ML17291B182

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Insp Rept 50-397/95-31 on 951015-1125.Violations Noted.Major Areas Inspected:Control Room Operations,Licensee Action on Previous Insp Findings,Operational Safety Verification, Surveillance Program,Maint Program & LER
ML17291B182
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 12/26/1995
From: Wong H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML17291B180 List:
References
50-397-95-31, NUDOCS 9512290338
Download: ML17291B182 (35)


See also: IR 05000397/1995031

Text

ENCLOSURE 2

U. S.

NUCLEAR REGULATORY COMMISSION

REGION IY

Inspection Report:

50-397/95-31

License:

NPF-21

Licensee:

Washington Public Power Supply System

3000 George

Washington

Way

P.O.

Box 968,

MD 1023

Richland,

Washington

Facility Name:

Washington

Nuclear Project-2

Inspection At:

WNP-2 site near Richland,

Washington

Inspection

Conducted:

October

15 through

November

25,

1995

Inspectors:

R.

C. Barr, Senior Resident

Inspector

G.

W. Johnston,

Senior Project Inspector

J.

L. Dixon-Herrity, Resident

Inspector

Approved:.

ong

C ie

,

eactor

roJect

rane

ate

Ins ection

Summar

Areas

Ins ected:

Routine,

announced

inspection

by resident

and Region-based

inspectors of control

room operations,

licensee

action

on previous inspection

findings, operational

safety verification, surveillance

program,

maintenance

program,

and licensee

event reports

(LERs).

Results:

Operation

The licensee's

Gold Card Program effectively identified good

and poor

practices

associated

with operations activities;

however,

a number of

deficiencies identified in the Gold Card

Program that met the criteria

for problem evaluation

requests

(PER)

were not documented

in the

PER

Program.

This finding indicates

the need for increased

management

oversight of the Gold Card Program (Section 3.2. 1).

Shift turnovers

were generally effective.

In some instances,

operators

did not implement management's

expectations

for alarm response

in

95i2290338 95i22h

PDR

ADQCK 05000397

8

PDR

announcement

of alarms

and reference

to alarm response

procedures

(Section 3.2.3).

A walkdown of several

engineered

safety features

systems

indicated

generally

good material conditions

and the proper lineups

(Section 3.3).

A noncited minor violation was identified when

an equipment operator

failed to adhere

to plant procedures

in that

he implemented

a clearance

by not individually hanging

and signing clearance

tags

(Section

6. 1).

fn ineerin

Reactor

feedwater flow testing

was well planned,and

implemented

(Section 4.1).

Maintenance

~

Surveillance testing

was generally performed

and documented

properly

(Section 5).

Personnel

used

a poor work practice of leaning

a ladder against

a

residual

heat

removal

(RHR)

pump during vibration measurements

(Section 5.1).

Work management

procedures

did not provide adequate

instructions for

developing troubleshooting

plans

(Section 6.2).

Plant

Su

ort

~

Response

to resin intrusions into the reactor coolant

improved;

however,

previous corrective actions to assure reliable condensate filter

demineralizer

(CFD) operation

have not been fully effective

and

additional attention to oversight

and work practices

on the assembly of

the internal

components

of the

CFD appears

warranted

(Section

2. 1).

~

An equipment

operator

violated the requirements

of a radiation work

permit

(RWP)

when

he breached

a contaminated

system outside

a

contaminated

area

(Section

6. 1).

~

Housekeeping

conditions in the diesel

generator

(DG) rooms

need

additional

management

attention

(Section 7.3).

A noncited minor

violation associated

with tool

box storage

was identified.

Summar

of Ins ection Findin s:

New Items

Violation 397/9531-01

(Section

6. 1)

was opened.

Two noncited violations were identified (Sections

6. 1 and 7.3).

~-

Closed

Items

Violation 397/9350-03

(Section 8.1)

was closed.

Violation 397/9414-02

(Section

8. 1) was closed.

Violation 397/9419-02

(Section 8.2)

was closed.

Violation 397/9419-03

(Section 8.3)

was closed.

Violation 397/9424-01

(Section 8.4)

was closed.

Violation 397/9427-01

(Section 8.5)

was closed.

Violation 397/9429-02

(Section 8.6)

was closed.

Violation 397/9433-01

(Section 8.7)

was closed.

Violation 397/9433-02

(Section 8.8)

was closed.

Inspection

Followup Item 397/9402-05

(Section

9. 1)

was closed.

LER 397/93-14,

Revision I (Section

10. I) was closed.

LER 397/94-05,

Revision I (Section

10.2)

was closed.

LER 397/94-18,

Revision

1 (Section

10.3)

was closed.

LER 397/95-03

(Section

10.4)

was closed.

Attachments:

Attachment

I

Persons

Contacted

and Exit Heetin9

~

Attachment

2

Acronyms

DETAILS

1

PLANT STATUS

The plant was at 97.5 percent reactor

power at the beginning of the inspection

period due to testing that indicated slightly elevated

feedwater flows.

On

November 3,

1995,

the licensee

reduced

reactor

power to 75 percent to conduct

maintenance

on the control rod drive system.

The reactor

was returned to

97.5 percent

power on Tuesday,

November 7,

1995.

On November

10, operators

reduced reactor

power to 80 percent to perform maintenance

on

CFD A.

Reactor

power was returned to 97.5 percent

and remained at 97.5 percent for the rest

of the inspection period.

2

ONSITE

FOLLOWUP TO EVENTS

(93702)

2. 1

Hi

h Reactor Coolant Sul hate Concentration

Due to Resin Intrusions

During this inspection period the facility experienced

several

minor resin

intrusions in which reactor coolant sulphate levels

exceeded

5 ppb

and

on

October 31,

1995,

a large resin intrusion with reactor coolant sulphate levels

exceeding

40 ppb

(no Technical Specification

(TS) limit).

The licensee

determined that

CFDs A,

E,

and

F were the source of the resin intrusions,

The

licensee

removed

from service,

inspected,

and disassembled

these

CFDs.

The

licensee

found

a number of problems that

had previously occurred.

In two of

the

CFDs, the flow distribution tube

was found disengaged

from its retaining

plate.

The flow distribution tube inserts into this plate in

a bayonet

manner.

A number of filter septa

were found disengaged

from their retaining

adapters.

These

septa filters insert bayonet-like into the retaining adaptor

which is threaded

into the

CFD distribution plate.

Also, approximately

12

septa

adapters

were found to not be perpendicular

to the distribution plate.

The licensee initiated

PERs

295-1136

and 295-1149 to document

these findings.

The licensee

discussed

improved methods for installing the flow distribution

tube

and the filter septa with the

CFD vendor

who suggested

revised

reassembly

techniques.

The licensee

used

these

practices

in reinstalling the

CFD

components.

The licensee

plans to modify procedures

to incorporate

these

suggestions.

The licensee

determined that the nonperpendicular

septa

adapters

were acceptable

for use

even though it requires

the attached

septa to be

slightly bent to fit into the top retaining plate.

2.2

NRC Ins ection

and Conclusions

The inspectors

observed

selected

portions of the disassembly

and reassembly

of

CFD A.

The inspectors

noted that the licensee

responded

to high reactor

coolant sulfates

more conservatively

than they had in the past.

Reactor

power

was reduced to minimize resin introduction to the reactor coolant

and

CFD

disassembly

was

more timely.

The licensee

missed

an opportunity to identify

these

problems earlier due to the misinterpretation of resin trap high

differential pressures.

Previous corrective actions including specific

e

assembly

methods

and revised

backwash

and precoat

techniques

appear

not to be

effective.

The inspectors

concluded that the licensee's

response

to resin intrusions into

the reactor coolant

system

has

improved;

however,

past corrective actions to

assure

the proper reassembly

of the

CFDs

have not been effective.

Overs'ight

and work practices

on the assembly of the internal

components of the

CFDs

require strengthening.

3

PLANT OPERATIONS

(71707,

92901)

3. 1

Plant Tours

The inspectors

toured the following plant areas:

Reactor Building

Control

Room

DG Building

Radwaste

Building

Service

Water Buildings

Technical

Support Center

Turbine Generator

Building

Yard Area

and Perimeter

3.2

Ins ectors

Observations

3.2. 1

Gold Card

Program

The licensee initiated the Gold Card

Program in July 1995 to document

good

and

poor practices

associated

with operations activities.

This program was in

addition to the

PER Program that documents

problems that have the potential

or

do impact plant safety.

On November

5,

1995,

the inspectors

noted that

a Gold Card was written after

the shift manager

recognized that

an equipment operator failed to follow

procedures

while working on control rod hydraulic accumulators.

The inspector

questioned

why

a Gold Card

was initiated rather than

a

PER.

The shift manager

explained that the individual had

made

an error and that the Gold Card system

was set

up to catch errors in process,

so it was not considered

an erron

requiring 'a

PER.

The inspectors

reviewed Plant Procedure

Manual

(PPH) 1,3. 12,

"Problem Evaluation Request,"

Revision

21,

and verified that any deviation

from the requirements

in a safety-related

plant procedure

required

a

PER to be

initiated.

To determine if other instances

of not initiating a

PER had

occurred,

the inspectors

reviewed the list of Gold Cards written between

October

15-28,

1995,

and identified

a number of events that should

have caused

a

PER to be initiated.

The licensee

had recognized

the potential for the Gold Card Program to be used

instead of the

PER Program.

The licensee

was in the process

of performing

a

quality assurance

(gA) surveillance to assure

proper implementation of this

program during the time the inspectors

was conducting this inspection.

The

inspectors

discussed

the findings of the inspection with the

gA inspector

involved in the surveillance.

The findings of the licensee's

surveillance

and

the

NRC inspection

were similar.

The

gA surveillance

determined that

approximately

12 of the events

the inspectors

had identified should

have

either resulted

in

a

PER directly or in

a

PER because

of a developing trend

with a number of repeat

events.

The

gA inspector initiated

PER 295-1175 to

address

the concerns

the surveillance identified.

The licensee's

corrective actions

included generating

PERs for the Gold Cards

that met the

PER criteria of PPH 1.3. 12, reevaluating

the Gold Card Program

instructions

and training,

and reevaluating

the

PPH 1.3. 12 criteria requiring

PERs.

The inspectors

concluded that in some instances

operations

personnel

had

inappropriately initiated

a Gold Card in lieu of a

PER.

These

instances

indicate

a weakness

in licensee

management's

oversight of the newly

implemented

Gold Card

Program

and

a weakness

in change

management.

The

licensee

assigned

an individual to perform

a daily review of the Gold Card

findings, to evaluate

the findings against

the

PER criteria

and to initiate

a

PER when appropriate.

The inspectors

concluded that the licensee's

actions to

prevent recurrence

of this problem appeared

adequate.

3.2.2

DG Room Tour

On November

1,

1995,

the inspectors

toured the

DG rooms.

The general

material

condition of the equipment

was good,

but there were

a number of oil leaks

noted.

The service water valves in

DG Room

1

had

a chemical

buildup in the

packing gland area

and appeared

to be in poor material condition.

The

inspectors

discussed

the concerns

with the system engineer.

The service water

system engineer identified that the valves

had

been repaired,

but had not been

cleaned

up.

3.2.3

Operating

Logs,

Records

and Control

Room Observations

The inspectors

reviewed operating logs

and records

against

TS and

administrative control procedure

requirements.

The inspectors

observed

a

number of shift turnovers for all the shifts.

The inspectors

observed that

each off-going crew member

reviewed the previous shift activities with the

on-coming crew member.

The reviews included discussion

of logs,

work orders,

and night orders.

While walking down the control

room panels,

the crew

members

examined pertinent tags,

noted unusual

or important indications,

and

discussed

ongoing evolutions.

The inspectors

determined that the off-going to

on-coming watchstander

turnover activities appeared

adequate.

Following the

" individual watchstander

turnovers

and watch turnover,

the control

room

supervisor

(CRS) briefed the crew on planned activities

and

abnormal

equipment

lineups for the shift.

Other watchstanders

were then called

upon to present

pertinent information that they had learned

through their individual

turnovers.

The inspectors

observed that during the crew briefings operators

did. not

consistently

acknowledge

alarms

according to management's

expectations.

Operators

did not always

announce

the alarms

and obtain

acknowledgement

of the

alarm

and refer to the alarm response

procedure.

Additionally, some

crew

briefings lasted for approximately

30 to 45 minutes.,

During this time,

noncontrol

room watchstanders

were not at their watchstations

and

some

personnel

lost attention.

The inspectors

shared

these

observations

with

operations

management

who indicated they would consider

the comments.

While

these

observations

did not represent

safety concerns,

they indicated the

inconsistent

implementation of management's

expectation

to have concise

briefings.

3.2.4

Shift Manning

The inspectot s observed

control

room and shift manning for conformance with

10 CFR 50.54(k),

TS,

and administrative

procedures.

The inspectors

also

observed

the attentiveness

of the operators

in the execution of their

duties'he

inspectors

concluded that shift manning

was in conformance with the

applicable

requirements

and operators

were generally attentive to duties.

The

control

room was observed

to be free of distractions.

3.2.5

Equipment

Lineups

The inspectors verified that valves

and electrical

breakers

were in the

position or condition required

by TS and administrative

procedures

for the

applicable plant mode.

This verification included routine control

board

indication reviews

and conduct of partial

system lineups.

Appropriate entry

into TS limiting condition for operation

(LCO) was verified by direct

observation.

3.2.6

Equipment

Tagging

The inspectors

observed

selected

equipment, for which tagging requests

had

been initiated and verified that tags

were in place

and the equipment

was in

the condition specified.

3.2.7

General

Plant

Equipment Conditions

The inspectors

observed

plant equipment for indications of system leakage,

improper lubrication, or other conditions that would prevent the system

from

fulfillingits functional .requirements.

Annunciators

were observed

to

ascertain their status

and operability.

No anomalies

were identified.

3.3

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 that they were 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

and remote position

indication,

as applicable.

The inspectors

walked

down selected

portions of the following systems:

DG, Division 2

Low Pressure

Coolant Injection Trains

A and

B

High Pressure

Core Spray

RHR Trains

A and

B

Standby

Gas Treatment

Standby Liquid Control

125-Vdc Electrical Distribution, Divisions

1

and

2

250-Vdc Electrical Distribution

The inspectors

noted that the engineered

safety features

systems

were

generally in good material condition

and were aligned in accordance

with

applicable licensee

procedures

for the portions walked down.

4

ONSITE ENGINEERING

(37551,

92903)

4. 1

Reactor

Feedwater

RFW

Flow Testin

Background

The licensee

calculates

re actor power by performing

a heat

balance calculation (calorimetric).

One of the inputs to the calorimetric is

RFW flow.

In September

1995, the licensee

conducted

two rubidium feedwater

flow tests that indicated

RFW flow was

102.4 percent.

The licensee

reduced

power by 2.5 percent while the test results

were further evaluated.

To

confirm the results of these tests,

the licensee

performed four additional

RFW

flow tests

in November

1995.

4. 1. 1

RFW Flow Test Results

On November

9 and

16, the licensee

performed

sodium

RFW flow tests;

on

November

10 and

11, the licensee

performed rubidium

RFW flow tests.

The

preliminary results of this testing indicated that

RFW flow is 101.5 percent

instead of 102.4 percent

as September

1995 testing indicated.

The licensee

attributed the differences

between

the September

1995

and

November

1995 tests

to leakage

by the seat of test isolation valves.

Additional isolation valves

were

added for the

November tests.

The licensee

expects

to have the final

test data

by mid-December.

The licensee

plans to remain at 97.5 percent

power

until the final test data is verified.

4. 1.2

NRC Inspection

and Conclusions

The inspectors

attended

the licensee's

pretest briefing for the sodium test

conducted

on November 9, observed

selected

portions of the sodium tests

conducted

on November

9 and

16,

reviewed the test procedures

for the sodium

and rubidium tests,

and discussed

the preliminary results of the tests with

the licensee.

The inspectors

considered

the pretest briefing thorough.

The

pretest briefing included the appropriate

precautions

for handling highly

radioactive

sodium to minimize the radioactive

dose received during the

testing.

The inspectors

performed

a limited review of the licensee's

test methodology

and concluded

the test

appeared

capable of accurately

determining

RFM flow.

The inspectors will continue to review this issue

when the final testing data

is available.

5

SURVEILLANCE TESTING

(61726)

The inspectors

reviewed

TS surveillance tests

on

a sampling basis

to verify

that:

~

a technically adequate

procedure

existed for performance of the

surveillance tests;

~

the surveillance tests

had

been

performed at the frequency specified in

the

TS and in accordance

with the

TS surveillance

requirements;

and

~

test results satisfied

acceptance

criteria or were properly dispositioned.

R. ~RT

On November 7,

1995,

the inspectors

toured

Pump

Room

RHR 2B while

a

pump

operability test

was in progress.

The inspectors

noted

an extension

ladder

was leaning against

the running

pump.

The inspectors

discussed

with the

CRS the practice of having

a ladder leaning

on the running

pump.

The supervisor

explained that

an electrician

planned to

use the ladder to take in-service testing vibration data.

The inspectors

questioned

whether the electrician

standing

on the ladder during the test

could affect the

pump vibration data.

The inspectors

also discussed

this

concern with the electrical

supervisor.

The supervisor

was not sure

how the

practice would affect the data.

He directed that the practice

be

discontinued;

however,

pump data

had already

been taken with the ladder

against

the

pump.

The inspectors

reviewed the vibration data taken.

The data

was below the

alert level limits.

On November 9,

1995',

the

pump was run again to allow the

data to be taken

from a position that would not affect the readings.

A

comparison of the data indicated that leaning

on the

pump affected the

readings,

but the difference

was very small.

The inspectors

concluded that

the practice of taking vibration data

from a ladder leaning

on the equipment

being monitored

was

a poor work practice.

The corrective action to

discontinue this practice

appeared

appropriate.

-10-

The inspectors

witnessed

portions of the following surveillance tests:

d

~0

7.4.3. 1. 1.53

Reactor

Steam

Dome High Pressure

7.4.7.9.

1

Turbine Bypass

Valve Test

7.4.3.8.2.

1

Turbine Governor Valve Test

Overall, surveillance testing

was performed

and documented

properly.

6

NAINTENANCE OBSERVATIONS

(62703)

During this 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/quality control involvement,

proper

use

of'learance

tags,

proper equipment

alignment

and

use of jumpers,

personnel

qualifications,

and proper retesting.

6.1

Scram Solenoid Pilot Valve

SSPV

Re lacement

On November 3,

1995,

the inspectors

observed

maintenance

associated

with the

replacement

of the

SSPVs

on the control

rod drive hydraulic system hydraulic

control units

{HCUs).

Generally,

the evolution was carefully planned

and

effectively implemented.

An assembly line technique

was

used to replace

the

SSPVs

on the

65

HCUs during

a period of 55 hours6.365741e-4 days <br />0.0153 hours <br />9.093915e-5 weeks <br />2.09275e-5 months <br />.

The inspectors

attended

the briefing that was held for maintenance

personnel

before starting the work.

The briefing was not detailed,

but the inspectors

noted

a briefing had

been

held for all participants earlier in the week.

Licensee

management

stressed

that the job would not be driven by the schedule.

The electricians

were knowledgeable of work that

was to be performed

and

pointed out

a number of concerns.

The information covered

was appropriate.

The inspectors

observed

portions of the tagout,

valve replacement,

and

preparation for return to service of the first six HCUs.

All work was

done in

accordance

with procedure

and good radiation control

and maintenance

practices

were used.

The work proceeded

without production pressures.

'ersonnel

were

knowledgeable

of the tasks

being performed.

On November

5,

1995,

the inspectors

observed

an equipment operator

remove the

clearance

from an

HCU.

The operator

removed the tags in accordance

with the

procedure.

However,

when the accumulator drain Valve CRD-V-107/HCU started

leaking after the operator replaced

the fitting that

was normally installed,

the operator blotted the water with a towel

and placed

the towel

on the floor.

The water continued to drip onto the floor.

The operator continued

removing

the tags;

but remained

cognizant of the leak.

He stopped

frequently to absorb

the leaking water.

The work was being performed in

a noncontaminated

area,

but the water in the

HCU was potentially contaminated.

The inspectors

noted

that the operator did not survey the towel for contamination.

The inspectors

-11-

discussed

these

observations

with the work area supervisor.

A health physics

(HP) technician

was contacted

to clean

up the water.

No contamination

was

found.

The inspectors later reviewed the

RWP for the job,

RWP 95000224.

The

RWP

required that breaches

of contaminated

systems

outside of contaminated

areas

be performed using rubber gloves,

HP coverage,

and provisions to collect the

leakage until surveyed

and released

from these controls

by HP.

The equipment

operator

who performed the task

was not wearing gloves,

did not have

HP

coverage,

and the leakage

was not contained.

The operator failed to recognize

the potential for contamination

and to contact

HP when the leak first

occurred.

This failure to adhere to the

RWP had the potential to spread

contamination.

The failure to follow the

RWP is

a violation (Violation

397/9531-01).

There

have

been previous

problems

implementing radiation

protection procedures.

During the observation of the placement of the clearance

on another

HCU, the

equipment operator

who placed the clearance

stated that

he was not going to

sign the clearance

order for the valves until they were all tagged,

then

started

the task.

The inspectors

noted this statement

and observed

the

operator correctly position

and tag the valves.

The inspectors

questioned

why

the operator

decided to sign off the valves after they were all positioned

and

tagged rather than meeting management's

expectation

to sign off each tag

as it

was hung.

The operator explained that the area

was possibly contaminated

and

that

he was wearing work gloves.

He stated

he did not want to have to take

off the gloves to use his pen or to have the extra paper at the top of the

ladder.

The inspectors

asked

whether this was his normal practice.

The

operator explained that it was not and,

in normal practice,

valves being

cleared

were in different plant areas,

which made individual signoffs more

readily accomplished.

The inspectors

and the licensee's

second-verifier

noted that the operator

initialed the clearance

order for the valves

he had just finished tagging

and

that

he initialed next to two fuses that

he

had not yet removed.

The operator

acknowledged

the error and stated that

he

had

been distracted.

He then

removed the fuses

and another

equipment operator verified their removal.

The

tags for the fuses

were still in his possession

and, therefore,

the likelihood

of not removing the fuses

was slight.'he

equipment operator

who had

been

observed

by the inspectors

reported his error to the shift manager

and

initiated

a Gold Card to document

the error.

The inspectors

observed

the placement of several

clearances

during the

continuation of the work and noted the equipment operators

were meeting

management

expectations.

The inspectors

reviewed

PPH 1.3.8,

"Danger Tag

Clearance

Order," Revision 25,

and found that it required initials as

each

tag

was placed

and the item reposItioned.

The initialing after

each tag is hung

assures

that

no tag can

be lost or misplaced to assure

the clearance

is

completed.

This failure constitutes

a violation of minor significance

and is

being treated

as

a noncited,violation,

consistent

with Section

IV of the

NRC

Enforcement Policy.

-12-

Upon assessing

this issue,

the licensee

pointed out that Step 8.2.5 of

PPN 8.9.1,

"HCU SSPV Replacement,"

stated

"Hang tags

1 through

10:

document

on

Attachment

10. 1, Standard

HCU Clearance

Order,

the procedure for performing

the

HCU work."

The licensee

indicated that the direction provided

by

PPN 8.9.1 likely confused

the equipment operator

since the direction appeared

to contradict

PPN 1.3.8.

The inspectors

noted that the administrative

procedures

establish

the guidance

and expectations

for the remainder of the

plant procedures.

The inspectors

noted that

PPM 8.9. 1 was not specific

as to

whether the clearance

tags

were to have

been

hung individually or as

a group.

As corrective action,

the licensee

discussed

with the equipment operator

on

the expectations

for clearance

order implementation.

The inspectors

concluded that the work performed

was generally well planned

and performed in accordance

with the procedures

and work instructions,

with

the exception of the two examples

discussed

above.

6.2

Transversin

In-Core Probe

TIP

Indexer Maintenance

On November

1,

1995,

the inspectors

observed

an instrument

and control

( I&C)

technician

and the system engineer

investigate

a problem with the TIP indexer

on TIP-CRM-5B,

The work performed

was in accordance

with PPN 1.3.7G,

"Work

Implementation,"

Revision 9,

and Job Investigation

Sheet

(JIS)

95005795.

The

inspectors

questioned

why a JIS was

used

instead of using formal

troubleshooting

instructions

as required

by

PPM 1.3.42,

"Troubleshooting Plant

Systems

and Equipment," Revision

11,

The system engineer

and

I&C supervisor

explained that the JIS was

used for tasks

where detailed

work controls,

an

RWP, or

a clearance

order were not needed

or where the work would not aFfect

other systems.

The inspectors

reviewed the procedures

used to control work management

which

included the

PPM 1.3.7 series of procedures

and

PPM 1.3.42.

The purpose for

PPM 1.3.42

was to establish

guidelines for the control of troubleshooting

activities not covered

by the work order process

or not contained

in other

procedures,

The inspector

found that there

was nothing in the

PPN 1.3.7

series of procedures

that would cause

the troubleshooting

Procedure

PPN 1.3.42

to be used.

The decision

process

described

by the engineer

and supervisor

was

not included in procedures.

The inspectors

discussed

this concern with the

I&C supervisor.

The supervisor

was

aware of the problem due to

a similar

concern

he

had addressed

in a

PER on

a separate

subject.

The inspectors

concluded that the work management

procedure

did not provide adequate

administrative instructions for the development of a work package

to control

troubleshooting activities.

The licensee

agreed with this observation

and

planned to revise appropriate

procedures

to control troubleshooting.

7

PLANT SUPPORT ACTIVITIES

(71750)

The inspector evaluated

plant support activities based

on observation of work

activities, review of records,

and facility tours.

The inspector

noted the

following during this evaluation.

-13-

7.1

Fire Protection

The inspector

observed firefighting equipment

and controls for conformance

with administrative

procedures.

The inspector

noted that

a high number of

fire impairments existed for which fire tours were being conducted

because

of

concerns with Thermo-Lag

and fire seals.

7.2

Radiation Protection Controls

The inspector periodically observed radiological protection practices

to

determine whether the licensee's

program

was being

implemented

in conformance

with facility policies

and procedures

and in compliance with regulatory

requirements.

The inspector

also observed

compliance with RWPs,

proper

wearing of protective

equipment

and personnel

monitoring devices,

and

personnel

frisking practices with the exception of the equipment operator

working on the

SSPVs discussed

in Section

6. 1.

Radiation monitoring equipment

was frequently monitored to verify operability and adherence

to calibration

frequency.

7.3

Plant Housekee

in

The inspector

observed

plant conditions

and material

and equipment

storage

to

determine

the general

state of cleanliness

and housekeeping.

Housekeeping

in

the radiologically controlled area

was evaluated

with respect

to controlling

the spread of surface

and airborne contamination.

Housekeeping

was observed

to be good,

except in the

DG rooms.

The inspector identifie'd

a number of discrepancies

on November

1,

1995.

Two

tool gang

boxes

were located within 4 feet of safety-related

flexible conduits

in both

DG Rooms

1

and 2,

even

though signs

on the boxes indicated that the

boxes

should not be within 4 feet of safety-related

equipment.

(The box was

within

1 foot of the conduits in

DG Room

1

and within 2 I/2 feet in

DG Room

2

and both had their wheels locked).

A vacuum,

a coil of vacuum hose,

and

a mop

were stored in

DG

Room 2,

A speaker

was stored

in front of the fire

extinguisher in

DG Room 1.

The top of an oil can permanently

set

up to

collect vented oil fumes

had not been replaced correctly and

had spilled

on

the floor.

The inspector

reviewed

PPH 10.2.53,

Revision

12, "Seismic Requirements

for

Scaffolding,

Ladders,

Man-Lifts, Tool

Gang

Boxes, Hoists,

and Hetal Storage

Cb

<<."

I>>

d

q

<<h

b

h

stored in safety-related

areas

be stored in the designated

area delineated

by

striping or painting.

If the box was not restrained

(held down or tied back)

in some manner, it was not to be placed nearer to safety-related

equipment

than the full height of the item plus

12 inches.

The boxes in the

OG rooms

were not held

down or tied back

and did not have striping around

them.

The

inspector considered

the failure to store the tool boxes at the required

distance

from safety-related

equipment

as

an example of a minor procedural

adherence

issue

and

an isolated incident.

Because

the potential for the tool

boxes to move was limited since the wheels

were blocked,

there

was minor

safety significance to this occurrence.

This failure constitutes

a violation

of minor significance

and is being treated

as

a noncited violation, consistent

with Section

IV of the

NRC Enforcement Policy.

The inspector discussed

the

corrective actions for the other concerns

identified with the system engineer

and

found that the actions

taken or planned

appeared

appropriate.

The licensing engineer initiated

PER 295-1176 to address

the improper storage

of the tool boxes.

As

a corrective action,

the licensee

held shop training

on

the proper storage of all types of equipment

which could

damage safety-related

equipment.

The licensee

walked the plant to verify that

no other tool boxes

were improperly stored.

The licensee's

corrective actions,

while not

particularly timely, appeared

adequate.

7.4

~Securit

The inspector 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

operational,

that the vital area portals were kept locked

and alarmed,

that

personnel

allowed access

to the protected

area

were

badged

and monitored,

and

that the monitoring equipment

was functional.

No problems

were noted during

these observations.

7.5

Emer enc

Plannin

The inspector toured the

Emergency Operations Facility, the Operations

Support

Center,

and the Technical

Support Center

and ensured

that these

emergency

facilities were in

a state of readiness.

Housekeeping

was noted to be very

good

and all necessary

equipment

appeared

to be functional.

The inspector

reviewed chemical

analyses

and trend results for conformance

with TS and administrative control procedures.

Plant chemistry

was

satisfactory during this inspection period.

The plant experienced

several

resin intrusions

and sulfate excursions

as discussed

in Section

2 of this

report.

7.7

Conclusions

II

Plant support

performance

was generally

good during this inspection period.

8

FOLLOWUP ON CORRECTIVE ACTIONS FOR VIOLATIONS

(92702)

The inspector

reviewed records,

interviewed personnel,

and inspected

plant

conditions relative to licensee

actions

in response

to previous

open items.

0

-15-

8. 1

Closed

Violations 397 9350-03

and

397 9414-02:

Failure to Secure

Com ressed

Gas Bottles in Accordance

With Procedures

On December

22,

1994,

and again

on April 24,

1994,

NRC inspectors

found two

compressed

gas cylinders unattended

and unrestrained

near safety-related

equipment.

These

were repetitions of previous incidents of unattended

and

unrestrained

gas cylinders.

The licensee's

corrective actions for the

April 24,

1994,

instance

included extending training in handling

gas cylinders

to operations,

chemistry,

and other personnel

who routinely use

compressed

gas

cylinders.

The inspectors

noted that training for the previous events

was

conducted

only for maintenance

personnel.

The inspectors

found that

corrective actions for a previous violation were not Fully effective because

the licensee

did not train personnel

that could use

gas bottles.

The

licensee's initial corrective actions

were too narrowly focused to prevent

recurrence.

Subsequent

corrective actions

were more comprehensive

and appears

appropriate.

8.2

Closed

Violation 397 9419-02:

Shroud

Head Bolts for Moisture

Se arator

Not Pro erl

Ali ned for Removal of Moisture

Se arator

Per Procedure

During reFueling operations,

licensee

personnel

did not effectively self- and

second-verify that all

36 shroud

head bolts were properly aligned for removal

of the moisture separator.

The error in verification resulted

From the

personnel

not being able to effectively view the shroud

head bolts.

To

correct this problem,

the licensee

revised

PPH 10.3.6,

"Reactor Vessel

Steam

Dryer and Moisture Separator

Removal

and Replacement,"

to require the use of

underwater

viewing equipment to verify unlatching of the shroud

head bolts.

The inspectors

reviewed the revised

procedures

and found the changes

reflected

in the procedures.

Subsequent

reFuelings

have encountered

no problems

determining the position of these bolts.

8.3

Closed

Violation 397 9419-03:

Exceedin

Liftin force

When Attem tin

Removal of Moisture

Se arator Contrar

to Procedure

During an attempt to lift the mois'ture separator,

the personnel

violated

PPH 10.4. 12,

"Crane

and Hoist Program Control,"

Revision 3, which required

that

a lift attempt not exceed

110% of the expected

weight of the load.

The

licensee

revised

PPH 10.3.6,

"Reactor Vessel

Steam Dryer and Moisture

Separator

Removal

and Replacement,"

to incorporate

the requirements

of

PPH 10.4. 12 that established

the load limit requirements.

The inspectors

reviewed the revised

procedures

and found the changes

reflected in the

procedures.

The licensee

conducted

subsequent'efueling

and heavy load lifts

without exceeding

load limits.

8.4

Closed

Violation 397 9424-01:

0 erators

Failed to Enter the

Emer enc

0 eratin

Procedures

EOPs

After Notin

That

an

EOP Entr

Condition

Existed

On July 27,

1994, operators

noted that suppression

pool water level

was at

+2.5 inches,

but did not enter

EOP

PPH 5.2. 1, "Primary Containment Control."

-16-

This action represented

a failure to note the significance of a

TS requirement

and to make

an immediate entry into the

EOP.

To prevent recurrence,

the

licensee

implemented

changes

to their

LCO entry sheets

that require

a review

by the shift manager

and

CRS.

The review provides

a second

check to assure

entry into the

TS

LCO action requirements

is made

when required.

The licensee

has also

implemented

a training program that includes

case

studies of TS

requirements.

The inspectors

reviewed the proposed training and f'ound that it

is adequate

to address

the issue

and enhances

the task-oriented

systematic

approach

to training.

8.5

Closed

Violation 397 9427-01:

Failure to Ensure

Containment

Atmos here

Control

S stem Instrumentation

Tubin

Clam

s Were Installed in Accordance

With As-Built Dr awin

s

An

NRC inspector identified missing instrument tubing support

clamps for

tubing attached

to Transmitter

CAC-FT-7B,

a flow transmitter for the

containment

atmosphere

control

(CAC) system.

There

was

a lack of conformance

between

the approved as-built drawing

and the installed tubing.

A quality

control inspector,

maintenance

personnel,

and the system engineer did not

question

the missing tubing clamps

when compared with Train A of the

CAC

system,

and failed to initiate

a

PER.

The licensee

corrected

the installation

and initiated changes

to the

PER program that addressed

the inspector's

concerns.

The personnel

involved were counseled

as to the importance of

initiating a

PER when conditions warrant.

The inspector

considered

the

corrective actions

adequate.

8.6

Closed

Violation 397 9429-02:

Failure to Store Hoist in Prescribed

Location

This violation identified the failure to store Hoist NT-HOI-8 in the

prescribed

storage location.

The licensee

determined that the cause of the

failure was

a deficient procedure.

PPN 10.4. 10, "Jib Cranes

and Electrically

Operated

Hoists Inspection,

Maintenance,

and Testing," did not reference

or

include the hoist safe

storage

requirements

described

in Drawing N-568 or in

PPN 10.2.53,

"Seismic Requirements

for Scaffolding,

Ladders, Nan-lifts, Tool

Gang

Boxes, Hoists,

and Metal Storage

Cabinets."

The immediate corrective

actions

included returning the hoist to its prescribed

location

and holding

a

"time-out" with mechanical

and electrical craft personnel

to provide training

on the proper storage

requirements

for hoists.

I

The licensee identified another hoist that was stored outside of its storage

location

on December

21,

1994.

The licensee

determined this occurred prior to

resolution of the violation.

Contractors

had identified the need to assign

an

alternative

maintenance

location for Hoist NT-HOI-6 during maintenance,

but

left the hoist unattended

for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before

an alternate

storage

location

was assigned.

As

a result,

a second

"time-out" was held with contractor craft

to ensure

they understood

the need to return hoists to prescribed

storage

locations or have

an alternative

storage location approved.

To prevent

recurrence,

the licensee

revised

PPM 10.4. 10 to require that Hoists NT-HOI-6

-17-

through -10 be returned to the storage

locations identified in

PPM 10.2.53 if

they were to be left unattended.

The inspectors

reviewed

PPM 10.4. 10 and 10.2.53

and verified that they were

revised to reflect the

need to store the crane in a prescribed

or approved

location.

Through tours in the plant, the inspectors

noted that. the storage

locations for the hoists

were c1early marked

and hoists

were stored

on the

proper locations.

The inspectors

concluded that the implemented corrective

actions

were adequate.

8.7

Closed

Violation 397 9433-01:

Failure to Follow Procedure

to Check

Cou lin

and Verif Full-Out Rod Li ht Lit

This violation identified the failure of control

room operators

to verify the

completion of coupling checks

and that the rod full-out light was lit.

The

licensee

found that the root cause

was the failure of operations

personnel

to

self-check,

and independently verify, the completion of the coupling checks.

As an immediate corrective action,

the licensee

performed the coupling checks

to verify operability.

As additional corrective actions,

operations

management

coached

the control

room crews regarding their responsibilities

associated

with control rod manipulation

and stressed

the need for proper

self-checking

and independent verification.

The

CRSs

were assigned

an

oversight responsibility for rod movements that occurred during their watch.

An operations

supervisory task was created

to require the review of various

operations

documentation

For accuracy

and completeness.

A program for

monitoring personnel

performance

was

implemented to provide feedback to

operators

regarding

performance.

The inspectors

made observations

as rod movements

were

made

and determined

the

new practice of using

second verification for each

step in the procedure

should prevent future errors.

In addition, the inspectors

reviewed the OI-09

Program

Form,

"Moving Control

Rods," which was

used to review individual

performance

in performing this task.

The form clearly defined management's

expectations

for the task.

The

CRS indicated that it was management's

expectation

that the 01-09 form be completed for the first rod movement

in a

shift.

The inspectors

reviewed the recent

rod movements

and verified that the

documentation

was completed to licensee

management's

expectation.

The

inspectors

concluded that the current procedure

and the implemented corrective

actions

were appropriate.

8.8

Closed

Violation 397 9433-02:

Failure to

Com l

With TS Action

Statement

When Allowed Outa

e Time

Was

Exceeded for a Containment

Isolation Valve

An

NRC inspector identified licensed operators'ailure

to comply with Post

Accident Sampling

TS 3.3.7.5.

The operators failed to comply with the

TS

because

they were not aware of the significance of the position indication of

the control

room valve indicator.

As corrective actions,

the licensee

revised

the

TS bases

to clarify TS 3.3.7.5

and instructed the control

room operators

regarding

reviews of operability and communicating sufficient information when

-18-

determining

TS

LCO applicability.

The inspector'determined

that the actions

were adequate.

9

FOLLOWUP ENGINEERING

(92903)

9. 1

Closed

Ins ection Followu

Item 397 9402-05:

Effects of

S ra

Pond

Icin

on Seismic

Loads for S ra

Pond

Su

orts

The licensee initiated

PER 293-0140,

dated

February

5,

1993, to review

concerns of the

NRC inspector

who observed

approximately

5 inches of ice in

the service water spray ponds.

The inspector's

concern

focused

on the impact

the ice would have

on the supports for the piping in the ponds during

postulated

seismic events.

The licensee's

analysis for PER 293-0140 indicated that the additional

'loads

from the ice during postulated

seismic events

were all within'the expected

loads

and design margins for the piping.

The inspectors

assessed

the

licensee's

methodology

and concluded that the assumptions

were within accepted

practice.

The licensee's

analysis

included bounding the

maximum possible

thickness of ice,

then calculating the loads

both in the horizontal

and the

vertical planes for a 10-inch depth of ice.

The inspectors

concluded that the

licensee

had adequately

addressed

the inspectors'oncerns.

10

LER REVIEWS

{90712, 92700)

10. 1

Closed

LER 397 93-14

Revision

1:

Inade uate

Backu

Overcurrent

Protection for Containment

Penetrations

This item documented

the licensee's

discovery of five primary containment

electrical lighting circuits with inadequate

overcurrent protection that were

not turned off during plant operations.

While completing corrective

actions,

the licensee

discovered

additional

inadequate

penetration

overcurrent

protection conditions.

The licensee

determined that the cause of this event

was

a design analysis that used

inaccurate

and incomplete documentation.

The licensee

immediately opened

the breakers

in the five lighting circuits.

Upon discovery of eight additional circuits, the licensee

declared

the

penetrations

and the equipment

supported

by the penetrations

inoperable

and

entered

the appropriate

TS.

The licensee

modified the wiring in the circuits

identified later with the exception of two valves to provide adequate

primary

and

backup overcurrent protection.

The two valves that were not modified,

Valves

RHR-V-123A and -123B,

were

removed

from service,

declared

inoperable,

and will remain inoperable.

To prevent recurrence,

the licensee

revised

PPM

1.3.4,

"Operating Data

and Logs," to require that the five lighting circuits

be verified in the tripped condition at least

once per day while the plant is

in Modes

1, 2, or 3.

The

TS and

FSAR were changed

to reflect the actual

condition of the circuits.

The primary containment electrical penetration

short circuit capability calculation

was updated.

The inspectors

reviewed the

corrective actions

taken

and determined that they were appropriate.

-19-

10.2

Closed

LER 397 94-05

Revision

1:

Failure of Control

Rod to Scram

Due to

De radation of Pilot Valve Elastomers

Caused

b

In-Service

A in

This

LER documented

the failure of Control Rod 06-39 to scram during routine

scram testing.

The licensee

determined that the root cause of the failure was

an unusual

combination

of., degradation

of both the

SSPV pressure

and exhaust

diaphragms.

The licensee

believed the cause of the degradation

was

accelerated

aging .due to differences

in diaphragm composition.

Upon

discovering the failure, the control

room operator manually inserted

Control Rod 06-39

and hydraulically disarmed it.

All the remaining control rods were

scram time tested to verify that there

was

no

common

mode failure.

As

a

result,

the licensee

identified four control rods with acceptable,

but slower

than expected

scram times,

declared

the rods inoperable,

and hydraulically

disarmed

them.

The licensee

commenced

weekly scram time testing of all

operable control

rods

and expedited

replacement

of SSPV diaphragms.

All SSPVs

were rebuilt prior to the completion of Refueling Outage

R10.

The licensee

changed

the environmental

qualified service life for the diaphragm in the

SSPVs

from the manufacturer's

suggested

3 to

4 years to

2 years,

with the

option to extend it to

3 years after further analysis.

The licensee

plans to replace

the

SSPVs with valves with improved diaphragm

material

(Viton) that should last

10 or more years.

The licensee

replaced

the

SSPVs

on 75 of the

HCUs with valves that

used the improved material.

The

licensee

plans to replace

the remaining prior to the completion of Refueling

Outage

R12.

The schedule

to replace

the remaining valves will depend

on

analysis of the degradation

of the diaphragm material recently

removed during

SSPV maintenance.

The inspectors

reviewed the corrective actions

taken

and

observed installation of the

new diaphragms.

The inspectors

determined

the

actions

taken

and compl'etion of the planned

replacement

of the remaining

SSPVs

were adequate.

10.3

Closed

LER 397 94-18

Revision

1:

Failure to

Com l

with a TS

Action Re uirement

When Ino erable Control

Rod Block Instrumentation

Exceeded

the Allowed Outa

e Time

This item identified the failure to comply with the action statement

for

TS 3.3.6.b

as

a result of the failure of the Channel

A scram discharge

volume

high water level control rod block level switch.

The licensee

determined

the

root cause

was the failure to identify the nonadjustable

design characteristic

of the replacement

scram discharge

volume rod block level switch.

The

licensee

declared

the switch inoperable,

placed it in the tripped condition

as

required

by the

TS action statement,

and repaired

the switch.

To prevent

recurrence,

the licensee

strengthened

the substitution evaluation

process,

revised the replacement

level switch substitution evaluations

and information,

obtained

the proper operation

and maintenance

manual,

and conducted

maintenance

shop briefings concerning

the event.

The inspectors

reviewed the

LER and supporting information and determined that

an additional

causal

factor involved the failure of IKC personnel

to follow

procedures

after identifying differences

between

the switch removed

and the

0

0

-20-

replacement

switch.

As discussed

in

NRC Inspection

Report 50-397/94-32,

I&C

technicians

modified and installed the switch without an approved modification

package

or procedure.

This concern

was addressed

in the response

to

PER 294-0975,

but was not brought out in the

LER.

The inspectors

reviewed the

corrective actions

and concluded that both the root cause

and the causal

factor were adequately

addressed

in either the

PER or LER.

10.4

Closed

LER 397 95-03:

Failure to

Com

1

With TS Action Statement

When

Allowed Outa

e Time Was

Exceeded for a Containment

Isolation Valve

This

LER is closed

based

on the review of Violation 397/9433-02

discussed

in

Section 8.8,

ATTACHMENT I

1

PERSONS

CONTACTED

Washin ton Public Power

Su

1

S stem

J.

D.

  • J
  • R.

p

~

  • D
  • J
  • L
  • G
  • V
  • H

p.

  • R.

A.

  • T
  • N.
  • J

H.

  • J
  • C
  • W.
  • V
  • J
  • W

G.

  • C
  • W.
  • L
  • G
  • J
  • D
  • p
  • R.
  • J

Albers, Radiation Protection

Manager

Atkinson, Reactor

and Fuels Engineering

Manager

Baker, Training Director

Barbee,

System Engineering

Manager

Bemis,

Regulatory

and Industry Affairs Di'rector

Bennett,

Chemistry Supervisor

Burn, Engineering Director

Fernandez,

Licensing Engineer

Gelhaus,

WNP-2 Projects

Manager

Harris,

Maintenance Specialist

Hedges,

Corporate

Chemist

Inserra,

equality Assurance

Manager

Koenigs,

Project

Manager

Langdon, Assistant

Operations

Manager

Love, Chemistry Manager

Mann, Operations Staff

McDonald, Assistant

Engineering Director

Monopoli, Maintenance

Manager

Muth, equality Support

Manager

Noyes, qua')ity Control Manager

Oxenford,

Outage/Work Control Supervisor

Parrish,

Vice President

Nuclear Operations

Pedro,

Compliance Specialist

Rigby, Health Physics Supervisor

Sanford,

Planning,

Scheduling,

Outage

Manager

Schwarz,

Operations

Manager

Shaeffer,

Operations

Training Manager

Sharp, Assistant

Engineering Director

Smith, equality Assurance Director

Swailes,

Plant General

Manager

Swank,

Licensing Manager

Taylor, Shift Manager

Winslow, Radiation Protection

Support Supervisor

Wyrick, Assistant to Plant General

Manager

Southern California Edison

U.S

Faranandi,

equality Assurance

Supervisor

Nuclear

Re ulator

Commission

  • H.
  • R.
  • J

Wong, Chief, Project

Branch

E

Barr, Senior Resident

Inspector

Clifford, Senior Project

Manager,

NRR

I

I

'

The inspectors

also interviewed various control

room operators,

shift

supervisors,

shift managers,

and maintenance,

engineering,

quality assurance,

and management

personnel.

  • Attended the exit meeting

on December

5,

1995.

2

EXIT MEETING

An exit meeting

was conducted

on December

5,

1995.

During this meeting,

the

inspectors

reviewed the scope

and findings of the report.

The licensee

acknowledged

the inspectors'indings.

The licensee

did not identify that any

proprietary information was provided to, or reviewed

by, the inspectors.

ATTACHMENT 2

ACRONYNS

CAC

CFD

CRS

DG

EOP

FSAR

HCU

HP

IS.C

JIS

LCO

LER

NRC

PER

ppb

PPH

QA

RFW

RHR

RWP

SSPV

TIP

TS

WNP-2

containment

atmosphere

control

conderisate filter demineralizer

control

room supervisor

diesel

generator

emergency

operating

procedure

Final Safety Analysis Report

hydraulic control unit

health physics

instrument

and control

job investigation

sheet

limiting condition for operation

licensee

event report

U.S. Nuclear Regulatory

Commission

problem evaluation

request

parts

per billion

plant procedure

manual

quality assurance

reactor

feedwater

residual

heat

removal

radiation work permit

scram solenoid pilot valve

transversing

in-core probe

Technical Specifications

Washington

Nuclear Project-2

l

P