ML17291B182
| ML17291B182 | |
| Person / Time | |
|---|---|
| Site: | Columbia |
| 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:
Licensee:
Washington Public Power Supply System
3000 George
Way
P.O.
Box 968,
MD 1023
Richland,
Facility Name:
Nuclear Project-2
Inspection At:
WNP-2 site near Richland,
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
ADQCK 05000397
8
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.
Revision I (Section
10. I) was closed.
Revision I (Section
10.2)
was closed.
Revision
1 (Section
10.3)
was closed.
(Section
10.4)
was closed.
Attachments:
Attachment
I
Persons
Contacted
and Exit Heetin9
~
Attachment
2
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
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.
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
RHR Trains
A and
B
Standby
Gas Treatment
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
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
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
flow tests
in November
1995.
4. 1. 1
RFW Flow Test Results
On November
9 and
16, the licensee
performed
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
Re lacement
On November 3,
1995,
the inspectors
observed
maintenance
associated
with the
replacement
of the
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
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
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
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
-12-
Upon assessing
this issue,
the licensee
pointed out that Step 8.2.5 of
PPN 8.9.1,
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
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
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
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
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
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
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
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
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
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
Protection for Containment
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
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
and the equipment
supported
by the penetrations
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
and will remain inoperable.
To prevent recurrence,
the licensee
revised
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
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
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
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
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
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
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,
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
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- H
p.
- R.
A.
- T
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- J
H.
- J
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G.
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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,
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
CFD
IS.C
LCO
LER
NRC
PER
ppb
PPH
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
residual
heat
removal
radiation work permit
scram solenoid pilot valve
transversing
in-core probe
Technical Specifications
Nuclear Project-2
l
P