ML20140E641

Insp Rept 50-416/97-03 on 970209-0322.Violations Noted.Major Areas Inspected:Licensee Operations,Maint,Engineering & Plant Support Activities

ML20140E641
Person / Time
Site:	Grand Gulf
Issue date:	04/24/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140E618	List: ML20140E614 ML20140E635 ML20140E641
References
50-416-97-03, 50-416-97-3, NUDOCS 9704290061
Download: ML20140E641 (17)

See also: IR 05000416/1997003

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ENCLOSURE 2

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV  ;

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Docket No.: 50-416

License No.: NPF-29

Report No.: 50-416/97-03

Licensee: Entergy Operations, Inc.  ;

Facility: Grand Gulf Nuclear Station

Location: Waterloo Road

Port Gibson, Mississippi

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Dates: February 9 through March 22,1997 l

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Inspectors: K. Weaver, Resident inspector  ;

W. Smith, Senior Resident inspector, River Bend Station

Approved By: P. Harrell, Chief, Project Branch D

Division of Reactor Projects  ;

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ATTACHMENT: Supplemental Information  ;

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9704290061 970424 E ,

PDR ADOCK 05000416- i

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EXECUTIVE SUMMARY

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Grand Gulf Nuclear Station i

NRC Inspection Report 50-416/97-03 I

The inspectors evaluated aspects of licensee operations, maintenance, engineering, and

plant support activities. This report covers a 6-week period of resident inspection. )

Operations

Conduct of plant operations was professional and reflected a focus on safety

(Section 01.1).

• The licensee's administrative controls over safety-related keys were effective

(Section 01.2).

• Valves in the flow path of the scram discharge volume portion of the control rod

drive system were properly positioned and locked as required by procedure

(Section 02.1)

Maintenance

• All maintenance activities observed were conducted in accordance with the '

instructions and procedures provided in the work packages (Section M1.1).

• Due to an inadequate review, the impact statement for a work order identified that

the Reactor Recirculation Loop "A" flow transmitter would be out of service instead

of the Recirculation Loop "B" flow transmitter (Section M1.1).

• Operators performed steps of the Division I standby diesel generator (SDG)

operability test out of sequence because of personnel error. Management took

appropriate corrective actions to address the deficient performance (Section M1.2).

• Housekeeping continued to be generally good; however, examples of poor material

condition of equipment were identified (Section M2).

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• Engineering demonstrated poor performance throughout the 6 years it took to

resolvo the issue of properly testing containment isolation boundaries. A violation l

was identified for f ailure to timely generate a condition report (Section E1.1). l

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Plant Suonort

• A poor radiation work practice was noted when a worker mistakenly put the I

screwdriver that he was using to disassemble a potentially contaminated flow I

transmitter in his mouth (Section M1.1).

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A violation for failure to document the results of a contamination survey and to l

update an area radiological survey map was identified (Section R1.1).  !

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Report Details

Summarv of Plant Status

The plant remained at or near 100 percent power throughout this inspection period,

l. Operations

01 Conduct of Operations

01.1 General Comments

The inspectors conducted frequent reviews of ongoing plant operations including

control room observations, attendance at the licentee's plan-of-the-day meetings,

and plant tours, in general, the conduct of plant operations was professional and

reflected a focus on safety. The control room viss operated in a formal manner

with good communications. Operator respons<as to alarms were observed to be

appropriate to the circumstances and the alarm response instructions were

consulted in each case observed.

01.2 Review of Safety Related Kev Controls

a. Insoection Scope (71707)

The inspectors reviewed the licensee's administrative controls over keys used by

plant operating and maintenance personnel for the purpose of locking valves,

switches, and cabinets associated with safety-related systems.

b. Observations and Findinas

On March 11,1997, the inspectors reviewed Operations Section

Procedure 02-S-01-9, " Key Control," Revision 18. The procedure specified in detail

what keys were to be controlled by the Shift Superintendent in a locked cabinet in

the control room. The procedure also provided instructions on the use of operator

locks and implemented monthly key control reviews to ensure that the

administrative controls were being met and that all required keys were accounted

for.

The inspectors reviewed the Shift Superintendent's key locker and picked keys at

random and found them to be properly accounted for. The inspectors reviewed the

documentation of the monthly key control reviews for the past several years and

found the reviews had been completed every month, as specified by

Procedure 02-S-01-9. As an area for improvement, the inspectors noted that the

Monthly Key Control Review attachment provided by the procedure did not contain

a signature blank for the reviewer to sign. There was, however, a blank for the

Shift Superintendent to sign in acknowledgement that he was informed of any

missing keys. The records indicated that the Shift Superintendent always signed

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the form acknowledging whether or not keys were missing. The licensee's reviewer -

stated that he always signed a separate cover indicating, fct the record, who the

reviewer was. This was considered' acceptable.

c. Conclusions.

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The licensee's administrative controls over safety-related keys were effective and

adequately documented. The licensee demonstrated that all keys were consistently i

, accounted for on a monthly basis.

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02 Operational Status of Facilities and Equipment

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02.1 Enaineered Safetv Feature System Walkdown (71707)

The inspectors used Inspection Procedure.71707 to walk down the scram discharge

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volume portion of the control rod drive system (C11). Valves in the flow path were  ;

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! properly positioned and locked as required by Procedure 04-1-01-C11-1, " Control

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Rod Drive Hydraulic System," Revision 103. Housekeeping in the area and the

, material condition of the components was good. No problems were identified with

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the exception of a missing component label from the C11-F134D scram discharge -

volume Channel D test connection valve. The inspectors notified the licensee and a

label was promptly installed on the valve. .

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11. Maintenance

M1 Condu:* of Maintenance

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M 1.1 General Maintenance Comments

a. Insoection Scooe (62707)

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The inspectors observed portions of maintenance activities, as specified by the

following WOs:  ;

• WO 00136035: Recirculation Loop A Flow Transmitter; Replac. Electronics

• WO 00180928: Accident Range Monitor AXM-1 Calibration

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• WO 00183260: Local Power Range Monitor Calibration

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b. Observations and Findinas

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In general, the inspectors found the performance of this work to be satisfactory. All

work observed was conducted in accordance with the instructions and procedures 7

provided in the. work packages. Maintenance craft personnel were found to be

knowledgeable of the work activities and equipment. One instance of poor radiation

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worker practices was noted when a worker mistakenly put in his mouth the

screwdriver that he was using to disassemble the Recirculation Loop A Flow

Transmitter 1B33N0148, which was located in a radiologically controlled area.

During a subsequent review of the completed work package for WO 00183260, the

inspectors noted that the impact statement identified that the work activity would

require Reactor Recirculation Loop B Flow Transmitter 1B33N014B to be out of

service; however, the work activities were for the Reactor Recirculation Loop A

flow transmitter. The inspectors interviewed maintenance planning personnel to -

determine if a review was conducted for the impact statement prior to issuance.

The licensee responded that a review was performed, but the error was not

identified. No problems due to the inaccurate impact statement were noted by the c

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inspectors during the performance of this work and the appropriate Technical

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Specification (TS) action statements were entered. The licensee initiated CR 1997-

0291 to address the incorrect impact statement. In addition, the licensee reviewed

the repetitive tasks for the Recirculation Loop A Flow Transmitters 1833NO14A, B,

C, and D and for the Recirculation Loop B Flow Transmitter 1833NO24A, B, C, and

D to ensure they referenced the correct recirculation loop.

c. Conclusions j

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The performance of observed maintenance activities was satisfactory. All work ,

observed was conducted in accordance with the instructions and procedures

provided in the work packages. Maintenance craft were found to be knowledgeable

of the work activities and equipment. One instance of poor radiation work practices i

was noted when a worker mistakenly put in his mouth the screwdriver that he was

using to disassemble the Recirculation Loop A Flow Transmitter 1B33N014B, which

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is located in a radiologically controlled area.

M1.2 Division i SDG Ooerability Surveillance Test

a. Inspection Scoce (61726)

The inspectors observed portions of, and reviewed the results of, the monthly

operability test performed in accordance with Surveillance

Procedure 06-OP-1P75-M-0001, " Standby Diesel Generator (SDG) 11 Functional

Test," Revision 102.

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b. Observations and Findinas

On March 11, after the operators obtained permission to start the test in

accordance with Step 5.3.1 of Procedure 06-OP-1P75-M-0001, the SDG was

, placed in the " maintenance" mode per Step 5.3.2 and liquid levels were checked

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per Step 5.3.3 Step 5.3.3.a required the operators to verify engine lubricating oil

temperatures between 130 and 170 F. This criterion was not met because the

j temperature was 174.5 F. The operators then proceeded to air roll the SDG per

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) temperature was 174.5oF. The operators then proceeded to air roll the SDG per

Step 5.3.5. At this point, the inspectors questioned where the operators were in

the procedure and the operators responded by stating that they had made an error

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by skipping Step 5.3.4, which required an operational check of the auxiliary jacket

, water and lubricating oil pumps. The operators then proceeded to perform the

pump checks _ per Step 5.3.4. Subsequently, the operators informed the control

i room that they had performed Step 5.3.4 out of sequence and that lubricating oil

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temperature was above the 170 F limit. With assistance from the SDG System

I' Engineer, the operators determined that there was no technical problem with

! performing the jacket water and lubricating oil pump checks at the time it was

! performed; however, there appeared to be a problem with the lubricating oil heater

because it was energized when there was no need for heating.

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i The Shift Superintendent secured the test and restored the SDG to the standby

status pending troubleshooting and repair of the lubricating oil heater circuits. The

i Shift Superintendent also initiated an Event Free card to enter the out-of-sequence -

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performance of the procedure into the licensee's corrective action program. The

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Event Free Operation Program provided a mechanism for Operations personnel to

! conveniently document either good or poor performance issues for analysis. In this

case, the card became a precursor to a CR, which was subsequently initiated as

CR 97-0242. The inspectors questioned whether such a program might tend to

i circumvent the CR program. The licensee assured the inspectors that such has not

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been the case and that CRs were initiated where appropriate.

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Administrative Procedure 01-S-02-1, " Description and Use of the GGNS Operations

Manual," Revision 21, Section 5, stated that steps within procedures should be

completed in the sequence specified unless otherwise allowed by the procedure. j

j The word should was defined by this procedure as a management expectation >

t requiring management approval to deviate, and not a regulatory requirement.

Performing the pump checks out of sequence as described above did not violate the

i technical requirements or intent of the surveillance procedure and thus the

j regulatory requirements for following the test procedure were met.

Licensee management indicated that their expectations were clearly not met for

operator performance. As corrective action, the individual operators were

counseled, a memorandum was issued on March 12 to Operations personnel

reinforcing the level of performance expected, and the shift involved was tasked to

investigate the issue under the Event Free Operation Program.

On March 12, a faulty lubricating oil heater contactor was replaced; however, the

root cause of the temperature being above 170 F was the overlap of the heater

controller setpoint tolerance combined with the temperature indicator accuracy

tolerance. This was corrected by revising the surveillance procedure to allow an

indicated oil temperature of 130 to 180 F. Subsequently, the SDG operability test

was performed satisfactorily. The inspectors reviewed the completed test data and

noted that all acceptance criteria were met and the test was properly documented.

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c. Conclusions

The operators performing the Division l SDG operability test demonstrated poor

performance in that the auxiliary jacket water and lubricating oil pumps were tested

out of sequence because of personnel error. Management took appropriate

corrective actions to address the performance deficiency.

M2 Maintenance and Material Condition of Facilities and Equipment (62707)

During plant tours, the inspectors noted that housekeeping continued to be

generally good throughout the plant; however, the following examples of poor

material condition of equipment were identified by the inspectors and appropriately

corrected by the licensee. No system or component operability concerns were

identified.

• Approximately 16 square inches of corrosion and flaking of the coating was

noted in the outside bend on the discharge piping elbow immediately

downstream of standby service water Pump A. The inspectors questioned

whether the licensee had recently determined wall thickness as part of their

erosion / corrosion program and the response was that this pipe fitting was

not in the program. CR 97-0251 was initiated and the licensee promptly

performed an ultrasonic test to determine wall thickness and found it to be in

the range of 0.413 to 0.455 inches, with a specified minimum wall thickness-

of 0.375 inches. The licensee stated that the corroded area would be

cleaned and repainted. This action was considered to be satisfactory.

• High pressure core spray Division ill batteries were in poor condition with

copper sulfate corrosion dripping between the battery cells onto the floor,

signs of corrosion on the busbars, very little antioxidation grease on the

busbars, and wetness on the top of the batteries. The_ inspectors notified

the Maintenance Manager and the batteries were subsequently cleaned.

• TS Fire Door OC-709, for the control building cable spread room, had a

broken mechanism and would not latch. TS Fire Door OC-710 was not

properly latched. When notified by the inspectors, the licensee promptly

added the doors to the roving fire watch list and condition identification

. reports were written to correct the problem.

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El Conduct of Engineering

l E1.1 Residual Heat Removal (RHR) A and B Test Return Pioina Submeraence Issue

a. Inspection Scope (375511

The inspectors reviewed the licensee's actions in response to CR 97-0201, in which

Design Er.gineering identified design basis accident conditions where the test return

piping from the RHR A and B systems may not be submerged in the suppression

pool. Consequently, the medium used for 10 CFR Part 50, Appendix J,

containment isolation valve testing for the associated penetrations may have been

water, when it should have been air.

b. Observations and Findinas

On March 3,1997, while reviewing containment penetration piping that

communicated with the suppression pool, the licensee's design engineer reported in

CR 97-0201 that the test return piping from the RHR A and B systems could

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become uncovered and open to the containment atmosphere if the suppression

pool level reached the minimum drawdown level of 107 feet,6 inches elevation

following a loss-of-coolant accident. The design elevation of the horizontally run

section of 12-inch piping was 107 feet,4-1/2 inches at the centerline, leaving

1 1/2 inches of the piping open to the containment atmosphere. The associated

containment isolation valves were leak tested using water instead of air because it

was assumed that the piping was always submerged below the surface of the

suppression pool.

Material Nonconformance Report MNCR-0012-91 identified a similar condition in

1991 with two RHR relief valve outlet pipes that terminated at elevation 108 feet,

8 inches and 108 feet,1/2 inch, which was higher than the RHR test return pipes.

The engineer was aware of the resolution of the concern with the RHR piping, and

as a result, recommended that the operators consider the RHR test return valves

operable pending further evaluation. The 1991 report contained an evaluation

showing that there was sufficient margin in the design and operating assumptions

such that the relief valve piping would not become uncovered; therefore, using

water for the leak test was appropriate. The operators accepted the engineer's

recommendation and did not enter a TS limiting conditions for operation.

On March 11, the inspectors became aware of this issue when the licensee

provided the CR and the final operability evaluation, which demonstrated that with

all emergency core cooling system (ECCS) pumps running, suppression pool level

i would only drop to approximately 108 feet,11 inches elevation in 10 minutes after

the event, after which the operators would be controlling reactor pressure vessel

level at or below Level 8. Also, with all ECCS pumps running, the RHR A and B

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systems would be pressurized, precluding containment leakage into the system via

l the test return valves. The inspectors reviewed the evaluation and found it to have

a credible basis: however, the inspectors were concerned about the adequacy of

corrective actions taken in response to the 1991 issue. The inspectors reviewed

the 1991 report and questioned licensee personnel as to the sequence of events on

this issue.

On February 11,1991, in response to a problem that occurred at another plant, the

licensee was reviewing containment penetrations and found the problem discussed

above with the outlet pipes on two RHR relief valves. As corrective action, the

licensee decided to test the penetrations with air, which was proper for piping that

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would not be submerged at minimum suppression pool drawdown level. The

inspectors did not find any indication in the 1991 documentation that the licensee

intended to determine if there were any other penetrations similarly designed with

the inappropriate test medium specified. The licensee explained that a review was

completed, but it was not documented. In addition, the licensee suggested that the

review might have overlooked the fact that the RHR test return pipes were run

horizontally and, therefore, the open end of the pipes were exposed to the

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containment atmosphere earlier than the specified centerline elevation might have

implied.

On October 20,1993, the licensee issued the final disposition for the 1991 report,

which confirmed that the test medium was air, thereby resolving the relief valve

discharge piping issue. In addition, the disposition document required plant staff to

review the configuration of all other penetrations communicating with the

suppression pool to ensure proper testing was being performed.

On July 31,1995, Report MNCR-0012-91 was closed without having completed

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the penetration review. Closure documentation, dated July 21,1995, stated that

! the review did not need to be performed because Nuclear Plant Engineering initiated

an independent review of all containment penetrations for other reasons. However,

that review did not address the original problem of ensuring that all penetrations

i were being properly tested.

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in February 1997, during an independent design basis review, the design engineer

l became aware of questions regarding closure of Report MNCR-0012-91, as it l

l re?ated te Ine accomplishment of the above review. The design engineer  !

commenced the intended review.

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On February 28,1997, the design engineer discovered the problem with the RHR A

and B test return lines. With his supervisor's concurrence, the design engineer did

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not initiate a CR until March 3, because there was a long weekend pending and he

stated he had confidence that there was no operability problem based on his l

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knowledge of the operability evaluation completed for the 1991 relief valve )

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discharge piping issue. This was contrary to Procedure 01-S-03-10, "GGNS

Condition Report (CR)," Revision 0, Paragraph 6.1.1, which required a condition

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j report be initiated whenever a nonconformance is discovered. The significance of

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this was that the licensed operators were not informed of the potential inoperability

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of the containment penetrations such that an evaluation could be performed to ,

j verify compliance with the plant operating license. Furthermore, Design Engineering

l did not have the authority to make the operability determination. Failure to initiate a  ;

CR upon discovering that the RHR A and B test return containment penetrations '

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i may have not been tested properly is a violation of TS 5.4.1 for the failure to follow

Procedure 01-S-03-1-0 (50-416/97003-01).

The licensee designated CR 97-0201 as a significant CR requiring a Corrective  ;

Action Review Board. Licensee management indicated that the root cause

determinations and associated corrective actions would be expected to address

both the technical and administrative aspects of the above issues.

c. Conclusions

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' Engineering demonstrated poor performance throughout the 6 years taken to resolve l

the issue of whether or not all containment isolation boundaries communicating

with the containment atmosphere or the suppression pool were being properly

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tested. When engineering finally commenced the review, another problem was

identified, but the CR was delayed for nearly 4 days to allow for a long weekend. A

violation was identified for failure to comply with the administrative procedure for

timely condition reporting.

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E1.2 Paintina Effects on Standbv Gas Treatment System (SGTS) and Control Room Fresh  ;

Air (CRFA) System Charcoal Filters

a. Insoection Scoce (37551) L

During this inspection period, the inspectors reviewed CR 1996-0500, which .

documented that the SGTS A ran for 49 minutes while painting was in progress in  !

the auxiliary building. The inspectors also reviewed the applicable TS surveillance

requirements associated with the required testing of the engineered safety

feature (ESF) filtration units following painting.

b. Observations and Findinos

During the review of CR 1996-0500, the inspectors noted that operations personnel

had reque.sted engineering to evaluate what effect the painting in the auxiliary

building and running the SGTS A had on the system's charcoal filter. Engineering

Request (ER) 96-0959 was written to address this concern. _The inspectors noted

that engineering's reply to ER 96-0959 determined that the conservative total

amounts of volatile organic compounds that were released constituted

approximately 0.82 percent by weight of the total amount of charcoal in the SGTS

A filter train charcoal bed. ER 96-0959 also indicated that, based on testing ,

performed on carbon filters at two other nuclear power stations, the charcoal could i

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absorb at least 10 percent by weight of volatile organic compounds and meet

l removal efficiency requirements. ER 96-0959 concluded that the testing

l requirements specified by TS 5.5.7 and Regulatory Guide 1.52 could be waived for  ;

l SGTS A. The inspectors also reviewed ER 96-0946, which documented that the 1

SGTS B was started before the required wait time of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> following painting

l that communicated with the ventilation zones. ER 96-0946 concluded that the

testing requirements specified by TS 5.5.7 and Regulatory Guide 1.52 could be

waived for SGTS B.

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The inspectors noted that TS 5.5.7 stated that a program shall be established to '

l implement the following required testing of ESF filter ventilation systems at the

frequencies specified in Regulatory Guide 152, Revision 2.  ;

a. Demonstrate for each of the ESF systems that an inplace test of the high  !

efficiency particulate air (HEPA) filters shows a penetration and system

bypass < 0.05 percent when tested in accordance with Regulatory Guide

l 1.52, Revision 2, and ANSI N510-1975 at the system flowrate specified i

l below 10 percent.

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b. Demonstrate for each of the ESF systems that an inplace test of the charcoal

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absorber show a penetration and system bypass < 0.05 percent when

tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI

N510-1975 at the system flowrate specified below 110 percent.

c. Demonstrate for each of the ESF systems that a laboratory te :t of a sample

of the charcoal absorber, when obtained as described in Regu!atory 1

i Guide 1.52, Revision 2, shows the methyl iodide penetration less than the

l value specified below when tested in accordance with Regulatory

l Guide 1.52, Revision 2, Regulatory Position C.6.a, and greater than or equal

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to the relative humidity (RH) specified below

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ESF Ventilation System Penetration RH

SGTS 0.175% .70%

CRFA O.175% 70 %

The inspectors noted that the specified frequencies stated in Regulatory Guide 1.52,

Revision 2, for the above testing requirements were: (1) after any structural

maintenance on the HEPA filters; (2) following painting, fire, or chemical release in

l any ventilation zone communicating with the subsystem; or (3) after each complete

or partial replacement of a HEPA filter bank. The inspectors also noted that the

Technical Requirements Manual, Section 7.6.3.4, also stated these same

frequencies.

The inspectors questioned the licensee concerning conformance with the applicable

testing frequencies specified in Regulatory Guide 1.52 in that it was specifically

l stated that the testing requirements were to be performed following painting in any

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ventilation zone communicating with the system. The inspectors questioned the

licensee concerning the fact that there was no specific wording in Regulatory

Guide 1.52 that allowed the licensee to waiver those requirements based on

evaluation of how much volatile organic compounds entered the charcoal beds

following painting activities. The licensee determined that their policy conformed

with the current industry standard methods for complying with Regulatory

Guide 1.52 and TS requirements for testing the ESF filtration systems following

painting activities in any ventilation zone.

The inspectors further questioned the licensee as to what basis was provided for

l the wait time following painting of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> for the SGTS and 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for the ,

! CRFA units, as specified in Procedure 01-S-7-37, " Control of Work for Penetrations,

Painting, Snubbers and Insulation," Revision 101. At the end of this inspection

period, the licensee had not provided an engineering basis for the length of time

value. The inspectors questioned the licensee concerning what administrative

l controls were in place that would ensure that, upon an initiation 'of an ESF filtration

j system, the charcoal filters would not be degraded below their required efficiency

due to ongoing painting activities in the ventilation zones. The licensee responded

j that no administrative controls were in place and no limit had been established to ,

control the amount of paint or volatile organic compounds that could be taken in

l areas or used in areas that communicated with the ESF filtration ventilation zones.

At the end of this inspection period, the licensee was in the process of developing a )

formal request for submission to the NRC's Office of Nuclear Reactor Regulation for l

l an interpretation of the wording in Regulatory Guide 1.52, in addition, the licensee ' l

l initiated CR 1997-0195 and was evaluating and developing administrative controls I

for painting activities that communicated with the ESF filtration ventilation zones.

The licensee suspended all painting activities in safety-related ventilation zones until

j the procedural guidance could be developed.

Further evaluation of the licensee's conformance with TS 5.5.7 and the lack of

l administrative controls for painting in areas that communicate with ventilation zones

l of the ESF filtration systems is considered an unresolved item pending a review of

the licensee's interpretation request of the wording of Regulatory Guide 1.52

, (50-416/97003-02).

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Further evaluation of the licensee's conformance with TS 5.5.7 and the lack of

administrative controls for painting in areas that communicate with ventilation zones

of the ESF filtration systems is considered an unresolved item. j

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E2 Engineering Support of Facilities and Equipment

E 2.1 Review of Facility and Eauioment Conformance to Updated Finial Safety Analysis

Report (UFSAR) Descriotion (71707. 37551)

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While performing the inspections discussed in this report, the inspectors reviewed

the applicable portions of the UFSAR that related to the areas inspected. The  !

inspectors verified that the UFSAR wording was consistent with the observed plant

practices, procedures, and parameters. No anomalies between the UFSAR and

operation of the facility were identified.

IV. Plant Support

R1 Radiological Protection and Chemistry Controls

R 1.1 General Comments (71750)

a. inspection Scope

Using inspection Procedure 71750 as guidance, the inspectors made frequent tours

of the radiologically controlled area and observed radiological postings and worker

adherence to protective clothing requirements.

b. Observations and Findi: ..jii

During a routine tour conducted on March 4, the inspectors noted a packing leak on

the Reactor Core Isolation Cooling Steam Supply Bypass isolation Valve E51-F094

and notified the Shift Superintendent. This valve had previous problems with

packing leaks and the inspectors were concerned that the steam leak could cause

increased airborne contamination levels in the room. Shortly after the notification, ,

the inspectors interviewed the Shift Superintendent concerning the valve and were l

informed that operations personnel had inspected the valve, concluded that there

was a packing leak, and initiated Condition identification 62784. Later in the day, I

upon entry into the radiologically controlled area, the inspectors notified health

physics personnel of the possible packing leak on Valve E51 F094 so an evaluation

of the possible radiological changes could be made, since the valve was leaking

reactor main steam. Health physics personnel indicated that an investigation of the i

valve would be performed. The inspectors were subsequently informed that health

physics technicians had visually inspected the valve on March 5 and determined )

that no significant radiological problems existed due to the steam leak.  !

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The inspectors were informed later that a contamination survey was performed on I

February 27 or 28 and no noticeable contamination was noted; however, the survey )

was not documented on an approved health physics form as required by Procedure

08-S-02-50, Radiological Surveys and Surveillances," Revision 101. The f ailure to

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document the contamination survey performed on February 27 or 28 is the first l

example of a violation of TS 5.4.1 (50-416/97003-03). I

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During a subsequent tour of reactor core isolation cooling room on March 10, the '

inspectors noted the packing leak had gotten worse and that there was

approximately a 6-inch steam plume from the valve. The inspectors also noted that

no contamination area sign was posted and no catch basin had been installed to

preclude the potentially contaminated fluid from spreading to other areas. The

inspectors immediately notified health physics technicians. The health physics

technician promptly responded and surveyed the valve for contamination and noted

that the highest contamination level on the valve was 4000 dpm/100 cm2 . The

health physics technician installed a catch basin to contain the fluid; however, no

contamination area sign was posted on the valve. Procedure 01-S-08-2, " Exposure

and Contamination Control," Revision 103, required an area, where removable

surface contamination is greater than or equal to 1000 dpm/100 cm ,2 be posted

with signs stating CAUTION, CONTAMINATION AREA (or similar). The inspectors

questioned radiation protection management personnel concerning the posting

requirements for contamination areas. The licensee responded that Procedure 08-

S-02-20, " Establishing and Posting Controlled Areas," Revision 15, stated that _,

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yellow catch basins are used for contaminated system leaks and, by virtue of their

color, should be considered contaminated and that all proper radiological controls

apply; therefore, installation of a yellow catch basin was considered to be

equivalent to the posting specified in Procedure 01-S-08-2. <

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During a subsequent tour, the inspectors noted that the packing leak had again

increased and was approximately a 1-foot steam plume. _The inspectors also noted

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that a contamination posting was subsequently placed on the valve along with the i

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previously installed yellow catch basin. However, the inspectors noted that the

area radiological survey map, dated March 14, was not updated to include the

contamination identified on March 10. The inspectors notified health physics and

the survey map was updated. The inspectors were subsequently informed that the

area survey map had also not been updated on March 10, after the initial

identification of the contamination on the valve.

The inspectors previously identified and documented, in NRC Inspection Report 50-

416/96 20, that several area radiation survey maps was not properly updated

following radiological surveys that were performed. The licensee issued CR 1996-

0594 to address the issue and promptly updated the respective survey maps. The l

inspectors reviewed the corrective actions for CR 1996-0594 and noted that the ]

individual involved in not updating the map was verbally counseled on the

importance of updating wallmaps to provide the workers with current area l

radiological conditions, and training was held for all health physics technicians on

the need to update wallmaps. CR 1996-0594 was closed and the corrective

actions were completed.

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l Procedure 01-S-08-2 required all radiation workers to be aware of the radiological l

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conditions (radiation, contamination, and airborne levels) in any posted area before i

entry. Section 6.7.2 stated that all radiation workers are required to review

appropriate radiological survey information before entering a posted area.

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Failure to update the radiological area survey map that provided information to the

radiological worker to include the existence of contamination and contamination

levels on Valve E22-F094 is the second example of a violation of TS 5.4.1

(50-416/97003-03).

c. Conclusions _

l A violation for failure to document a contamination survey and to update the area

l radiological survey map was identified.

V. Manaaement Meetinas

X1 Exit Meeting Summary >

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The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on March 27,1997. The licensee acknowledged the findings

presented.

l The inspectors asked the licensee whether any materials examined during the inspection

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should be considered proprietary. No proprietary information was identified.

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ATTACHMENT

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

C. Abbott, Quality Programs Supervisor, Quality Programs

D. Bost, Director, Design Engineering

C. Bottemiller, Superintendent, Plant Licensing

C. Brooks, Licensing Specialist, Plant Licensing

J. Burton, Mechanical / Civil Engineering Manager, Nuclear Plant Engineering

L. Calvery, Root Cause Analyst, Performance and System Engineering

D. Cotton, Health Physics Supervisor, Radiation Protection

L. Daughtery, Technical Coordinator, Plant Licensing

W. Deck, Superintendent, Security

B. Eaton, General Manager, Plant Operations

C. Elisaesser, Manager, Performance and System Engineering

M. Guynn, Radiation Control Supervisor, Health Physics

C. Holifield, Licensing Engineer, Plant Licensing

W. Huey, Director, Plant Licensing

M. Larson, Senior Licensing Specialist, Plant Licensing

M. McDowell, Operations Superintendent, Plant Operations

A. Morgan, Manager, Emergency Preparedness

S. Saunders, Electrical Engineering Manager, Nuclear Plant Engineering

W. Shelly, Technical Coordinator, Training

T. Tankersley, Senior Oversight Specialist, Corporate Assessments

J. Venable, Operations Manager, Plant Operations

G. Vining, Manager, Plant Material and Control

NRC

J. Donahew, Project Manager, Office of Nuclear Reactor Regulation

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INSPECTION PROCEDURES USED l

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37551 Onsite Engineering

61726 Surveillance Observations l

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62707 Maintenance Observation j

71707 Plant Operations

71750 Plant Support Activities

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ITEMS OPENED. CLOSED, AND DISCUSSED l

Opened l

50-416/97003-01 VIO Failure to initiate a CR upon discovery of a deficient

condition (Section E1.1)

50-416/97003-02 URI Evaluation of licensee's conformance with Regulatory

Guide 1.52 on painting (Section E1.2)

50-416/97003-03 VIO Two examples of the failure to follow radiological

protection procedures (Section R1.1)

LIST OF ACRONYMS USED

CFR Code of Federal Regulations

CR Condition Report

ECCS emergency core cooling system

ESF engineered safety feature

ER Engineering Request

HEPA high energy particulate air

MNCR Material Nonconformance Report

RCIC reactor core isolation cooling

RHR residual heat removal

CRFA control room fresh air system

SGTS standby gas treatment system

SDG standby diesel generator

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

URI unresolved item

VIO violation

WO work order

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