure
change
was entered
and
was to be tracked in the plant tracking log under the
assigned
Number A-114645.
The inspectors,
after reviewing the inservice inspection status of completed
ultrasonic examinations
and discussing
the above
issues
with the examiners,
determined that the examiners
had complied with the procedure,
and
based
on
their experience,
had also applied the indication determination
methodology.
The inspectors
informed the nondestructive
examination
supervisor that the
use
of a procedure
which did not adequately
address criteria for determining that
important activities
have
been
accomplished
was
a second violation of
-12-
Criterion
V to Appendix
B to
The violation, however, will not
be cited because
the criteria specified in Section VII.B.(1) of Appendix
C to
10 CFR Part 2 have
been met.
5
EVALUATION OF
ROSEMOUNT
PRESSURE
TRANSMITTER PERFORMANCE
AND LICENSEE
ENHANCED SURVEILLANCE PROGRAM
(TEMPORARY INSTRUCTION 2515/122)
This portion of the inspection
was conducted
at the Washington Nuclear
Project-2 site
on May 15-19,
1995.
5.1
~Back round
On March 9,
1990,
the
NRC issued Bulletin 90-01,
"Loss of Fill-Oil in
Transmitters
Manufactured
by Rosemount."
The bulletin discussed
certain
Rosemount
pressure
and differential pressure
transmitter
models identified by
the manufacturer
as being susceptible
to fill-oil leakage,
which could result
in premature failure.
With the gradual
leakage of fill-oil, a transmitter
may not have the long-term
accuracy,
time response,
and reliability needed for its intended safety
function.
Further, this condition could go undetected
over
a long period.
The bulletin requested
licensees
to identify whether these transmitters
were,
or may later be, installed in safety-related
systems.
Actions were detailed
for licensee
implementation if the identified transmitters
were presently
installed in safety-related
systems.
This requested
action included
a
historical review of installed transmitter calibration data to identify any
potential failure of installed transmitters.
The bulletin endorsed
diagnostic
methodology
recommended
in four technical bulletins previously issued
by the
vendor.
On December
22,
1992,
the
NRC issued
Supplement
1, to
inform licensees
of continued
NRC staff and industry actions in evaluating
loss of fill-oil in Rosemount transmitters
and to request
actions to be taken
by licensees
to assure
the reliability of transmitters
in use.
Licensees
were
requested
to replace,
or place in an enhanced
surveillance
program
Model
1153B,
1153D,
and
1154 transmitters
manufactured
before July 11,
1989,
that were installed in safety-related
applications.
The purpose of the enhanced
surveillance
program
was to ensure that installed
Rosemount transmitters
met design criteria as highly reliable components
for
which failures could
be readily detected.
Pressure
transmitters
other than
Models
1153B,
1153D,
and
1154 were excluded
from the actions
requested
in the
supplement,
due primarily to few confirmed fill-oilloss failures
and
di-fferences in the oil sensor
design.
Similarly, due to transmitter design,
manufacturing
process
improvements,
and few confirmed failures,
Model
1153B,
1153D,
and
1154 transmitters,
which were manufactured after July 11,
1989,
were also excluded
from the bulletin supplement
actions.
Additional data
collected
on those transmitters
that are outside of the scope of the
supplement will be used to verify failure reports,
determine to what extent
-13-
licensees
notify Rosemount of transmitter failures,
and to confirm that the
actions
requested
by the bulletin supplement
are sufficient.
Model
1151,
1152,
and
1153A transmitters
were excluded
from the actions
requested
by Supplement
1 due primarily to the few confirmed fill-oilloss
failures
and differences
in the oil sensor
design
as
compared to Model
1153B,
1153D,
and
1154 transmitters.
These
design differences
were thought to make
Model
1151,
1152,
and
1153A transmitters
less likely to experience
loss of
fill-oilfailure.
However,
as
a result of a possible similar failure mode,
additional insight into their performance
was necessary
to confirm that their
inclusion in an enhanced
surveillance
program
was not needed.
Similarly, due
to transmitter design
and process
improvements
and few confirmed failures,
Model
1153B,
1153D,
and
1154 transmitters
manufactured
after July ll, 1989,
were excluded
from the list of bulletin supplement
actions.
For these
'ransmitters,
the information requested
in the inspection
guidance will be
used to verify failure reports,
determine
the extent to which licensees
notify
'osemount
of transmitter failures,
and confirm that actions
taken in the
bulletin supplement
were sufficient.
The Washington Nuclear .Project-2 licensee
response
to the bulletin supplement
was provided to the
NRC in Letter G02-93-055,
dated
March 8,
1993.
Response
to
a followup NRC request for additional
information was provided in
Letter G0-94-124,
dated
Hay 23,
1994.
In the initial response,
the licensee
committed to comply with requested
actions of the bulletin supplement.
5.2
Licensee
Dis osition of Stored Transmitters
The inspector
interviewed personnel
and reviewed procurement
records to
determine
how the licensee
had dispositioned
the transmitters,
stored
in the
warehouse,
with high potential for failure,
Personnel
stated that,
in
response
to the bulletin supplement,
a data
search
and inspections
were
conducted
to identify those transmitters
at high risk of failure.
According
to procurement
records that were provided,
a total of 13 transmitters
had
been
returned to the vendor since
was issued.
The majority of
these transmitters
were refurbished to eliminate the risk of failure and
returned to the licensee.
The licensee
was
asked for a list of all Rosemount transmitters
currently in
the warehouse.
A key word search
on the procurement
system database
provided
a list of all transmitters
plus spare parts provided
by Rosemount.
The
inspector
reviewed the list and determined that
a total of 80 Rosemount
Model
1153B
and
1153D transmitters
were currently in the warehouse.
According
to the information provided, there
were
no Rosemount
Model
1154 transmitters
in the warehouse.
Transmitters
manufactured after July 11,
1989,
were identified by serial
numbers greater
than 500,000
and transmitters
with serial
numbers
ending in
"A", were not at high risk of failure.
The licensee's
database
would not
provide spare transmitter serial
numbers
or date of manufacture.
The
inspector held
a discussion
with a licensee
representative
to determine
the
least intrusive method of checking
spare transmitter serial
numbers.
The
licensee
representative
agreed
to check receipt inspection
records
and provide
the inspector with the serial
numbers.
The inspector
stopped
the process
after the inspection
tags for 42 spare transmitters
had
been
checked
and all
serial
numbers verified to be greater
than 500,000 or ending in "A."
Based
on
this sample of 53 percent of the transmitters
in the warehouse,
with no
adverse
indication,
the inspector
concluded that all transmitters
at high risk
of failure had likely been
removed
from the licensee's
warehouse facilities.
5.3
Enhanced
Surveillance
Pro
ram
5.3. I
Background
In
a series of four technical bulletins issued
by Rosemount,
the required
elements of an enhanced
surveillance
program were developed.
These bulletins
became
appendices
to the
NRC inspection
guidance for addressing
the loss of
fill-oil issue.
The vendor segregated
inservice transmitters
into low,
medium, or high pressure
categories
and further subdivided inservice
transmitters
into two groups:
~
Transmitters that provided safety-related
indications;
and,
~
Safety-related
transmitters that monitored conditions
and initiated
reactor protection trip, engineered-safety
features
actuation,
and
anticipated trip without scram systems.
Therefore,
the enhanced
surveillance
requirements
for a given transmitter
were
determined
from the transmitter service
pressure
and its particular safety
function.
The affected
groups of transmitters
had
been identified by model
number
and
date of manufacture.
The vendor also determined that the risk of fill-oil
loss decreased
as the transmitters
aged in service at normal operating
pressure.
The vendor provided criteria expressed
in psi-months to identify
mature transmitters
that did not require
enhanced
surveillance.
The psi,
as
used
by the vendor,
was defined
as
normal operating pressure.
The threshold
criteria for ceasing
enhanced
surveillance
was the attainment of 60,000 or
130,000 psi-months,
depending
on transmitter
range
code.
Transmitters
not
attaining the required service life at operating
pressure
were classified
as
nonmature.
The following programmatic
elements
were generally
recommended
to effectively
monitor suspect
transmitters
in safety-related
service for impending failure:
The identification of the affected transmitters
to be monitored;
The trend of calibration data
on the percent shift of zero
and
span
(limits for percent shift up or down were established
to require
transmitter evaluation);
-15-
~
Comparative trending of operating
data
on the difference in the output
of redundant transmitters
(transmitter output differences
were to be
evaluated);
and,
~
The ability to detect failures after transmitters
were mature
and
no
longer included in an enhanced
surveillance
program.
Simultaneous
trending of operational
and calibrational
data for a given
transmitter
was not needed for failure identification.
The vendor technical
bulletins also discussed
monitoring methods
based
on the evaluation of
transmitter
sluggishness
or noise,
The required frequency of enhanced
surveillance varied according to the various inservice categories
and
operating
pressure.
5.3.2
Licensee
Program
The licensee's
enhanced
surveillance
program
was
implemented
by
Procedure
8.4.67,
"Rosemount Transmitter
Enhanced Monitoring," Revision 2.
The procedure
provided details in the following areas:
Trending Data Acquisition,
Calculation of Transmitter Drift,
Calculation of Transmitter Drift Limits,
Transmitter Trending,
Determination of Suspected
Oil-Loss Transmitters,
and
Actions for Suspected
Oil-Loss Transmitters.
The inspector
reviewed the procedure
and found it to be comprehensive
with
sufficient detail to administer
an effective program.
A review of the two
previous revisions revealed that the original program
had
been
improved.
The
first revision implemented
an .automatic trending
system
and enhanced
trending
evaluation technique.
The latest revision
had
added
program information,
added cautions for specific range
code instruments,
improved database
instructions,
and streamlined
instructions for determination of drift limits
and analysis of transmitter condition.
The enhanced
surveillance
program
was administered
by one engineer
who had
been responsible for all program
and database
development
and implementation
since inception.
Due to
a previous
commitment, this individual was not
available during the week of the inspection.
However,
the immediate
supervisor
was able to provide all of the information and documentation
necessary
to perform the inspection.
The inspector requested,
and
was given,
a demonstration
of the automated
trending database
that was
used to trend
individual transmitter calibration data.
The data required for a single
transmitter calibration entry was the date
and the transmitter output for the
minimum and
maximum points as-found
and as-left values.
With this information
in the data
base for at least
two calibrations,
the program would
automatically calculate
the interval
between
data entries,
percent
zero shift,
and percent
span shift since the last entry.
The cumulative shift since the
-16-
start of data collection was also trended
and tracked.
For analytical
purposes,
the system would provide hard copy tabular
and graphic information.
Graphic
and tabular depiction also included the
span
and zero shift limits for
the specific transmitter
range
code
as developed
in the vendor technical
bulletins.
According to
a licensee
representative,
the automated
trending
program
had
been
endorsed
by the vendor
as fully capable of providing the
required analytical
informat'on.
The inspector
reviewed documentation
and held discussions
with maintenance
training personnel
to assess
the effectiveness
of training that
had
been
provided to instrument
and control technicians relative to loss of fill-oil
from Rosemount transmitters.
According to records
provided, significant
training was developed
and administered
to technicians prior to issuance
of
NRC Bulletin 90-01., All technicians
(47) attended
an industry events training
presentation
provided in Lesson
Plan 82-14-3789-LP.
Since the bulletin was
issued,
the Rosemount transmitter loss of fill-oil issue
had
been
included in
the New-Hire Training Course
82-ICT-1201-LP.
This course
was recently
administered
to
a majority of current technicians
as continuing training.
The maintenance
training organization
had developed,
and put,into operation,
a
hands-on
laboratory facility containing test loops with actual
components
and
instrumentation.
This training facility was
used
by all disciplines to
actually troubleshoot,
repair,
overhaul,
and calibrate
equipment similar or
identical to that installed in the plant.
Formal training packages
had
been
developed
to train and evaluate
personnel
in the laboratory.
Course 82-ICT-4100-LP,
"Maintenance
Work Practices,"
contained
a scenario that
required
a trainee to perform
a calibration
on
an instrument loop that
contained
a Rosemount transmitter..
A laboratory guide contained evaluation
elements that evaluated
trainee ability to identify a transmitter failure due
to loss of fill-oil.
The inspector
was also
shown documentation
related to training operations
personnel
about the loss of fill-oil issue.
The continuing training program
for licensed
and non-licensed
operators
had resulted
in the administration of
training through the periodic industry events presentations.
The training that the licensee
had provided to technicians
was more
comprehensive
than similar training observed
by the inspector at other
facilities.
In addition, the technical
elements of the enhanced
surveillance
program were strong.
5.4
Sco
e of Trendin
Pro ram
The Washington Nuclear Project-2
program
was currently trending
62
transmitters that
had
been identified by the bulletin supplement
to be at high
risk of failure.
The inspector verified that these transmitters
had
been
placed into the correct surveillance
category
in accordance
with the
recommendations
of the bulletin supplement.
The licensee
had decided
not to
replace,
or return to the vendor for refurbishment,
the originally installed
transmitters.
Therefore, all of the transmitters
identified to be at
increased risk of failure were being trended.
However, all but one of these
-17-
transmitters
could have
been
removed
from the enhanced
surveillance
program
because
they were in a low-pressure
application or had matured
past
60,000 or
130,000 psi-months.
To remove these transmitters
from enhanced
surveillance,
required the licensee
to have the ability to identify a transmitter failure
within the normal activities associated
with transmitter maintenance
or
surveillance,
which was within the licensee's
capabilities.
The inspector
determined that the licensee's
program
was also trending
and
analyzing:
~
26 Model
1153B
and
1153D transmitters
manufactured after July 11,
1989,
in safety-related
applications
and not at risk of failure;
~
35 Model
1151 transmitters;
and
~
3 Model
1152 transmitters.
The licensee's
effort exceeded
the scope
recommended
by the bulletin
supplement.
5.5
Test Interval
All transmitters
subject to calibration data trending in accordance
with the
bulletin supplement fell into categories
where the
recommended
interval
between data collection was
24 months.
However,
a significant fraction of
transmitters
were being trended
annually simply because
annual
data
was
available.
Therefore, all test intervals
were meeting the recommendations
of
the bulletin supplement.
5.6
Monitorin
Techni
ues
Rosemount Inc., developed
methods with guidelines to independently
or in
combination, identify transmitters
suspected
of oil loss.
This section
discusses
the licensee's
implementation of those
methods.
5'. 1
Process
Noise Analysis
Because of interpretation difficulties and
a lack of universal applicability
due to differences
in transmitter application,
the vendor discontinued
the
development
in the use of noise
as
a diagnostic tool.
The licensee
did not
include this monitoring technique
in the enhanced
monitoring program to detect
loss of fill-oil.
5.6.2
Output Drift Analysis
There were two options for output drift analysis.
Normal calibration data
(as-found
versus as-left data)
could be evaluated
to determine
any cumulative
positive or negative drift trends.
Also, trending
and comparison of actual
operating
data
on processes
with redundant transmitters,
could identify
-18-
suspect
transmitters.
Both techniques
were field tested
and
showed the
ability to detect leaking sensors.
The licensee
did not employ any operating
data trending,
but relied
on calibration data trending to predict or identify
transmitter failure.
5.6.3
Sluggish
Response
Sluggish
response
of transmitters
was detectable
with two optional
methods.
One
was
a qualitative test where experienced
technicians
could detect
slow
response
during normal calibration
by monitoring transmitter output while
simulating
a process
input.
Additionally,
a bench test could
be performed
on
suspect
units to confirm and quantify the slow response,
The vendor technical
bulletins stated that monitoring for sluggish
response
was
an acceptable
method of detecting
a failed transmitter after it was
removed
from an enhanced
surveillance
program.
5.6.4
Licensee
Methodology
Procedure
10.24.32,
"PH CAL/TEST - Rosemount
DP Transmitters,"
Revision 9,
required the calibrating technician to identify and report
any sluggish
behavior of transmitter output during calibration.
The procedure for
Rosemount transmitter calibration also required that transmitter output'e
measured directly at the transmitter.
This required the removal of
transmitter
end covers to expose transmitter test terminal's which opened
an
environmentally qualified barrier
on transmitters potentially subject to
a
harsh environment.
The procedure
addressed
this issue
by providing
instructions
on evaluating
and properly restoring the barrier following
successful
calibration.
The inspector
concluded that the licensee
was
employing the proper monitoring techniques
needed to detect failed or failing
transmitters.
5.7
Review and Trendin
of Calibration Data
The inspector
reviewed the trended calibration data
and analysis for the
original
62 transmitters
that were identified as susceptible
to failure,
according to the supplement.
The amount of data collected for most
transmitters
was sufficient to provide for statistically valid trends.
The
implementing procedure
contained
acceptance
for transmitter drift that
mimicked the criteria specified
by the vendor technical bulletin.
A question
arose
concerning
the accuracy of the data trended.
Technical
information from the vendor
recommended
that transmitter output data
be
recorded
and trended
using milliampere fractions to three decimal
places.
The
licensee's
program
used milliampere fractions normally expressed
to two
decimal
places.
The licensee
had queried the vendor
as to the
adequacy
of
this process for identifying failed or failing transmitters.
The vendor
responded
that transmitter output data
measured
at the transmitter in two
decimal
place fractions
and inserted into the automatic trending database
was
sufficiently accurate
to identify failures.
The inspector
concluded that the
-19-
trending of calibration data
was being performed in accordance
with Rosemount
Technical Bulletin No. 4.
During the extensive
review of the hardcopy trending information, the
inspector raised
several
questions
about specific transmitter trending
and
analysis
to the licensee
representatives.
The majority of these
questions
were related to excessive
elapsed
time between
data entries
and past
due or
missing calibration data.
The inspector questioned if the required
surveillance
or preventive maintenance
performed
by the calibration
performance
had
been missed.
Based
on the reaction of licensee
personnel, it
appeared
to the inspector that these
questions
had not been
asked before.
Personnel
were eventually able to locate the missing data or explain
irregularities in the information.
However, this indicated the lack of a
questioning attitude about missing or incomplete data that was required to be
processed
by the licensee's
program.
This was considered
a weakness.
5.8
Rosemount
Transmitters Calibration Procedure
Review
The opportunity did not arise for the inspector to observe
the performance of
a transmitter calibration.
Therefore,
a sample of recently completed
calibration procedures
and master
data
sheets
was reviewed.
The inspector
also reviewed
Procedure
10.24. 1,
"ILC [Instrumentation
and Control] Data
Record Compilation
and Filing," Revision 9.
This procedure
provided guidance
on using, recording,
and handling documentation
related to plant instrument
calibration
and setpoint adjustment.
For those
completed calibrations
reviewed,
the inspector
noted that the transmitter data
was never entered
onto
the master data sheet.
Only loop component
data
was recorded
on the master
data sheet.
Transmitter da'ta
was recorded
on the i'nstrument work sheet.
An irregularity was noted in the recent
loop calibration for
Transmitter
SLC-PT-4,
which was the instrument
loop for the discharge
pressure
of the standby liquid control
pump.
Licensee
personnel
identified the
irregularity as they were delivering and explaining the documentation
to the
inspector.
Loop calibration
was
a refueling frequency preventive
maintenance
task.
According to the data provided,
the instrument
had
been calibrated
on
March 2,
1995, to meet
a due date of March 5,
1995.
The stated late date
was
July 9,
1995,
The exact problem noted
was that the transmitter output data
had not been
recorded
as required
by Step 6. 1.8 of Procedure
10.24.32.
Data
had
been recorded for the other loop components
identified as
a pressure
indicator and
a p'lant computer point input, but the required data for the
transmitter
was missing.
The inspector
asked
the licensee
personnel
who had provided the documentation
how they intended to correct this deficiency.
They responded
that they would
initiate
a problem evaluation request
and allow the corrective action
system
to identify the specific problem(s)
and provide detailed specific
and generic
corrective action.
In
a later conversation
with management,
the inspector
was
informed that the transmitter output as-found
and as-left data existed
in
other documentation
but had not been transcribed
to the final documentation
package.
The inspector believed that the method of recording calibration data
-20-
was probably
a factor in this oversight.
The
NRC followup on the licensee's
actions to resolve this item will be tracked
as Inspection
Followup Item
397/9514-01.
5.9
Transmitter Failure Anal sis
and
Re ortin
The licensee's
program
had identified potentially failing transmitters
in the
past.
According to documentation
provided,
the licensee
had returned six of
the transmitters,
which had
a high potential for failure, to the vendor for
verification of loss of fill-oil. Three of these
were confirmed
as failed or
failing due to loss of fill-oil. During the current outage,
a suspected
transmitter
was being replaced
and returned to the vendor for evaluation.
The
vendor
had not been consulted prior to the decision to replace
the transmitter
due to the important function of the transmitter.
Recently,
the licensee
had
requested
the vendor to evaluate
the trended
data of a transmitter
suspected
of failing.
The vendor determined that the transmitter
was not failing and
further provided information that the present
rate of drift would not affect
transmitter
performance
in the near future.
Based
on the above,
the licensee
had
a policy of returning transmitters
suspected
of failure to the vendor for analysis.
Also, the programmatic
criteria that
had
been
developed
to identify failed transmitters
was
conservative,
and actions
taken
by the licensee staff related to the
identification of failed or failing transmitters
tended to be conservative.
6
PROMPT ONSITE RESPONSE
TO EVENTS AT OPERATING
POWER
REACTORS (93702)
This portion of the inspection
was conducted
during the period
Hay 19-23,
1995
at the Washington
Nuclear Project-2 site
and in the Region
IV office.
6.1
~Back round
On Hay 12,
1995,
the licensee's
operating
crew failed to maintain residual
heat
removal
system
shutdown cooling as required
by Technical Specification 3.9. 11. 1.
The specification required that shutdown cooling flow
be maintained
and restored
in
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> if lost.
The requirement for maintaining
flow was modified to allow flow to be stopped for up to
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
period for any reason
determined to be necessary.
An inspector followed up on
the event to assess
the licensee's initial assessment
and preliminary
corrective action.
Following is
a sequence
of significant events describing
what occurred during the morning of Hay 12,
1995:
TIHf
ACTIVITY
0343
Shut off Loop A of the residual
heat
removal
system in the shutdown
cooling mode to support reactor pressure
vessel
inspection
activities.
-21-
0518
Started
Loop
B of the residual
heat
removal
system in the shutdown
cooling mode.
&815
A message
was put out in the daily outage
meeting that shutdown
cooling should
be secured
at 0930 to support
more vessel
inspection
activity.
0845
Shift Manager returned to control
room and told operators
that
shutdown cooling was to be secured
at 0930.
M855
Shift Manager left the control
room to perform other assigned
duties.
0951
Shutdown cooling secured.
1121
Restarted
Loop
B of the residual
heat
removal
system
in the shutdown
cooling mode.
Within minutes of restoring
shutdown cooling following the second
shutdown,
the control
room operating
crew reviewed the log and determined that shutdown
cooling was secured for a total of 185 minutes during the rolling 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
period between
0343
and
1143.
This time exceeded
the 2-hour limit plus the
1
hour allowance for recovery in Technical Specification 3.9. 11. 1.
Problem
Evaluation
Request
295-0546
was initiated at
1125 prior to the
end of the
rolling 8-hour period.
Additionally, licensee
management
immediately
initiated
a review in accordance
with Procedure
1. 1.8,
" Incident Review
Board," Revision 3.
6. 2
~Fol 1 owo
The inspector
reviewed documentation
and interviewed personnel
to evaluate
the
licensee's initial assessment
of the event.
Inservice inspection
personnel
were interviewed to ascertain
the nature of the vessel
inspection activity and
verify that it was necessary
to stop
shutdown cooling flow.
The inspector
determined that contractor personnel
were performing activities in accordance
with General Electric Nuclear
Energy Procedure
ADM-WNP-2-1022VO,
"WNP-2 Shroud
OD Inspectability Study," Revision 0.
This procedure
had
been
approved
by the
licensee for the contractor to use in order to determine
the accessibility for
a detailed ultrasonic examination of vessel
shroud peripheral
welds currently
scheduled for the next refueling outage.
The study methodology consisted of
using long handled
go/no-go
gages to measure
access
to areas of concern.
A
very high resolution color video camera
was used to observe
the available
clearance
as the gages
were inserted into the spaces
being measured,
The
camera
was very light, tethered
only by
a single line and, therefore,
easily
affected
by any flow in the annulus
between
the vessel
and shroud.
The
inspector
viewed video from the camera
in a situation with shutdown cooling
flow present,
and agreed that flow stoppage
was necessary
to obtain the needed
information.
Within a short time the licensee
incident review board determined
the
following facts regarding the event:
-22-
~
The iteration of stopping
shutdown cooling for vessel
inspection
had
been going on for several
days;
~
No individual or position was specifically assigned
to track shutdown
cooling off time;
~
There
was only an informal method of determining
when shutdown cooling
could
be shut
down;
~
The crew, supervisor,
and manager
were fully aware of the Technical
Specification;
~
The crew was supporting
several activities associated
with the outage;
and,
~
Management
oversight did not question
shutdown cooling previously being
secured..
The incident review board
made the following recommendations:
~
Clearly identify responsibility for tracking shutdown cooling off time
and verifying shutdown/restart
times prior to stopping;
Establish
a formal method for tracking shutdown cooling off time;
Identify any other issues
being similarly informally tracked
and
establish
clear responsibilities
(this may extend
beyond operations);
and>
~
Planning
and scheduling
should schedule
windows for shutdown cooling
outages
and other evolutions
such
as entering
the drywell exclusion
area.
Soon after the event,
the licensee
operations
department
made temporary
changes
to the procedure for logs
and operating
data requiring the shutdown
cooling off time to be tracked in the control
room logs.
On May 19,
1995,
Procedure
3. 1. 10, "Operating
Data
and Logs," Revision 4, underwent
a major
revision.
The inspector
reviewed Revision
5 of the procedure
and noted that
the control
room log had
been
changed
to include
a sheet for logging and
tracking of the residual
heat
removal
system in the shutdown cooling mode for
operating
Nodes
4 and 5.
The inspector
concluded that the licensee's
immediate action
was adequate
to
address
immediate
concerns
and prevent recurrence.
A detailed analysis
was
planned to be performed in conjunction with the problem evaluation report that
had
been initiated in response
to the event.
The licensee's
self-
identification of the issue, initiation of prompt corrective action to prevent
recurrence,
and the addressing
of generic implications met the requirements
of
Section VII.B.(1) of Appendix
C to
10 CFR Part 2 for discretion.
Therefore,
-23-
the violation of Washington Nuclear Project-2 Technical Specification 3.9. 11. 1
will not be cited.
ATTACHMENT 1
PERSONS
CONTACTED AND EXIT MEETING
1
PERSONS
CONTACTED
Washin ton Public Power
Su
l
S stem
1D
2D
'R.
2p
lp
'A.
2C
'C.
lT
2J
'T.
'M.
'A.
lg
2V
2p
'M.
1D
'C.
1,2g
1D
1D
'H.
lL
1.2
Atkinson, Manager,
Reactor/Fuel
Engineering
Becker,
Supervisor,
Engineering
Barbee,
Manager,
System Engineering
Bemis,
Manager,
Regulatory
Programs
Bentrup, Station Nuclear Engineer
.
Chiang, Principal
Engineer
Foley, Licensing Engineer
King, Acting Manager,
Materials
and Inspection
Love, Manager,
Chemistry
HcDonald,
Manager,
Technical
Services
Heade,
Manager,
Technical
Programs
Honopoli, Manager,
Maintenance
Hoore, Acting Hanager,
Analytical Support
Muth, Manager,
Plant Assessments
Parrish,
Vice President,
Nuclear Operations
Powell, Licensing Engineer
Pratt,
Operations
Ramey,
In-Service Inspection
Engineer
Reddemann,
Manager,
Technical
Services
Division
Schwarz,
Hanager,
Operations
Swailes,
Plant Manager
Swank,
Manager,
Licensing
Welch, Supervisor,
Non-Destructive Examination/I
Widmeyer, Supervisor,
Performance
Monitoring
Woosley, guality Assurance
Engineer
Nuclear
Re ulator
Commission
n-Service
Inspection
'R.
2J
2D
2p
Barr, Senior Resident
Inspector
Dyer, Deputy Director, Division of Reactor Projects
Proulx, Resident
Inspector
gualls,
Reactor
Inspector
In addition to the personnel
listed above,
the inspectors
contacted
other
personnel
during this inspection period.
'Denotes
attendance
at the exit meeting
on May 3,
1995.
'Denotes
attendance
at the exit meeting
on May 18,
1995.
2
EXIT MEETING
An exit meeting
was conducted
on May 3,
1995, to discuss
the findings related
to in-service inspection
and fuel handling.
During this meeting,
the
inspectors
reviewed the scope
and findings of the report.
The licensee
did
not express
a position
on the inspection findings related to in-service
inspection
and fuel handling documented
in this report.
Another exit meeting
was conducted
on
May 18,
1995, to discuss
the findings
related to Temporary Instruction 2515/122,
"Evaluation of Rosemount
Pressure
Transmitter
Performance
and Licensee
Enhanced
Surveillance
Program."
The
licensee
did not express
a position
on the inspection findings related to the
Rosemount
pressure
transmitter inspection
documented
in this report.
A telephonic exit was conducted
on May 23,
1995,
among Messrs.
J.
Whittemore
and
D. Chamberlain,
of Region IV, and Mr. D. Swank, of Washington
Nuclear
Project-2,
to discuss
the followup on the stopping of the residual
heat
removal
system while in the shutdown
mode.
The licensee
did not express
a
position
on the findings related to the inspection of the loss of shutdown
cooling event.
The licensee
did not identify as proprietary
any information provided to, or
reviewed by, the inspectors.
)l
ATTACHMENT 2
DATA RE UIRED BY TEMPORARY INSTRUCTION 2515
122
PERFORMANCE
SURVEY
FOR
ROSEMOUNT MODEL 1151,
1152,
AND 1153A TRANSMITTERS IN
ACCORDANCE WITH TI 2515/122,
ENCLOSURE 1.
Based
on
a review of licensee
records,
the following general
information on
Model
1151,
1152,
and
1153A, transmitters
in safety-related
(non-pressure
boundary application) is provided:
1.
Total
number of transmitters
currently installed.
2.
Total
number of transmitters
installed
as of January 1991............
11
For those
Model
1151,
1152,
and
1153A transmitters
that
show symptoms of.oil
loss
based
on the trending results,
provide the following information:
3.
Total
number of transmitters
that exhibit loss of fill-oil symptoms.,
0
4.
Total
number of transmitters
(identified by licensee
or inspector)
that
exhibit loss of fill-oil symptoms
which were not previously identified
by the licensee.......
0
5.
Total
number of transmitters
identified above in Item 3 which were also
confirmed
by Rosemount
as loss of fill-oil.
. ...................,0
PERFORMANCE
SURVEY
FOR
ROSEMOUNT MODEL 1153B/D
AND 1154
POST-JULY 11,
1989
MANUFACTURED TRANSMITTERS IN ACCORDANCE WITH TI 2515/122,
ENCLOSURE 2.
,V
Based
on
a review of licensee
records,
the following general
information on
Model
1153B,
1153D, 'and
1154, post-July
11,
1989, manufactured
transmitters
in
safety-related
(non-pressure
boundary applications)
is provided:
1.
Total
number of,1153B/D transmitters
currently installed.............
10
Total
number of 1154 transmitters currently installed ..........,,...
0
2.
Total
number of transmitters
installed
as of January
1991.
~ ..........
2
For those
Model
1153
and
1154 transmitters
manufactured after July 11,
1989,
that
show symptoms of oil loss
based
on the trending results,
provide the
following information:
3.
4.
5.
Total
number of transmitters
that exhibit loss of fill-oil symptoms..
0
Total
number of transmitters
that exhibit loss of fill-oil symptoms
which were not previously identified by the licensee.
0
Total
number of transmitters
identified above in Item 3 which were also
confirmed
by Rosemount
as loss of fill-oil. ......... ...............
0