ML19257A841

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IE Insp Rept 50-338/79-39 on 790925-1005.Noncompliance Noted:Failure to Conduct Safety Evaluations on Changes to Components as Described in SAR
ML19257A841
Person / Time
Site: North Anna Dominion icon.png
Issue date: 10/17/1979
From: Kellogg P, Ridd M, Webster E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19257A838 List:
References
50-338-79-39, NUDOCS 8001090200
Download: ML19257A841 (12)


See also: IR 05000338/1979039

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGION 11

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101 MARIETTA ST., N.W., SUITE 3100

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ATLANTA. G EORGIA 30303

Report No. 50-338/79-39 (with attached Investigation Report)

Licensee: Virginia Electric and Power Company

P. O. Box 26666

Richmond, Virginia 23261

Docket No. 50-338

Facility Name: North Anna Unit 1

License No. NPF-4

Inspection at North

na. Sit.e near Mineral, Virginia

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Inspectors:

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M. S. Kidd, Resident Inspector

Date Signed

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E. H. Webster, R,eactor Inspector

Date Signed

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Is R. W. 2ava oski/, Radiation Specialist

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k' xS. C. Ewa'1d, Radiation Specialist

Date Signed

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Accompanying Personnel on Settember 25-26, 1979:

N. C. Moseley, Director, aivision of Reactor Operations Inspection, IE

D. F. Ross, Deputy Director, Division of Project Management, NRR

A. Schwencer, Chief, Operating Reactors Branch No. 1, Division of Operating

Reactors, NRR

J. D. Neighbors, Project Manager, Division of Operating Reactors, NRR

B. W. Sheron, Reactor Engineer, NRR

G. Kwalina, Environmental Branch, Division of Operating Reactors, h3R

G. R. Mazetis, Div,ision of System Safety, NRR

K. R. Mahan, Ope

or L'ce s' g Branch, NRR

Approved by:

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P. J/ Kefl<fgg ' dert i#rhi af RONS_ Branch

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Dates of Inspection. September 25 - October 5,1979

SUMMARY

Areas Inspected

This special, announced inspection involved 78 inspector-hours onsite in the area

of a reactor trip with safety injection and release of radioactive gases to the

environment on September 25, 1979.

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d 0 010 90-EE7

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Summary

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Results

Within the area inspected, one apparent item of noncompliance with two examples

was identified (infraction - failure to conduct safety evaluations on changes to

components as described in the safety analysis report

paragraph 5).

>

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DETAILS

1.

Persons Contacted

Licensee Employees

  • E. A. Baum, Executive Manager, Licensing and Quality Assurance
  • W. R. Cartwright, Station Manager
  • J. D. Kellams, Superintendent of Station Operations
  • S. L. Harvey, Operating Supervisor
  • E. W. Harrell, Superintendent of Maintenance
  • D. W. Hopper, Health Physics Supervisor
  • E. R. Smith, Superintendent of Technical Services
  • B. R. Sylvia, Director of Nuclear Operations
  • J. M. Stallings, Vice President-Power Supply and Production

Operations

Three shif t Supervisors

Other licensee employees contacted included five operators.

  • Attended one or more exit interviews.

2.

Exit Interview

Meetings were held with licensee management on September 26, 27, 28, and

October 4, 1979, for those persons indicated in Paragraph I above.

Open

and unresolved items denoted in there details were discussed on September 28,

as was the apparent noncompliance involving blocking of the switch for

LCV-1115A. This modification plus the one involving liquid waste line

LW-81-152 and orifice R0-LW-104 were discussed in detail on October 4,

1979. The inspector's comments were acknowledged by station management.

3.

Licensee Action on Previous Inspection Findings

Not inspected.

4.

Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve noncoapliance or

deviations.

A new unresolved item identified during this inspection is

discussed in Paragraph 5.

.

5.

Event Description

On September 25, 1979, Unit 1 experienced a turbine trip / reactor trip with

a subsequent automatic initiation of safety injection (SI), due to excessive

cooldown of the reactor coolant system (RCS). The following chronology of

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significant occurrences during the event was developed by the inspector

using recorder printouts, traces, log reading and operator interviews.

Times given in the left hand column are approximate.

Time (am)

Event

0609

Turbine trip received due to high level in

low pressure feedwater heater 5B; reactor

trip from turbine trip.

0613

Automatic SI initiated on low pressurizer leve

and pressure due to excessive cooldown of the RCS

caused by a condenser steam dump valve sticking

open.

Reactor coolant pumps were manually tripped in

accordance with IE Bulletin 79-06C.

0619

One charging (HHSI) pump was manually tripped

because RCS pressure was returning to normal.

0620

Pressurizer power-operated relief valve (PORV)

actuated several times due to high RCS

pressure. One HHSI pump still operating.

0627

Letdown orifice valves opened in process of

re-establishing normal makeup and letdown flows,

and termination of SI.

0639

Estimated time of last PORV closure.

0648

Volume control tank (VCT) relief valve lifted,

gases / water were vented to high level waste drain

tank.

0652

Ventilation system radiation monitor reading

increased. Auxiliary building evacuated, air

sampling was initiated.

0717

VCT pressure decreased below relief valve setpoint.

0900

Ventilation system monitor readings returned to

approximately backgi ound values.

Response of plant control systems appeared to be as designed following the

turbine / reactor trip except that condenser steam dump valve, TCV-1408G,

remained open after RCS temperature had returned to the normal hot standby

value (547*F), causing excessive cooldown of the RCS. The cooldown resulted

in automatic SI initiation due to low pressurizer level and pressure. This

will be the subject of a fourteen day written report per Technical Specifi-

cations (0 pen Item 338/79-39-01 identified for followup purposes). During

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the event, other problems were identified. These are discussed briefly

below and will be reviewed in more detail at a later date.

The RCS hot leg cooldown rate of 110 F in approximately thirty minutes

a.

exceeded the 100 F per hour limit of Technical Specification 3.4.9.1.b

(0 pen Item: 338/79-39-02).

b.

The control room bottled air systems did not actuate. is designed upon

receipt of SI signal (Unresolved Item: 338/79-39-03).

c.

A turbine reheat stop valve failed to close when the turbine tripped,

contrary to design (0 pen Item: 338/79-39-04).

d.

A containment Hi-Hi air particulate radiation alarm was received.

This was apparently due to increased leakage across the seals of

reactor coolant pump "C" (0 pen Item: 338/79-39-05).

Following receipt of the SI, all reactor coolant pumps were tripped as

required by IE Bulletin 79-06C. SI was allowed to function for twenty

minutes as required by IE Bulletin 79-06A. In the process of re-estab-

lishing normal RCS makeup and letdown and terminating SI, the volume

control tank (VCT) overfilled, forcing some of contents through the VCT

relief valve, RV-1257

to the high level waste drain tanks (FSAR Figure

11.2.2-1).

The gas spaces of the drain tanks are piped to the process vent

system by design, but plant personnel found that the one-inch line

LW-81-152 had been opened at restricting orifice R0-LW-104 and an elbow

installed such that the tanks were open to auxiliary building atmosphere.

This abnormal configuration was the subject of an investigation condu^ted

October 2-4 and is documented in the Investigation Report appended to this

report.

Station management was informed on October 4 that the abnormal

configuration appeared to be in noncompliance with 10 CFR 50.59(b)

requirements and paragraph 14.5.2 of the Nuclear Power Station Quality

Assurance Manual (NPSQAM) in that it constituted a change to equipment

discussed in the FSAR and had not been evaluated and documented (Infraction

339/79-39-06).

The orifice was reinstalled upon discovery by station

personnel on September 25 and observed that same date by Region II inspec-

tors.

Review of the system by station personnel and Region II inspectors revealed

another potential release path to the auxiliary building which is discussed

in detail in paragraph 10.

.

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Regard.ag overfilling of the VCT, station management informed the inspector

on Septamber 26 that the apparent cause was blocking of the VCT level

control valve, LCV-1115A, to the VCT position by operators using a paper

clip and pencil to keep the control from returning to the auto position.

It was stated that this action had been practiced in the past because

LCV-1115A allowed leakage through to the boron recovery system when in the

auto position. Management further stated that the clip would be removed

from the switch for LCV-1115A and operators instructed not to block the

switch in the future. The necessity for controlling and reviewing such

" modifications" to component functions was discussed by the inspectors. On

October 1, during a tour of the control room, the inspector observed the

switch for LCV-1115A again blocked to the VCT position. Discussions with

members of the operating staff on duty revealed that they did not fully

understand the requirements of 10 CFR 50.59 regarding evaluation required

before changing a system or procedure described in the safety analysis

report. Station management was informed that blocking of LCV-1115A to one

position negated the control function as described on pages 9. 3. 4-7, 9. 3. 4-8,

and 9.3.4-24 of the FSAR and that failure to perform a safety evaluation on

this blocking action appeared to be another example of noncompliance with

10 CFR 50.59(b) and paragraph 14.5.2 of the NPSQAM (Infraction 338/79-39-06).

The inspector stated that a similar citation had been addressed in IE

Report 50-338/79-08.

On October 2 station management informed the inspectors that it had been

determined that LCV-1115A could not have been blocked to V:; position at

the time of the event because a continuous dilution of the RCS requiring

that letdown flow be diverted to the boron recovery system, had been in

progress during the entire shif t except for a brief time. This assertion

was addressed as part of an investigation and is covered in the Investiga-

tion Report appended to this report, which conciaded that the VCT overfilled

due to actuation of the letdown relief valve (RV-1209), which is piped to

the VCT. This relief actuated upon re-establishing letdown when the boron

recovery system gas stripper was isolated by trip valve, (TV-BR-Illa)

leaving no flow path for letdown except via the relief to the VCT.

6.

Radiological Sequence of Events

NRC radiological specialists reviewed plant event recorder printouts,

radiological sample results, radiation monitor printouts, and interviewed

plant staff to determine the sequence of events during the incident.

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Date

Time

Event

Results

_2

9/23

0730

Reactor Coolant Sample

I-131 @ 3.86 x 10

pCi/cc

9/25

0000-0400

Routine Auxiliary Building

No significant activity

Air samples

revealed.

0609

Reac; ,r Trip

0652

Auxiliary Building Ventila-

Monitors response increased

tion Montiors Alarm

by factor of 1000 over back-

ground and returned to normal

by 0900.

0700

Evacuation of Auxiliary

Building

0705-0710

Auxiliary Building Air

259' elevation:

155 times MPC*

Samples

Kryptons and Xenons

NOTE: MPC for noble gases

274' elevation:

101 times MPC*

are based on submersion

Kryptons and Xenons

doses

_5

0720-0803

Ventilation Stack Samples VVA: Xe-133 E 2.0 x 10_s pCi/cc

Xe-135 * 9.6 x 10,3 pCi/cc

VVB: Xe-133

1.0 x 10

pCi/cc

_6

Proc Vent: Xe-133 9.5 x 10_s pCi/cc

Xe-135 3.6 x 10_s pCi/cc

Kr-85m 4.5 x 10_7 pCi/cc

Rb-88

1.1 x 10

pCi/cc

0730

Posted Auxiliary Building as

" Airborne Radioactive Area"

0830-1433

Auxiliary Building Air

Activity reduced by factors

Samples

of 100 and 30 compared to

0750 samples for 274' and 259'

elevations respectively.

_2

0940

Reactor Coolant Sample

I-131 @ 8 x 10

pCi/cc

1400

Unit Containment Entry and

Exposures a 10 mrem

Air Sample

Air activity a 240 times MPC

(This is typical of an

operating facility)

_1

1600

Reactor Coolant Sample

I-131 @ 1.4 x 10

pCi/cc

Approx. 1700

South Fence TLDs removed

No exposures above background.

  • MPC is maximum permissible concentration.

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7.

Estimate of Activity Released

The inspectors reviewed results of the gaseous and particulate grab samples

taken from the auxiliary building vents (A&B) and the process vent. Below

is a tabulation of the results obtaine'., including flow rates.

Released Concentrations (pCi/ml)

Aux. Bldg. Vent A

Aux Bldg. Vent B

Process Vent

Isotope

(50,000 CFM)

(27,000 CFM)

(270 CFM)

Xe-133

2.02 x 10 5

1.01 x 10 5

9.47 x 10 5

Xe-135

9.60 x 10 6

-

3.59 x 10 5

Rb-88

-

-

1.10 x 10 7

Kr-85m

-

-

4.54 x 10 6

From a review of the strip chart recordings on RM-VG-112, the inspectors

ascertained that the duration of the release was no longer than a three

hour period commencing at approximately 7:00 a.m. on September 25, 1979.

Within one hour of the incident, licensee's representatives estimated that

no more than 7.5 curies of Xenon-133 equivalent could have been released

over the three-hour period. The inspectors reviewed the licensee's estimate

and determined that the estimate represented an upperbound because the

release was assumed to occur at a relatively high concentration for the

entire three hour period. The inspectors also determined that: (1) no radio-

active iodine w:. detected in the grab samples from the vents, and (2) no

technical specification release limits were exceeded.

The release rates

were less chan ten percent of the allowable limits as defined by the tech-

nical specifications.

An offsite dose assessment of the released activity was made by licensee's

representatives immediately after the release. Assuming a release of 7.5

curies of Xenon-133 for three hours and actual site meteorology, (average

wind speed of approximately 7.5 miles per hour from the north with two

hours in Pasquill's Stability Class D and one hour in Class E), licensee's

representatives estimated that the maximum site boundary dose to the south

was 3.5 x 10 3 millirad gamma and 1.1 x 10 3 millirad beta and the maximum

nearest residence dose to the south was 1.7 x 10 4 millirem whole body and

,

5.7 x 10 4 millirem skin.

Supporting data was obtained by licensee's

representatives who read the TLDs which were hung on the south protected

area fence. No noticeable increase above background was discernable for

the TLDs. The inspectors had no further questions or observations in this

area.

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8.

In Plant Exposures

Personnel exposures during the event were determined by routine use

a.

of TLDs aud self-reading pocket dosimeters. Pocket dosimeter readings

for the workers initially in the auxiliary building and those who

re-entered for air sampling, etc. , ranged from 5 to 10 millirem. The

workers TLDs were also read, with indicated doses ranging from 3 to

157 mrem. The doses, however, represent exposures for the previous

month, quarter, or for the individual with 3 mrem, the previous two

weeks. An inspector calculated skin (beta) exposures for these workers

using TLD system vendor equations indicating doses from 4 to 13 mrem.

b.

After evacuating the two workers from the auxiliary building at approxi-

mately 7:00 a.m. , several entries were made to draw air samples (partic-

ulate, gas, charcoal) from the auxiliary building general areas, and

reactor containment.

An inspector reviewed the results of these air

samp'es, summarized below and had no additional questions.

Approximate

Time

Location

MPC Fraction

Isotopes

0150

274' Aux. Bldg.

0.007

Rb-88

0405

259' Aux. Bldg.

0.008

Rb-88

0705

274' Aux. Bldg.

101

Kr-88, Xe-133,

& Xe-135

0715

259' Aux. Bldg.

155

Kr-87, Kr-88,

Xe-133, Xe-135

0830

274' Auz. Bldg.

1.1

Xe-133, Xe-135,

& Rb-88

0840

259' Aux. Bldg.

6.0

Xe-133, Xe-135,

& Rb-88

0955

259' Aux. Bldg.

0.7

Xe-133, Xe-135,

& Rb-88

1200

259' Aux. Bldg.

0.003

Rb-88

1400

291' #1 Contain-

ment Building

240

Xe-133, Xe-135

The Rb-88 activity measured before the transient was the result of an

identified small leak from the Gas Stripper. It should also be noted

that the MPC for all the isotopes above are based on submersion doses

and any personnel exposures resulting from the air activity would be

accounted for by TLD dosimetry.

9.

Effluent Monitoring

a.

The release points for airborne activity from the facility, the vent

monitor system, and monitor responses were reviewed.

The release

points and type of monitoring provided are summarized below.

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(1) Ventilation Vent A (VVA) (System flow is about 50,000 cfm). This

system ventilates the auxiliary building general areas, the

control area (Volume Control System) of the auxiliary building,

laboratory vents, sample sink, laundry and health physics areas.

The monitor system includes an isokinetic probe in the vent, a

gas monitor, particulate monitor, and a charcoal filter for

analysis of iodine releases. The monitor response is recorded,

and alarms in the control room.

(2) Ventilation Vent B (VVB) (System flow is about 27,000 cfm). This

system ventilates the Safeguards Building, Fuel Building, and

Decon Building. The Containment Purges are also routed through this

vent.

The monitor system includes an isokinetic probe,

a gas

monitor, particulate monitor and charcoal filter. The monitor

reads out, alarms and is recorded in the control room.

(3) Process Vent (PV) (System flow is about 270 cfm). This system

provides a release path for various tank vents and other sources

that might have airborne activity. The air is processed through

HEPA and charcoal filters prior to discharge. The monitor includes

an isokinetic probe and particulate and gas monitors with readout

recorder and alarms in the control room.

A separate sample

system incorporating a charcoal cartridge is also used.

b.

The inspectors reviewed strip chart recordings of the responses of the

three monitors discussed above. The strip chart (RR-150) recording of

VVA and PV had been removed for examination and were not reviewed by

the radiation specialists. They were reviewed at a later date by the

Resident Inspector.

A review of the computer printout indicating

various alarms revealed VVA (gas) alarmed at 6:52 a.m.

and PV (gas)

alarmed at 6:53 a.m.

The strip charts for VVB and VV' indicated monitor

response increased from 50 cpm to 50,000 cpm (particulate) and from 40

cpm to 10,000 cpm (gaseous) at approximately 6:55 a.m.

Using cali-

bration data of June 8,

1979, an inspector correlated the monitor

response for VVB with isotcpic data, discussed in paragraph 7, and had

no questions.

10.

Verification of Release Pathway

Accompanied by the licensee's representatives, inspectors traced the volume

control tank relief valve discharge pathway. The relief. valve discharges

into line 4"-DH-245-153A-Q3 which flows to the high level ~ waste drain tank

(1-LW-TK-2B) thru line 4"-LW-217-152.

The two high level waste drain tanks

have a six inch crass connect line (6"-LW-63-152) from which a one inch tap

(approximately 10 feet long and designated 1"-LW-81-152) goes through an

orifice (RO-LW-104). At the time of the transient the orifice was not in

place and the open vent line vented to the high level waste drain tank

cubicle on the 259'-6" elevation. The inspectors observed the overflow

cross connection between the high level waste drain tanks and the low level

waste drain tanks (1-LW-TK-3A and 3B).

The four inch cross-connect (line

numbers 4"-LW-91-52, 4"-LW-92-152, 4"-LW-249-159, 4"-LW-94-152 and

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4"-LW-95-152) contains approximately 50 feet of piping, with a locked open

diaphram valve (1-LW-787), between the high and low level waste tanks. The

low level waste drain tanks each have a four inch overflow which branches

off the cross-connect line. During normal operations the low level waste

drain tanks are vented through the process ventilation system. However,

during the discharge of the volume control tank to the high level waste

drain tanks, the high level waste drain tanks as well as the low level

waste drain tanks became pressurized.

The pressurization of the tanks

allowed radioactive gases to escape via the one inch vent line on the high

level tanks (line 1"-LW-81-15) and through the overflow lines (line Nos.

4"-LW-94-152 and 4"-LW-95-152) on the low level waste tanks. Smears taken

by the inspectors on the inside of the overflow lines on the low lev 21

waste tanks indicated the presence of activity.

Readings of several

hundred counts above background were obtained.

Based on pressure drop

considerations, the majority (>90%) of flow of contaminated gases should

have come from the low level waste drain tank overflow lines.

The

inspectors discussed the potential leak path of the low level drain tank

with licensee's representatives.

Licensee's representatives acknowledged

the leak path potential and stated that they were actively pursuing an

engineering evaluation of the problem. The inspectors will followup on

licensee evaluation in future inspections (338/79-39-07).

With the

exception of the orifice, which was identified above, the inspectors

verified the system was installed in accordance with the FSAR.

11.

Fuel Integrity

The inspectors reviewed the reactor coolant sampling program. Below is a

table listing the reactor coolant concentrations of significant isotopes

prior to and after the transient. From the data presented, it is obvious

that no significant fuel degredation resulted from the transient.

The

small increases in the iodine levels are well within the projected increases

for the transient. Based on the review of the data, the inspectors deter-

mined that no technical specifications for reactor coolant activity were

exceeded. The inspectors had no further questions or observations in this

area.

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REACTOR COOLANT ACTIVITY DETERMINATION (pCi/ml)

Isotope

Date: Time

Date: Time

Date: Time

9/23/79:0730

9/25/79:0940

9/25/79:1600

I-131

3.86 x 10 2

8.13 x 10 2

1.42 x 10 1

I-132

2.03 x 10 2

5.97 x 10 2

4.29 x 10 2

I-133

4.77 x 10 2

1.24 x 10 1

1.59 x 10 1

1-134

1.77 x 10 3

1.07 x 10 2

N/D

I-135

1.27 x 10 2

5.46 x 10 2

4.51 x 10 2

Xe-133

3.68 x 10 1

2.19 x 10 1

2.16 x 10 1

Xe-135

1.81 x 10 1

1.50 x 10 1

1.23 x 10 1

Cs-137

N/D

N/D

1.63 x 10 2

Cs-138

1.30 x 10-3

N/D

N/D

N/D = Not determined

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