IR 05000397/1986037

Insp Rept 50-397/86-37 on 861116-870103.No Violations or Deviations Identified.Major Areas Inspected:Esf Status.Lers, Surveillance Program,Maint Program,Special Insp Topics & Licensee Action on Previous Insp Findings

ML20212R579
Person / Time
Site:	Columbia
Issue date:	01/16/1987
From:	Rebecca Barr, Dodds R, Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20212R558	List: IR 05000397/1986037 ML20212R556
References
50-397-86-37, NUDOCS 8702020718
Download: ML20212R579 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No: 50-397/86-37 Docket No: 50-397 Licensee: Washington Public Power Supply System P. O. Box 968 Richland, WA 99352 Facility Name: Washington Nuclear Project No. 2 (WNP-2)

Inspection at: WNP-2 Site near Richland, Washington Inspection Conducted: Nove ber 16 - January 3, 1987

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d% /b Inspectors: b . I o ds Senior Resident Inspector Date Signed C +

hR. C. B~ rr, Resident Inspector t/AL Date Signed Approved by:

P. . We hnson,~ Chief

/L . b Date Signed Reac Projects Section 3 Summary:

Inspection on November 16 - January 3, 1987 (50-397/86-37)

Areas Inspected: Routine inspection by the resident inspectors of control room operations, engineered safety feature (ESF) status, surveillance program, maintenance program, licensee event reports, special inspection topics, and licensee action on previous inspection findings. During this inspection, Inspection Procedures 30702, 30703, 37702, 41400, 62703, 61726, 71707, 71710, 92702, 93702, and 90712 were covered.

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Results: No violations or deviations were identifie PDR ADOCK 05000397 O PDR t

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DETAILS Persons Contacted D. Mazur, Managing Director

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J. Shannon, Deputy Managing Director

• C. Powers, Plant Manager

• J. Baker, Assistant Plant Manager

. R. Corcoran, Operations Manager

• S. McKay, Assistant Operations Manager

• K. Cowan, Technical Manager J. Harmon, Assistant Maintenance Manager R. Graybeal,' Health Physics and Chemistry Manager

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• D. Feldman, Plant Quality Assurance Manager

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• J. Peters, Manager, Nuclear Plant Administration P. Powell, Licensing Manager'

M. Wuesterfeld,. Reactor Engineering Supervisor J. Landon, Maintenance Manager S. Washington, Lead Compliance Engineer J. Arbuckle, Compliance Engineer

• D. Williams, Nuclear Engineer, BPA

• Personnel in attendance at exit meeting The inspectors also interviewed various control room operators, shift supervisors and shift managers, engineering, quality assurance, and management personnel relative to activities in progress and record . Plant Status Except for a 5-day maintenance outage on November 20-25, 1986,-the plant operated at approximately 71% power throughout the_ inspection perio . Operations Verifications The resident inspectors reviewed the control room operator and shift r i manager log books on a daily basis for this report period. Reviews were also made of the Jumper / Lifted Lead Log and Nonconformance Report Log to verify that there were no c'onflicts with Technical Specifications and

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that the licensee was actively pursuing. corrections to conditions listed in either lo Events involving unusual conditions of equipment were discussed with the control: room personnel available.at the time of the review and' evaluated for potential safety significance. -The licensee's adherence to Limiting Conditions for 0peration (LCO's), particularly .

those dealing with ESF and ESF electrical; alignment, was observe The inspectors routinely took note of~ activated annunciators on'the control panels and ascertained that the control room licensed personnel on duty at the time were' familiar with the reason for each annunciator and its

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significance. The inspectors observed access control, control room

'- manning, . operability of nuclear ' instruments, and availability of onsite

and offsite electrical power. The inspectors also made regular tours of accessible areas of the facility to assess equipment conditions,

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radiological controls, security, safety and adherence to regulatory requirements.

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No violations or deviations were identifie i 4. Design Review The inspectors examined several recent design related events to determine whether they were isolated instances of, design errors or if the original design review process was at fault. Specifically examined were licensee event reports (LERs).86-27, 86-28 and 86-33 and a residual heat removal (RHR) system hanger design discrepancy. It appeared that these were isolated events and not indicative of programatic problem a. LER 86-27, 10CFR Part 21 Report -- Defective Cable / Conduit Weight Engineering Specification (Closed)

The specifications the architect / engineer (A/E) (Burns and Roe, Inc)

provided the contractor for conduit.and cable weight per foot.were based on average rather than actual data. The cable and conduit weight data were complied in 1974 at the time of the specification bid issue preparation. Data utilized for the bid specification were from the " Steel Electrical Raceways Design Manual" published by American Iron and Steel Institute (AISI), 1972 editio The 1972 edition was superseded by the 1975 edition and eventually by ANSI C80.1-1983, " Rigid Steel Conduit - Zinc Coated". The values of conduit weight in these references did not change significantl The ANSI Standard indicates these are minimum weight There was no such indication in the earlier AISI manual The as-constructed conduit weights have been compared to the original specification and while found to be more, the major difference stems from the cable weight. The source data used for the cable weight could not be identified from available historical information. Specific cable d:ta were not available when the construction contract was, awarded; the cable procurement contract was awarded sometime late *

Evaluations have been performed to determine the effect of the increased weight per foot of the conduit cable combination on structural integrity including:

(1) Preliminary frequency and stress calibration for all conduit sizes from 3/4" to 5" with the maximum span of 6.75 feet; (2) Adequacy of conduit clamps to sustain the increased weight per foot; (3) The incremental effect of conduit weight on cable tray supports; and

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(4) The specific example mentioned'in the LER wherein the combined weight was reported to be 52 percent higher than used in the calculatio These evaluations showed that there was a sufficient margin of safety available in the original calculations such that this additional load on conduit supports does not constitute a substantial safety hazard as defined by 10CFR2 Burns'and Roe examined other projects for which they established criteria for design unit weight of cable and conduit and determined that a similar situation does not exist on those projects. They have, however, revised their engeneering standards accordingl b. LER 86-28-00 and 01, 10CFR Part 21 Report - Potential Flooding of Control Room and Other Plant Areas Not Analyzed (Closed)

An evaluation of the A/E design criteria by Generation Engineering ' determined that 1) a flooding analysis was not conducted during the design of a wet-sprinkler system added to the WNP-2 Control Room and 2) the A/E flooding analysis requirements included only the Reactor Building and not other areas of the-plant that contain safety-related equipmen The piping and hanger design for the fire protection sprinkler system within the Control Room has been evaluated and determined to be seismically designed and installed and therefore not subject to failure as a direct result of a seismic even The automatic sprinkler heads have also been evaluated to ensure that they are seismically qualified. A flooding analysis based on ANSI /ANS 58.2 - 1980 has been performed for all water sources in the Control Room. The analysis has shown that flooding can occur due to a pipe crack. Nuclear Engineering Standard No. 7 (NES-7) will be changed to permit shutdown from the remote shutdown room in the event of flooding and spraying in the Control Roo An engineering evaluation of areas outside of the Reactor Building containing equipment essential to safe shutdown identified no potential flooding conditions that would prevent safe shutdown of the plan The addition of the automatic sprinkler system within the control room area was the result of an NRC Fire Protection Audit (WPBR-F-83-312). It was handled as a plant modification in accordance with a Project Engineering Directive that was not submitted to " downtown" Burns and Roe Engineering for revie The design review checklist did not require a flooding evaluation per se. Engineering's evaluation of this event shows it to be an isolated incident. It appears that a flooding analysis has been done on the balance of the plant, since the appropriate curbs and drains have been installe o

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c. LER 86-33-00 and 001, 10CFR Part 21 Report - Incorrect Sizing of Cables (0 pen)

The Supply System has determined that Burns and Roe established the cable ampacity for all circuits using IPCEA/ NEMA WC51-1972,

"Ampacities - Cables in Open Top Trays"; however, the installation of covers or wrapping material over the trays or the application of Thermolag reduces the cable ampacit The use of open top cable tray ampacity tables for conduit is conservative except in cases where several conduits are clustered in close proximity or are buried underground. Cables routed in primary containment may not have sufficient ampacity since the ambient temperatures are higher than anticipate Estimates for some cases show as much as 31.5% additional derating of presently installed cables may be required, although these revised ratings may be adequate for existing load condition The effect of undersized cable is that the cable operates at higher temperatures than designed, which results in shortened cable lif The Burns and Roe Engineering Criteria Document Section D, Revision 14, used by the Supply System Engineering for new design, did not adequately adress new cable installation at WNP-2. This document was being modified to correctly specify the sizing requirements for cables installed in underground duct banks, trays and condui Analysis to date indicates that modifications will not be required for safety-related cables, but that actual usage factors will need to be considered for certain cables (i.e., valve motors operate for only a short period of time rather than full time as presumed in the cable rating calculations).

This deficiency for derating because of the application of Thermolag was initially identified during the conduct of the

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independent design verification program prior to licensing but was not dispositioned as a finding at the time since Burns and Roe was still in the process of reviewing the cable rating factors;-

afterwards, it was inadvertently omitted. The licensee expects to complete their review of this issue and provide a supplemental report in January 198 d. Hangers / Supports for RHR-A System Not Designed for Operations Above 114 Degrees Fahrenheit One Hanger / Support group for the RHR-A system was only analyzed by Burns and Roe for operating conditions up to 114 degrees A review of the calculations shows that this was consistent with the input data supplied by General Electric for the RHR system operating conditions. The design criteria assumed the plant would always be shut down using RHR-B as the lead syste Generally this will be the case, but RHR-A has been used on occasion. Subsequent calculations have shown the Hanger / Support group is adequate for operations up to 295' degrees _ _ _ _ -_ ______

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. This appears to be an isolated instance and not indicative of a

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design review process proble No unreported violations or deviations were identifie . Off-Site Safety Committee Activities The inspector examined the~results of selected audits conducted during 1986 under the direction of.the Corporate Nuclear Safety Review Board (CNSRB). The schedule and scope of audits were found to be consistent with the intent of the Technical Specification Project response to audit findings generally appeared to be efficacious and timel No violations or deviations were identifie . Surveillance Program Implementation The inspectors ascertained that surveillance of safety-related systems or components was being conducted in accordance with license requirement In addition to witnessing and verifying daily control panel instrument checks, the inspectors observed portions of several detailed surveillance tests by operators and instrument and control technician PPM 7.4.0.5.8, RHR, low pressure core. spray (LPCS) and reactor core isolation cooling (RCIC) Valve Operability .

- PPM 7.4.6.3.5.1, Traversing incore probe (TIP) Squib Continuity Check

- PPM 7.4.6.1.4.1, Monthly main steam isolation valve (MSIV) Leakage Control System Test, Div 1 and Div 2

- PPM 7.4.7.3.3, RCIC.0perability Test

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- PPM 7.4.6.5.3.1, Standby Gas Treatment Operability Test

- PPM 7.4.0.5.17, Standby Service Water Loop B Operability Demonstrations

- PPM 7.4.4.2.1.2, Accoustical Monitor Operability

- PPM 7.4.6.4.1.2, Suppression Chamber Drywell Vacuum Breaker Operability No violations or deviations were identifie ~ Monthly Maintenance Observation Portions of selected safety-related system maintenance activities were observe By direct observation and review of records the inspector determined whether these activities were consistent with LCOs; that the proper administrative controls and tag-out procedures were followed; and that equipment was properly tested before return to service. The inspector also reviewed the outstanding job orders to determine if the licensee was giving priority to safety related maintenance and to verify that backlogs which might affect system performance were not developin Examination of the work package associated with maintenance on RHR-V-53A (MWR-AN 707B and associated radiation work permit,

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RWP-386)-disclosed that the workman had' received instructions on PPM 1.3.18, Tool and Equipment Accountability Control ~Around Open Plant Systems; PPM 1.3.19, Housekeeping; PPM 10.1.13, Systems Cleanliness Control; and PPM 10.2.7, Valve Troubleshooting, Handling and Repair. A radiation protection technician was required to be in attendance for the entire job. Respiratory protection was required and the workman and attending health physics technician were afforded the necessary equipmen The installation of the accoustical monitor for main steam relief valve MS-RV-5C was observe The monitor'was verified to have been installed in accordance with the instructions on RWP-AU-7777 and NCR-286-47 The work was monitored by a QC enginee A faxed trip report from a licensee engineer indicated that the connector had been previously environmentally' qualified for_ a 24-hour LOCA environment at Wylie Laboratories, Huntsville, Alabama. The connector will continue to be tested to be qualified.for a 6 month LOCA environment. The inspector verified that the instrument technicians who applied heat shrink tubing on the cabling and the connector had previously received training from an engineer who had attended a Raychem seminar at Menlo Park, California. The engineer was familiar with the content of IE Information Notice 86-53, Improper Use of Heat Shrinkable Tubin The inspector examined the rerouting of instrument lines and repositioning of MSLC-FT-3A and 3C (Main Steam Leakage Control Flow Transmitters) that were performed pursuant to DCP 85-0486-0A and MWR AV447 The flow transmitters had been installed below the flow taps and were repositioned to eliminate condensation in the instrument lines. The inspection included a review of the

"10CFR50.55 Safety Evaluation", " Design Verification Record" and

"ASME Weld Record WR-113". PPM 7.4.6.1.4.23 MSLC High Flow Channel Ca_libration was conducted prior to placing the channels in servic No violations or deviations were identifie . Engineered Safety Feature Verification The inspectors verified the operability of the high pressure core spray (HPCS) and standby liquid control (SLC) systems by performing a walkdown of the accessible portions of the systems. The inspectors confirmed that the licensee's system lineup procedures matched plant drawings and the as-built configuration, and verified that valves were in the proper position, had power available, and were locked as appropriate. The inspection included a verification of HPCS valve position inside containment on November 23, 198 The licensee's procedures were verified to be in accordance with the Technical Specifications and the FSA No violations or deviations were identifie '

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9. Licensee Actions On Previous NRC Inspection Findings The inspectors reviewed records, interviewed personnel, and inspected plant conditions relative to licensee actions on previously identified inspection findings: (Closed) Enforcement Item 85-11-02, Corporate Nuclear Safety Review Board (CSNRB) Evaluation of 10CFR50.59 Changes The licensee did not agree with this enforcement action item in that they believe, "the words, 'the CNSRB shall review', do not state each member shall review each item associated with the remainder of the section. The phrase does not preclude individual reviews with reports to the membership by subcommittee and/or technical specialist". . While this philosophy is consistent with NRC requirements, what the CNSRB had not been doing was to document in the meeting minutes their acceptance of these reports made by their duly authorized subcommitte(s) and/or technical specialist (s).

All members and alternates of the CNSRB attended a half day training seminar on February 7, 1986 which included a session on

" Obligations of Safety Review Committee Members". For the past year, the minutes of the CNSRB have specifically indicated that the Executive Secretary reported that all procedures, procedure deviations, modifications, test procedures and setpoint changes approved by P0C in meeting minutes (identified by number) have been reviewed using the criteria of 10CFR50.59 and that there were no unreviewed safety questions. The " Instructions of the' Corporate Nuclear Safety Review Board" were being revised to assure that this action will be reflected as a subcommittee action with Board approva The CNSRB minutes show that several special or periodic licensee reports have been transmitted to eaci; member and alternate member However, unless there were questions such as on the Trends Report in meeting 86-15, the meeting minutes did not reflect any specific type of action'(i.e., review, acceptance or denial)'on reported material-

such as that containeri in the 1985 annual report. The Chairman of the CNSRB stated that the minutes will be more specific in this regard in the future. This committment will be monitored as part of the routine inspection program.

t (Closed) Enforcement Items 85-11-04 and 86-11-02~ Control of

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Measuring and Test Equipment (M&TE) Not Implemented According to Procedure The licensee's actions in response to these violations was verified to have been accomplished as stated in letters G02-85-357 and

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G02-86-960 dated July 2, 1985 and October 20, 1986 respectively. A random selection of 15 M&TE items, including crimping tools, showed all of them to be appropriately accounted for. A check of

approximately 25 instruments stored in the contaminated equipment I

lockers showed all of them to be in calibration. A separate storage area and contaminated equipment locker have been established for those instruments awaiting transportation to the calibration

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laboratory. The inspection of the Instrumentation and Control calibration shop on the 525-foot elevation of the radwaste building disclosed that separate storage had been established for instruments awaiting calibration. A computerized tool control program has been established to assure that equipment is returned and reissued as appropriate every seven days. The Standards Laboratory Maintenance Engineer stated that Supervisors are promptly notified whenever any equipment is overdue. A check on December 12 of the listing for December 11, 1986 showed that the equipment had indeed been returned and reissued. Nothing was outstanding for more than two days that had not been accounted for. An equipment usage tag has been attached to each piece of M&TE gear to permit an appropriate evaluation to be made when equipment is found to be significantly out of calibratio A check of several cards against the usage file showed them to be consistent with one anothe It was verified that the tool crib attendents were assigned in early October, trained, and put on round-the-clock duty on October 18, 1986 to assure continued control of M&T An examination of records associated with the crimping tools collected during January-March 1986 showed that they had been placed in storage at the Standards Laboratory and were not released until calibrated and placed on the M&TE computer listing. This specific item was subsequently determined not to be in violation of regulatory requirement c. (Closed) Enforcement Item 86-11-04, Work Performed ~on RHR Valve but Not Allowed by Procedure It was verified that MWR work instruction guidelines were issued on October 6, 1986 and that training for maintenance engineers on these guidelines was completed on October 17, 198 d. (Closed) Enforcement Item 86-11-06, Failure to Perform Bore Measurements on an Air Start Motor and Provide Independent Checks Section 10.20.10.2B of PPM 10.20.10, " Diesel Air Start Motor Maintenance" has been revised to delete the reference to independent signatures on Data Sheet 1. However, independent QC inspection will be performed in accordance with QC's new program for critical systems and components. Since this was a new motor, the inspector agrees with the licensee that a cylinder bore measurement was not necessary based on motor test results, e. (Closed) Enforcement Item 86-11-07, Failure to Complete Termination Sheets on Work Associated With Emergency Diesel Generators The inspector verified that the data on the MWR were sufficient to ddequately complete the " Wire Termination List"; however, contrary to the licensee's response, the wire termination was not completed and filed with the work package until the inspector examined this item on December 12, 1986. This discrepancy was'

discussed during the management meeting (paragraph 12).

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. . (Closed) Enforcement Item 86-11-11,' Housekeeping - Failure to Remove Foreign Material From Work Areas After Work Has Been Completed Administrative Procedure PPM 1.3.19, " Housekeeping," was revised on November 11, 1986 as stated in the licensee's response. Recent plant tours and inspections inside control cabinets indicated that

- housekeeping is improving and is not a problem at this tim Quarterly inspections of instrument and electrical panels have been placed on the Scheduled Maintenance System- the first being ,

conducted by Operations on December 13-14, 198 (Closed) 86-11-03, Failure to Take Prompt and Effective .

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Corrective Action It was verified during the team inspection in June 1986 that the Maintenance supervisors had read QA Surveillance Report 2-85-08 ,

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Subsequent reviews of MWRs indicate that the increased amount of post-work review of MWRs by Maintenance personnel appears to have been effectiv '

' (Closed) Enforcement Items 86-11-05 and 86-11-09, Failure to Have Established Written Procedures for Controlling QC Inspection and Inspecting Bolt Torquing.of F1ow Control Valves and Air. Start Motors The inspector previously observed the retorqueing of the bolts as

indicated in Inspection Report 86-34, Paragraph 5. -The licensee has periodically briefed the inspectors on the status of the QC inspection program for corrective maintenance, Quality Control Instruction PQC-01, " Plant QC Inspection Activities". The program has been updated to assure QC inspection of corrective maintenance

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based upon a determination of whether the maintenance is critical

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(i.e. , work activities that could significantly jepordize or will compromise the design safety function of safety related structures, systems or components) or significantly affects the reliability of

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plant operation. All MWRs, including work documents, ar'e being i reviewed by QC in consultation with Maintenance engineers to assure

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adequate inspection and documentation of work by the establishment

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of " Hold Point Inspections". Specific hold points have been established in the QC inspection procedures PQC-03, PQC-04 and

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PQC-0 An active inspection record file has been established by

MWR number for inspection of assigned hold points. Until sufficient experience has been gained to justify a sampling program, QC

inspection is being performed on all critical corrective maintenance activities. .The licensee has also increased the QC staff to support

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the increased work load. The utilization of additional QC Engineers-for the interim QC corrective maintenance program has been verified during the observation of maintenance work over the past three i months. It appears that the licensee has implemented a program of quality control inspection of critical maintenance on 4 safety related plant component Discussion with the cognizant QC Senior Engineer indicated that

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10 definite criteria were being established and placed in the data base to identify critical maintenance on safety-related plant components. According to the licensee, this program will be in effect and implemented by March 1987. The sampling program for corrective maintenace will be established by September 1987. 100 percent inspection is planned for those components for which sampling can not be justified. These aspects of the program will be followed as part of the routine inspection progra (Closed) Enforcement Item 86-11-01, Failure to Reverify Prerequisites and Record Instrument Used During Retest of HPCS Battery The Electrical Maintenance Supervisor has included in shop briefings the importance of recording calibrated instruments on test records, as stated in a letter to the Plant Compliance Enginee It was verified that the calibrated instruments used during the retest of E-B1-HPCS have now been identified in the surveillance record. Administrative Procedure PPM 1.5.1, " Technical Specification Surveillance Testing Program" was revised to require, "In those cases where a surveillance procedure has been delayed beyond a shift, the prerequisites must be reverified prior to restart of the procedure". The commitment to revise the procedure by December 1, 1986 had been overlooked until the inspector examined the licensee's corrective actions on this matter. Apparently, this had been left off the commitment tracking lis This discrepancy was discussed during the Management Meeting (paragraph 12).

10. SALP and Enforcement Conference Followup - Management Meeting Licensee management met with the resident inspectors and Region V management representatives on November 19, 1986 to review the status of improvement initives resulting from the 1986 SALP report and the enforcement conference of August 29, 1986. Specifically discussed were the following topics:

- Management Involvement

- Housekeeping

- Fire Protection Program (transient combustible control)

- Tool Control

- M&TE Control

- Quality Control Program Upgrade

- Quality Assurance Assessment Feedback

- SALP Report Improvement Program

- Fire Protection Program Review The licensee's continued efforts to resolve NRC identified issues was acknowledged and encourage . Respiratory Protection Training The inspector (s) attended basic and refresher courses given by the licensee to Operations, Maintenance, and emergency response personnel for

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equipment, and the protection factor assigned to each. An examination was given following each class,that required a score of at least 70-percent for a passing grade. The instructor (s) personally reviewed any missed questions with each class participan No violations or deviations were identifie . Management Meeting The' inspectors ~ met with the Plant Manager approximately weekly during this period to discuss inspection finding status. On January 9, 1987,

'the Senior Resident Inspector met with the Plant Manager and members of his staff to discuss the inspecton findings during this perio Specifically discussed was the timely closure of commitments to the NRC (as discussed in paragraphs 9.e and 9.i). The licensee recognized the significance of this matter and was taking action to preclude recurrenc ,

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