ML20155A187

Insp Rept 50-482/98-17 on 980823-1003.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support.Use of Fire Protection Sys Pumps for Purposes Other than Fire Protection Constituted Degradation of Sys

ML20155A187
Person / Time
Site:	Wolf Creek
Issue date:	10/22/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20155A179	List: ML20155A174 ML20155A187
References
50-482-98-17, NUDOCS 9810280169
Download: ML20155A187 (19)

See also: IR 05000482/1998017

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ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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Docket No.:

50-482

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License No.:

NPF-42

Report No.:

50-482/98-17

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Licensee:

Wolf Creek Nuclear Operating Corporation

Facility:

Wolf Creek Generating Station

Location:

1550 Oxen Lane, NE

Burlington, Kaqsas

Dates:

August 23 through October 3,1998

Inspectors:

B. A. Smalldridge, Acting Senior Recident inspector

R. V. Azua, Project Engineer, Project Branch B

D. Passehl, Senior Resident inspector, Callaway

Approved By:

W. D. Johnson, Chief, Project Branch B

ATTACHMENT:

Supplemental Information

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9810280169 981022

PDR

ADOCK 05000482

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EXECUTIVE SUMMARY

Wolf Creek Generating Station

NRC inspection Report 50-482/98-17

Operations

The lack of a policy to verify the restoration of systems or components on which work or

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testing was not fully complete contributed to the failure of the reactor coolant system

makeup control valve to operate as expected. Operators did not verify that the control

valve was properly restored before it was returned to operation following the suspension

of a calibration procedure by maintenance technicians (Section 01.1).

The licensee identified and responded to an increase in component misposition events.

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The licensee's response provided techniques for use by site personnel to prevent

component misposition events and raised the level of awareness and attention for this

issue to site management and personnel (Section 01.2).

The licensee failed to ensure that turbine trip instrumentation surveillance tests were

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performed during the required modes of operation as required by Technical

Specifications. This nonrepetitive, licensee-identified and corrected violation is being

treated as a noncited violation consistent with Section Vll.B.1 of the Enforcement Policy.

This issue was identified by the licensee in Licensee Event Report 50-482/9722-00

(Section 08.3).

Maintenance

The licensee failed to properly test Pressurizer Pressure Permissive P-11, because

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of an inadequate design. This nonrepetitive, licensee-identified and corrected violation

is being treated as a noncited violation consistent with Section Vll.B.1 of the

Enforcement Policy. This issue was identified by the licensee in Licensee Event

Report 50-482/9710-00 (Section M8.2)

Enaineerina

Licensee management demonstrated a questioning attitude durir g an engineering

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presentation on the health of the residual heat removal system by asking challenging

questions regarding long-term operability and bearing lube oil volume and demanding

adequate responses (Section E7.1).

Plant Support

The inspectors identified maintenance technicians working greater than 8 feet above the

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floor inside the radiologically controlled area without first contacting health physics. This

supported the conclusion in NRC Inspection Report 50-482/98-15 that there was a

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deficiency in radiation worker knowledge regarding the requirement to contact health

physics before working in the overhead in the radiologically controlled area

(Section M4.1).

Observations by the inspectors of poor radiological work practices indicated a deficiency

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in the knowledge of some radiation workers regarding contaminated area boundary

controls and methods of preventing the spread of contamination (Section R1.1).

Weaknesses were identified in the licensee's stop-work criteria and in identifying the

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increased potential for airborne radioactivity, known to exist, to workers performing

reactor coolant system filter shearing operations. The stop-work criteria was based

soley on the dose from the high efficiency particulate air filtration unit and a known

increased potential for airborne radioactivity was not communicated to the workers

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(Section R1.2).

The inspectors noted a reduction in the number of storage containers and installed drip

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bags, and a generally improved appearance inside the radiologically controlled area

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because of licensee housekeeping improvement efforts directed at reducing the

resources required to maintain tools and equipment, and improved surveying

capabilities inside the radiologically controlled area (Section R2.1).

Use of fire protection system pumps for purposes other than fire protection constituted a

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significant degradation of the fire protection system and was contrary to license

conditions. This nonrepetitive, licensee-identified and corrected violation is being

treated as a noncited violation consistent with Section Vll.B.1 of the Enforcement Policy.

This issue was identified by the licensee in Licensee Event Reports 50-482/9716-00,01,

and 02 (Section F8.1).

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Report Details

Summary of Plant Status

The plant operated at essentially 100 percent power throughout the inspection period.

I. Operations

01

Conduct of Operations

01.1

Review of Operations Deoartment Process for System Restoration

a,

insoection Scoce (71707)

The inspectors reviewed the operations department process for verifying that

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components, systems, and system configuration is restored to a known or operable

condition following the suspension or interruption of a surveillance or work procedure.

b.

Observations and Findinas

On August 21,1998, reactor operators attempted to dilute the reactor coolant system for

temperature control. However, ret.ctor coolant system makeup Valve BG FCV-111 A

failed to open as expected. Upon investigation, a nuclear station operator found that a

local instrument air valve to the makeup valve positioner was isolated. The instrument

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air valve was opened and system operability was restored. This was identified in

licensee Performance Improvement Request 98-2484.

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Further investigation by the operations and maintenance departments identified that

work had been performed on Valve BG FCV-111 A earlier in the day per

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Procedure STN IC-420A," Calibration of Boric Acid Blend Flow Transmitters,"

Revision 4. The procedure was suspended before it was completed and the system

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restoration portion of the procedure was not accomplished. The maintenance

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technicians who conducted the procedure did not use a formal system restoration

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procedure to restore the system, which resulted in leaving the instrument air valve in the

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closed position instead of open. When the technicians returned the makeup valve to the

operations department, the operators did not verify that system configuration was

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restored procedurally nor was a nuclear station operator sent to verify system

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configuration before the component was returned to service.

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The inspectors determined during followup discussions with the licensee that the

operations department had no formal expectation or policy to verify the restoration of

components or systems on which work or testing is not fully complete with the

expectation to use the component / system as fully functional. The inspectors noted that

this contributed to the failure of the reactor coolant system makeup valve to open as

expected. The licensee initiated an evaluation to determine if a policy for verifying

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adequate restoration should be developed for components or systems on which work or

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testing is not complete when returned to service.

c.

Conclusions

The lack of a policy to verify the restoration of systems or components on which work or

testing was not fully complete contributed to the failure of the reactor coolant system

makeup control valve to operate as expected. Operators riid not verify that the control

valve was properly restored before it was returned to coeration following the suspension

of a calibration procedure by maintenance technicians.

01.2 Licensee Pesponse to an increase in Component Misposition Events

a.

Inspection Scoce (71707)

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The inspectors reviewed the licensee's response to a self-identified increase in the

number of sitewide component misposition events.

b.

Observations and Findinas

The inspectors noted an increase in the number of sitewide component misposition

events beginning in mid-August 1998. The components found out of position included:

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Breaker NG03CHF3, for Valve EG HV-0015, component cooling water service

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loop return isolation valve. This was identified in Performance improvement

Request 98-2327.

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Valve EF V-0247, essential service water prelube storage tank cross-connect

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valve. This was identified in Performance Improvement Request 98-2840.

An unlabeled instrument air isolation valve to Valve BG FCV-111 A, reactor

makeup water to boric acid blender tee valve. This was identified in

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Performance Improvement Request 98-2484.

Damper GK HIS-0060, control room filter System A supply damper. This sas

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identified in Performance improvement Request 98-2868.

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During subsequent discussions with site management, the inspectors noted that, while

none of these component misposition events had an impact on safety or indicated a

programmatic problem, when taken in aggregate there was cause for concern. The

licensee responded that this trend of increasing component misposition events had

been identified and steps were underway to correct the trend.

Actions taken by the licensee to correct the trend of increasing component misposition

events raised the level of attention for this issue to include operations and maintenance

department personnel stand down meetings, personnel required reading, and crew

briefings. The techniques discussed for use to prevent component misposition events

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included stop, think, act, and review (STAR), qualification validation and verification;

attention to detail; and a questioning attitude,

c.'

Conclusions

The licensee identified and responded to an increase in component misposition events.

The licensee's response provided techniques for use by site personnel to prevent

component misposition events and raised the level of awareness and attention for this

issue to site management and personnel.

08

Miscellaneous Operations issues (92901)

08.1 (Closed) Violation 50-482/9804-01: Operators' failure to log entry into Technical

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Specification. The inspectors verified the corrective actions described in the licensee's

response letter, dated April 28,1998, to be reasonable and complete. No similar

problems have been identified.

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08.2 LQlosed) Licensee Event Report 50-482/9802 00: Inadequate evaluation of a reactor

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coolant pump lube oil leak collection system nonconforming condition. -This issue was

addressed during the review and closure of the noncited violation (50-482/9812-11). No

further actions were required.

08.3 (Closed) Licenree Event Report 50-482/9722-00: Turbine trip instrumentation

surveillance testing not performed prior to startup, This item was identified when the

licensee was inforrned by another utility that their surveillance testing frequency for

turbine trip instrumentation did not meet the trip actuating device operational testing

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requirements as stated in Table 4.3-1 of Technical Specification 4.3.1.1. The root cause

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of this event was determined to be the mind set of personnelinvolved in the

development and revision of the procedures in which plant conditions and operational

knowledge were utilized in the application of Technical Specifications, without thorough

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consideration of the literal wording of the Technical Specifications. Corrective actions

taken included creating Procedure STS AC-003," Turbine Valve Testing While

Shutdown," making changes to the surveillance tracking computer database, and

reviewing the mode change checklist for other Technical Specification startup frequency

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requirements. The described corrective actions were found to be appropriate for

addressing this issue. The failure by the licensee to ensure that surveillance tests were

performed during the appropriate modes of operation as required by Technical

Specification is a violation of NRC requirements. This licensee-identified and corrected

violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the

NRC Enforcement Policy (50-482/9817-01).

08.4 (Closed) Licensee Event Report 50-482/9724-00: Engineered safety features and

reactor protection system actuations due to a spike on the excore neutron monitoring

system Nuclear Instrument NI-35, intermediate range channel. This item was

addressed in NRC Inspection Report 50-482/97-22.

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II. Maintenance

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M1

Conduct of Maintenance

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M1.1 General Comments on Maintenance Activities

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a.

Inspection Scope (62707)

The inspectors observed all or portions of the following work activities.

WO 98-119607-005

Replace annunciator tri-auxiiiary relay module on Emergency

Diesel Generator B annunciator panel

WO 98-200680-000

implement CP 07767, diode installation on Emergency Diesel

Generator B

WO 98-124592-001

Remove, disassemble, and reassemble AB PV-0003,

Atmospheric Relief Valve C

WO 98-101433-030

Remove existing breaker, install Westinghouse breaker

WO 97-123118-001

Clean, inspect, and rework seating surfaces of AL V0004,

turbine-driven auxiliary feedwater pump suction from essential

service water Train B isolation valve

b.

Observation and Findinas

Except as noted in Section M4.1, the inspectors identified no concerns with the

maintenance observed.

c.

Conclusions

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Except as noted in Section M4.1, the inspectors concluded that the maintenance

activities were performed as required.

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M1.2 General Comments on Surveillance Activities

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a.

Inspection Scope (61726)

The inspectors observed all or portions of the following surveillance activities.

STS IC-603A, Slave Relay Test K603, Train B safety injection

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STS EF-100A, Essential service water system inservice Pump A and essential

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service water cross-connect valve test

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STS EG-100A, Component cooling water Pumps A and C inservice pump test

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STS EM-205, Safety injection system inservice pump testing

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b.

Observations and Findinas

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The inspectors identified no concerns with the surveillances observed.

c.

Conclusions

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The inspectors concluded that the surveillance activities were performed as required.

M2

Maintenance and Material Condition of Facilities and Equipment

M2.1 Review of Material Condition Durina Plant Tours

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a.

inspection Scoce (61726)

During this inspection period, routine plant tours were conducted to evaluate plant

material condition.

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b.

Observations and Findinas

in general, where equipment deficiencies existed, the deficiencies had been identified by

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the licensee for corrective action. The inspectors noted that several systems were

unavailable during all or part of this inspection period.

Channel 8 of the loose parts monitoring system, which monitors Steam Generator B,

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was declared inoperable on August 7,1998. Licensee troubleshooting efforts identified

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a preamp located inside containment outside of the bioshield as the source of the

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problem. The component was replaced during the first week of September and all

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checks indicated that the channel was functional. The licensee was unable to calibrate

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the circuit without entering the bioshield but expected to complete the calibration in 1999

during the next refueling outage when the monitoring instrument located at the steam

generator was accessible. The licensee continued to monitor for loose parts in Steam

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Generator B, using redundant Channel 7, which ensured the steam generator was

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monitored per Regulatory Guide 1.133," Loose-Part Detection Program for the Primary

System of Light-Water-Cooled Reactors." The licensee identified this issue in

Performance improvement Request 98-2354.

On August 14,1998, the reactor vessel level indication system Train B was declared

inoperable when the output from a compensation resistance temperature detector circuit

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was found outside of the acceptable range. The licensee's initial evaluation indicated

that the problem was located in a segment of the circuit located inside containment and

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inside of the bioshield. The licensee was unable to determine the cause of the

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compensation resistance temperature detector circuit failure but expected to repair the

system in 1999 during the next refueling outage when the resistance temperature

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detector is accessible. The licensee was unable to return the reactor vessel level

indication train to operable status within the 30 days required by Technical Specification 3.3.3.6 and had submitted Special Report 98-003, dated September 3,

1998, to the NRC as required by Technical Specification 6.9.2.

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On August 26,1998, multiple lightning strikes on site caused the free-field acceleration

sensor in the seismic monitoring system to fail. The licensee did not have a spare

sensor in stock, having just replaced the free-field sensor in June 1998, following a

severe thunderstorm. The free-field sensor detects the acceleration in the earth in the

vicinity of the plant should a seismic event occur, but it is susceptible to failure during

severe thunderstorms with multiple lightning strikes. The free-field seismic monitor was

unavailable for 15 days.

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in June 1998, the reactor operators noted that the dilute function of the reactor coolant

makeup system controlled by the control board handswitch failed intermittently. Initial

troub!eshooting efforts identified no specific hardware failure, equipment alignment, or

operator action as the cause of the intermittent failure. Subsequent troubleshooting

revealed that the problem was heat related. It was identified that opening the door to

the cabinet where the circuit cards for the reactor coolant makeup system dilute function

were located resulted in the system operating properly after several minutes.

Maintenance technicians were unable to identify the specific degraded card (s) because

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of the system self-correction once the cabinet doors were opened. Operators worked

around the reactor coolant makeup system malfunction for several months and had

developed contingency plans for use in the event that the system degraded further

during use. Operators also made a procedure change to address the manual dilution of

the reactor coolant system. The licensee ruled out a complete replacement of all the

circuit cards in the cabinet that affect the reactor coolant makeup system at power

because some of the same cards were used in the pressurizer heater controls circuitry.

However, the licensee ordered replacement parts for several cards and expected to

have the cards replaced by the end of November 1998. The licensee identified this as

an operator work around on September 29,1998.

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During the calibration of a plant nitrogen system pressure switch, a vendor supplied

1/4-inu. stainless steel braided hose failed suddenly at 2500 psi. This resulted in a

6-oot length of stainless steel braided hose whipping around violently driven by

a 2500 psi regulated source. Three of the four persons in the immediate area were

outside of the reach of the hose. The fourth person, a maintenance technician, was

adjusting the pressure regulator at the time of the hose failure. The technician, who

isolated the pressure source within 5 seconds of the hose separation, was struck by the

hose before the pressure was isolated. The licensee determined that the hose had a

working pressure rating of 3000 psi and a burst pressure rating of 12,000 psi and

contacted the vendor for more information. The licensee identified this in Performance

improvement Request 98-2585 and had taken steps to incorporate other means of

preventing hose whio in the event that a high pressure hose separates in the future.

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c.

Conclusi ns

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The material condition of those plant systems and components evaluated during this

inspection period were good with few equipment deficiencies, including those discussed

in this section.

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M4

Maintenance Staff Knowledge and Performance

M4.1 Knowledae Deficiency Reaardina Radiation Worker Guidelines Criteria for Workina

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Greater than 8 Feet Above the Floor

a.

Inspection Scope (62707)

The inspectors questioned maintenance workers about their use of ladders inside the

radiologically controlled area,

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b.

Observations and Findinas

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On September 14,1998, maintenance technicians removed Atmospheric Relief Valve C

in accordance with Work Order 98-124592-001. While observing this work inside the

radiologically controlled area, the inspectors noted that the maintenance technicians

used a ladder to access the overhead in order to move a permanently installed chain fall

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over a structural support beam approximately 12 feet above the floor.

When asked if they had contacted the health physics department before climbing the

ladder, the technicians responded that they had not. The technicians stated that health

physics personnel knew they were working on the atmospheric relief valve which

included climbing up on a temporary scaffold which was installed specifically for the

task. However, health physics personnel were not made aware that maintenance

technicians were going to use a ladder at a location away from the scaffolding. The

inspectors also noted that the work order did not contain caution statements reflecting

that work planners recognized there was a need for the technicians to climb a ladder

inside the radiologically controlled area to move the chain fall. The inspectors informed

the maintenance technicians that radiation worker guidelines for working in the

overhead require that health physics be contacted before working greater than 8 feet

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above the floor inside the radiologically controlled area. This was identified in licensee

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Performance improvemen' T?equest 98-2789.

In paragraph R4.1 of NRC inspection Report 50-482/98-15, the inspectors concluded

that there was indication of a potential deficiency in the knowledge of some radiation

workers regarding the radiation worker guidance requirement to contact health physics

before performing work in the overhead of the radiologically controlled area. The

occurrence of radiation workers using a ladder to access and work greater than 8 feet

above the floor inside the radiologica;ly controlled area during this inspection period

indicates that there was a definite deficiency in the knowledge of some radiation

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workers.

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The licensee's review and evaluation of the deficiency in radiation worker knowledge

regarding the requirement to contact health physics before using a ladder or climbing on

plant equipment to work greater than 8 feet above the floor in the radiologically

controlled area commenced following the inspectors' assessment in NRC Inspection

Report 50-482/98-15. These efforts were still underway when the inspectors identified

this additional example of a deficiency in radiation worker knowledge regarding the

requirement to contact health physics before working in the overhead in the

radiologically controlled area.

c.

Conclusions

The inspectors identified maintenance technicians working greater than 8 feet above the

floor inside the radiologically controlled area without first contacting health physics. This

supported the conclusion in NRC Inspection Report 50-482/98-15 that there was a

deficiency in radiation worker knowledge regarding the requirement to contact health

physics before working in the overhead in the radiologically controlled area.

M8

Miscellaneous Maintenance issues (92902)

M8.1 (Closed) Violation 50-482/9814-01: Improper storage of temporary equipment in the

control room equipment cabinet room. The inspectors verified the corrective actions

described in the licensee's response letter, dated April 21,1998, to be reasonable and

complete. The inspectors also noted that the licensee committed in Attachment lli of

the letter to assess and evaluate the definitions for stable versus unstable equipment

and the approval process for storage areas of temporary equipment.

M8.2 (Closed) Licensee Event ReDort 50-482/9710-00: Inadequate surveillance of

pressurizer pressure interlock. On June 4,1997, the licensee determined that

engineering safety feature actuation system pressurizer pressure Permissive P 11 was

nct adequately tested. Technical Specification 4.3.2.1, Table 4.3-2, Item 11.a, required

a quarterly analog channel operability test of Permissive P-11.

Permissive P-11 permitted a normal cooldown of the reactor coolant system and

depressurization without actuation of safety injection or main steam line isolation. The

licensee's surveillance and calibration procedures for Permissive P-11 did not

adequately verify proper overlap. The licensee determined the cause to be inadequate

sysMr 1 design.

The licensee revised the following test procedures:

Procedure STN IC-201 A, " Analog Channel Operational Test of TAVG, dT, and

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Pressurizer Pressure Protection Set 1";

Procedure STN IC-202A, " Analog Channel Operational Test of TAVG, dT, and

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Pressurizer Pressure Protection Set 2"; and

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Procedure STN IC-203A, " Analog Channel Operational Test of TAVG, dT, and

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Pressurizer Pressure Protection Set 3."

The procedure revisions ensured the proper testability of Permissive P-11. As part of

the long-term corrective actions, the licensee evaluated installing a test jumper in the

Permissive P-11 circuitry. The licensee determined that the procedure revisions were

adequate to satisfy the Technical Specification surveillance requirement and the jumper

was not necessary. The inspectors identified no concerns.

The inspectors concluded that the failure to properly test pressurizer pressure

Permissive P-11, as a result of inadequate design, was a violation. This nonrepetitive,

licensee-identified and corrected violation is being treated as a noncited violation,

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consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-482/9817-02).

M8.3 { Closed) Inspection Followuo item 50-482/9710-04: Inadequate surveillance of

pressurizer pressure interlock. This inspection followup item was identified as a result of

the issue discussed in Licensee Event Report 50-482/9710-00. This item was closed

based on the corrective actions described in Section M8.2.

Ill. Enaineerina

E7

Quality Assurance in Engineering Activities

E7.1

Enaineerina System Health Reports

a.

Inspection Scope (37551)

The inspectors evaluated a presentation by system engineering to licensee

management on the health of the residual heat removal system and the component

cooling water system.

b.

Observations and Findinas

On August 31,1998, the inspectors attended the normally scheduled system health

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presentation by system engineers to site management. System engineers presented

their findings on the health of the residual heat removal system and the component

cooling water system. The inspectors noted that during the system health

presentations, site management demonstrated a questioning attitude by asking

challenging questions and demanding adequate responses. In one case with less than

thorough responses to the questions asked by site management, the system engineer

was asked to further evaluate the system and to present the report at the next

scheduled presentation.

c.

Conclusions

Licensee management demonstrated a questioning attitude during an engineering

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presentation on the health of the residual heat removal system by asking challenging

questions regarding long term operability and bearing lube oil volume and demanding

adequate responses.

IV. Plant Support

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.R1

Radiological Protection and Chemistry Controls

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R1.1

Poor Contaminated Area Work Practices

a.

Insoection Scoce (71750)

The inspectors evaluated radiological work practices associated with work in a

contaminated area.

b.

Observations and Findings

On September 14,1998, the inspectors observed licensee efforts to determine the

cause of packing leakage from Valva EM HV-8801 A, the boron injection tank Train A

inlet isolation valve, during the performance of Procedure STS EM-205, " Safety injection

System inservice Pump Testing," Revision 5. Valve EM HV-8801 A, which was in a

posted contaminated area, was cycled several times during the test. A member of the

operations department management team also observed this activity.

Before Valve EM HV-8801 A was cycled, a maintenance technician accompanied by a

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health physics technician attached a magnetically mounted dial indicator to the valve

bonnet and positioned the device to measure lateral valve stem deflection. While

attempting to set up and properly attach the mounting device, the maintenance

technician moved his gloved hands in and out of the valve stem area in a mannor that

could have resulted in cross contamination. The inspectors noted that, while this was

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occurring, the health physics technician did not move to prevent the maintenance

technicians poor radiological work practice. At one point, the maintenance technician

requested that the health physics technician hold one piece of the mounting device while

an adjustment was made to another. The health physics technician responded in a

manner that could also have resulted in cross contamination.

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The health physics technician immediately recognized this error and took the

appropriate corrective action. The poor radiological work practices on the part of both

technicians did not result in personnel contaminations or in the spread of contamination

outside of the contaminated area. The inspectors also noted that personnelin the area,

while discussing and observing the valve stem and packi- on Valve EM HV 8801 A,

extended their hands, arms, and heads across the verticai plane of the contaminated

area boundary without touching any part of the valve.

The work practices observed by the inspectors are not consistent with the guidance

provided in licensee Training Manual GT1245200, " Radiation Worker Training,"

Revision 28. The licensee informed the inspectors that radiological work practices

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observed by the inspectors did not meet site management expectations. The licensee

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identified this issue in Performance improvement Requests 98-2797 and 98-2846.

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Based on the poor radiological work practices observed by the inspectors during work in

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a small contaminated area posted around Valve EM HV-8801 A, the inspectors noted

that there was indication of a deficiency in the knowledge of some radiation workers

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regarding contaminated area boundary controls and methods of preventing the spread-

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of contamination.

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c.

Conclusions

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Observations by the inspectors of poor radiological work practices indicated a deficiency

in the knowledge of some radiation workers regarding contaminated area boundary

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controls and methods of preventing the spread of contamination.

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R1.2 Licensee Response to Airborne Radioactivity in the Radioactive Waste Buildina

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a.

Insoection Scope (71750)

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The inspectors reviewed the licensee's response to airborne radioactivity in the

radioactive waste building as a result of reactor coolant system filter shearing

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operations.

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b.

Observations and Findinas

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On September 20,1998, during shearing operations on filters used to remove

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radioactive particulate from the reactor coolant system, health physics technicians

discovered loose surface radioactive contamination on the grappling device used to

move filter cartridges from the shielded storage drums to the shearing device. The

health physics technicians providing job coverage immediately suspended all work in the

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truck bay of the radiological waste building because of the potential to generate airborne

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radioactivity. The technicians collected and analyzed the air filters and loose surface

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contamination smears collected from the area for radioactivity.

The results of the air filter analysis revealed that the air sample in the immediate vicinity

was 7.0 derived air concentrations (DAC) and the general area air sample

was 0.15 DAC. The loose surface contamination smears collected from the general

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area of the truck bay were less than or equal to 2000 dpm/100cm . Followup air

samples indicated that no airborne radioactivity remained in the area. The health

physics technicians appropriately controlled access to the area and posted the entire

truck bay as a contaminated area. On September 24,1998, the licensee had

decontaminated the area and restored normal access to the affected area of the

radiological waste building.

The four technicians who were involved in the filter shearing operations exited the

radiologically controlled area without alarming the personnel contamination monitors.

However, the technicians were whole body counted as a precaution to determine if there

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was an intake of radioactive material. The inspectors were informed that three of the

four technicians had detectable internal activity; however, the highest internal dose was

determined to be less than one millirem.

During a tour of the affected area, health physics technicians discussed the filter

shearing process with the inspectors, describing the work process and the layout of the

equipment used to support the filter shearing evolution. The technicians explained that

the exhaust from the high efficiency particulate air (HEPA) filtration unit used to provide

negative ventilation was directed back toward the filter shear and shielded drum

placement area. In subsequent discussions with the licensee, it was determined that

the exhaust from the 1000 cfm HEPA filtration unit may have contributed to the

entrainment and distribution of airborne radioactive particulate in the work area.

During followup evaluation and further discussion with the licensee, the inspectors

identified several weaknesses associated with the prejob brief and the radiological work

procedure for this filter shearing evolution:

The stop-work criteria emphasized, was based only on external dose to the

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workers irom the HEPA filter and did not consider airborne radioactivity or

cumulative dose from all sources.

No description of the increased potential for airborne radioactivity or the

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increased risk from the finer particulate with higher specific activity than was

normally encountered was provided to the workers. This condition was known to

exist as a result of filtering reactor coolant while experiencing axial offset

anomaly in 1997.

The inspectors found the licensee's evaluation of the filter shearing process to be

adequate under the circumstances to evaluate the potential hazard that could be

present. Howevar, the inspectors noted that the practice of allowing workers to enter an

area between a source of high levels of loose surface contamination and the single

negative ventilation suction line inlet opening, without real time airborne radioactivity

level information or other added controls, added unwarranted risk to the workers.

On September 22,1998, the licensee started an investigation of the filter shearing

process. This event was documented in significant Performance Improvement

Request 98-2875.

c.

Conclusions

Health physics technicians responded appropriately to the discovery of unexpected

contamination and elevated levels of airborne radioactivity during reactor coolant system

filter shearing operations.

Weaknesses were identified in the licensee's stop-work criteria and in identifying the

increased potential for airborne radioactivity, known to exist, to workers performing

reactor coolant system filter shearing operations. The stop-work criteria was based

soley on the dose from the HEPA filtration unit and a known increased potential for

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. airborne radioactivity was not communicated to the workers.

R2

Status of Radiological Protection and Chemistry Facilities and Equipment

. R2.1

Radioloaically Controlled Area Imoroved Housekeepina

a.

inspection Scope (71750)

The inspectors reviewed the licensee's efforts to improve housekeeping of the

radiologically controlled area,

b.

Observations and Findinas

The licensee recently completed a major effort to improve housekeeping in the

radiologically controlled area. The inspectors observed a reduction in the number of

containers used to store potentially radioactive tools and equipment in the radiologically

controlled area, a reduction in the number of drip bags installed to control potentially

contaminated liquid and boron residue, and a generally improved appearance inside the

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radiologically controlled area both inside and outside of the buildings. The licensee also

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stated that the overall percentage of contaminated square footage was reduced by

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50 percent during this effort.

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During discussions with the licensee, the inspectors learned that the housekeeping

improvements in the radiologically controlled area were motivated by the desire to

reduce the potential for personnel contaminations, improve the ability to monitor and

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survey for contamination, clearly identify and limit the number of contaminated tools

maintained inside the radiologically controlled area, and reduce the overall resources

required to maintain the tools, equipment, and access inside the radiologically controlled

area.

c.

Conclusions

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The inspectors noted a reduction in the number of storage containers and installed drip

bags, and a generally improved appearance inside the radiologically controlled area

because of licensee housekeeping improvement efforts directed at reducing the

resources required to maintain tools and equipment, and improve surveying capabilities

inside the radiologically controlled area.

F8

Miscellaneous Fire Protection issues

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F8.1 - (Closed) Licensee Event Report 50-482/9716-00. 01. and 02: Use of fire protection

pumps for purposes other than fire protection constituted a significant degradation of fire

protection system. This item was identified during a licensee review of uses of the fire

protection system. The fire protection engineer found that the use of these pumps for

nonfire protection services was contrary to the requirements of License

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Condition 2.C(5)(a), and determined that the diversion of significant quantities of water

could impair the fire suppression system capability. The root cause of this event was

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attributed to the inadequacy of the fire protection program management with respect to

training of personnel and ensuring compliance with licensing requirements. Corrective

actions taken included revising Procedures AP 26A-003," Screening and Evaluating

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Changes, Tests, and Experiments"; SYS FP-293," Fire Pumps Manual Operations"; and

a number of other procedures; revising Updated Safety Analysis Report,

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Section 9.5.1.2.3, to list all allowed uses (training, maintenance / testing, off-normal and

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emergency) of the fire protection system; and performing a self assessment of the fire

protection program. The described corrective actions were found to be appropriate for

addressing this issue. The failure by the licensee to ensure that the requirements of

their license conditions were met is a violation of NRC requirements. This nonrepetitive,

licensee-identified and corrected violation is being treated as a noncited violation

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consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-482/9817-03).

V. Manaaement Meetinas

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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 October 3,1998. The licensee acknowledged the findings

presented.

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

should be considered proprietary. No proprietary information was identified.

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ATTACHMENT

PARTIAL LIST OF PERSONS CONTACTED

Licensee

M. J. Angus, Manager, Licensing and Corrective Action

G. D. Boyer, Chief Administrative Officer

S. R. Koenig, Manager, Performance improvement and Assessment

J. W. Johnson, Manager, Resource Protection

O. L. Maynard, President and Chief Executive Officer -

B. T. McKinney, Plant Manager

R. Muench, Vice President Engineering

C. C. Warren, Chief Operating Officer

INSPECTION PROCEDURES USED

IP 37551

Onsite Engineering

IP 61726

Surveillance Observations

IP 62707 -

Maintenance Observations

IP 71707

Plant Operations

IP 71750

Plant Support Activities

IP 92901

Followup - Operations

IP 92902

Followup - Maintenance

ITEMS OPENED AND CLOSED

Opened

50-482/9817-01

NCV Turbine trip instrumentation surveillance testing not

performed prior to startup (Section 08.3)

50-482/9817-02

NCV Inadequate surveillance of pressurizer pressure interlock

(Section M8.2).

50-482/9817-03

NCV Use of fire protection pumps for nenfire protection

purposes constituted a significant degradation of fire

protection system (Section F8.1).

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Closed

50-482/9710-00

LER

inadequate surveillance of pressurizer pressure interlock

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(Section M8.2)

50-482/9710-04

IFl

Inadequate surveillance of pressurizer pressure interlock

(Section M8.3)

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50-482/9716-00, 01,02

LER

Use of fire protection pumps for nonfire protection

purposes constituted a significant degradation of fire

protection system (Section F8.1)

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50-482/9722-00

LER

Turbine trip instrumentation surveillance testir'g not

performed prior to startup (Section 08.3)

50-482/97.24-00

LER

Engineered safety features and reactor protection system

actuations due to a spike on the excore neutron monitoring

system Nuclear Instrument Ni-35 intermediate range

channel (Section 08.4)

50-482/9802-00

LER

Inadequate evaluation of an reactor coolant pump lube oil

leak collection system nonconforming condition

(Section O8.2)

50/482-9804-01

VIO

Operators failure to log entry into Technical Specification

(Section O8.1).

50-482/9814-01

VIO

Improper storage of temporary equipment in the control

room equipment cabinet room (Section M8.1).

50-482/9817-01

NCV Turbine trip instrumentation surveillance testing not

performed prior to startup (Section 08.3)

50-482/9817-02

NCV Inadequate surveillance of pressurizer pressure interlock

(Section M8.2).

50-482/9817-03

NCV Use of fire protection pumps for nonfire protection

purposes constituted a significant degradation of fire

protection system (Section F8.1).

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