IR 05000103/2002011

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Insp Rept 50-261/95-03 on 950103-0211.Noncited Violations Identified.Major Areas Inspected:Plant Operations,Maint Observation,Engineering Evaluation & Plant Support Activities
ML14181A662
Person / Time
Site: Robinson, 05000103 Duke Energy icon.png
Issue date: 03/06/1995
From: Christensen H, Ogle C, William Orders, Starefos J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14181A661 List:
References
50-261-95-03, 50-261-95-3, NUDOCS 9503150044
Download: ML14181A662 (19)


Text

REG UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

o 101 MARIETTA STREET, N.W., SUITE 2900 ATLANTA, GEORGIA 30323-0199 Report No.: 50-261/95-03 Licensee:

Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:

50-261 License No.: DPR-23 Facility Name: H. B. Robinson Unit 2 Inspection Conducted: January 3 - February 11, 1995 Inspectors:

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(h W./T. Orders, Seni Resipent Inspector Date Signed C/ R. Ogle, Resid t In/pector Date Signed J L. Stare os, P opect Engineer Date Signed Approved by:

--

. Christensen, Chief Da e igned Reactor Projects Section 1A Division of Reactor Projects SUMMARY SCOPE:

This routine, resident inspection was conducted in the areas of plant operations, maintenance observation, engineering evaluation, and plant support activities. The inspection effort included reviews of activities during non regular work hours on January 9, 10, 13, 14, 23, February 2, 5, and 10, 199 RESULTS:

Plant Operations:

A non-cited Violation was identified which involved three mis-positioned waste disposal system components. The components were misaligned due to a poorly written clearance and an operator's failure to implement a clearance as writte An Unresolved Item was also identified which pertains to the licensee's interpretation of the chemical and volume control system design basis which would allow the utilization of the A charging pump as an equivalent replacement for the B or C charging pumps, even though the A pump does not have an emergency power sourc PDR ADOCK 05000261 G

PDR

Maintenance:

One non-cited Violation was identified involving two examples of inadequate safety-related battery surveillance procedures. One example dealt with a non conservative pilot cell voltage acceptance criteria, and the other example concerned an acceptance criteria inconsistent with the results expected from a formula in a procedur A weakness was also identified concerning the adequacy of reviews of a vendor manual revision and the utilization of vendor supplied dat Engineering:

The inspectors collected steam and feedwater flow measurements from the plant computer and RTGB indicators which indicated that the steam flow nozzle performance appears to be consistent with the assumed accuracy of the applicable calibration. This data supported closure of URI 94-28-0 Plant Support:

One Unresolved Item was identified in the Security area concerning protected area fence irregularities and security personnel issue r L PERSONS CONTACTED Licensee Employees:

W. Brand, Supervisor, Environmental and Radiation Control M. Brown, Manager, Design Engineering A. Carley, Manager, Site Communications B. Clark, Manager, Maintenance

  • D. Crook, Licensing/Regulatory Compliance C. Gray, Manager, Materials and Contract Services D. Gudger, Licensing/Regulatory Programs
  • K. Jury, Manager, Licensing/Regulatory Programs J. Kozyra, Licensing/Regulatory Programs
  • R. Krich, Manager, Regulatory.Affairs B. Meyer, Manager, Operations G. Miller, Manager, Robinson Engineering Support Section D. Taylor, Plant Controller G. Walters, Manager, Support Training R. Wardern, Manager, Plant Support Nuclear Assessment Section W. Whelan, Industrial Health and Safety Representative D. Whitehead, Manager, Plant Support Services T. Wilkerson, Manager, Environmental Control
  • L. Williams. Manager, Security
  • L. Woods, Manager, Technical Support
  • D. Young, Plant General Manager Other licensee employees contacted included technicians, operators, engineers, mechanics, security force members, and office personne NRC Personnel:
  • W. Orders, Senior Resident Inspector
  • C. Ogle, Resident Inspector J. Starefos, Project Engineer
  • Attended exit interview on February 10, 199 Acronyms and initialisms used throughout this report are listed in the last paragrap. PLANT STATUS AND ACTIVITIES Operating Status The unit operated at power throughout the report period with no major operational perturbances. At the end of the report period, the unit had been on line for 188 day Other NRC Inspections and Meetings The Project Engineer, J. Starefos, was onsite during the weeks of January 9-13 and January 23-27, 1995, to assist the Resident Inspectors. The details of that inspection are documented in this repor A routine radiological effluents/chemistry and radioactive material transportation inspection was accomplished by B. Carrion and R. Shortridge of the NRC Region II office. They were accompanied by G. Guerra of the NRC Region IV office. Details of that inspection are delineated in Inspection Report 50-261/95-0. OPERATIONS Plant Operations (71707)

The inspectors evaluated licensee activities to determine if the facility was being operated safely and in conformance with regulatory requirements. These activities were assessed through direct observation, facility tours, interviews and discussions with licensee personnel, evaluation of safety system status, and review of facility record The inspectors reviewed shift logs, operation's records, data sheets, instrument traces, and records of equipment malfunctions to assess equipment operability and compliance with TS. The inspectors evaluated the operating staff to determine if they were cognizant of plant conditions, responded properly to alarms, adhered to procedures and applicable administrative controls, were cognizant of in-progress surveillance and maintenance activities, and were aware of inoperable equipment status. The inspectors performed instrument channel checks, reviewed component status, and reviewed safety-related parameters to determine compliance with TS. Shift changes were routinely observed to determine if system status continuity was maintained and that proper control room staffing existed. Access to the control room was controlled, and operations personnel carried out their assigned duties in an effective manner. Control room demeanor and communications were appropriat Routine plant tours were conducted to evaluate equipment operability, assess the general condition of plant machinery, and to verify that radiological, fire protection, and physical protection controls, were properly implemente CVCS System Operation And Technical Specification Compliance Robinson Technical Specification 3.2, Chemical and Volume Control System, requires in part, that the reactor not be made critical unless two charging pumps are operable. The licensee's definition

  • of "operable" as delineated in Definition 1.3, states, "A system subsystem, train, component or device shall be operable or have operability when it is capable of performing its specified function(s).

Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its specified function(s) are also capable of performing their related support function(s)."

Robinson has three installed positive displacement charging pump The B and C pumps are supplied power from the El and E2 onsite, emergency electrical power sources. The A charging pump is not fed from an emergency electrical power source, and as such does not appear to meet the definition of an "operable" charging pum The licensee routinely removes either B or C charging pumps from service for routine maintenance/surveillance and heretofore has regarded the A charging pump as a fully "operable" replacement for the pump removed form servic On January 15, 1995, the licensee removed the C charging pump from service due to a crack in a drain line off the pump suction stabilizer. The licensee considered the A and B charging pumps to be operable and considered themselves to be in compliance with TS 3.2 which requires two charging pumps to be operable if the reactor is critica At 1:13 p.m., on the afternoon of January 17, 1995, the A charging pump high speed alarm was received which the licensee subsequently determined was due to the rapid degradation of the pump's packin The licensee was forced to remove the A pump from service. The B charging pump was placed in service and the licensee entered the 24-hour TS action statement which is applicable when only one charging pump is operable. As a precautionary measure, the licensee placed the C charging pump in an "available" lineup, even though the pump had not been repaire By 10:45 a.m., the next morning, the license had completed maintenance on the A pump, including post maintenance testin Although the pump was in the Alert range for both flow and vibration, the licensee declared the pump to be operable and exited the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> action statemen As an adjunct to assessing the event, the inspectors questioned the licensee concerning their interpretation of the requisites of T.S. 3.2. and the viability of the A charging pump. The licensee's position, as provided to the resident inspectors, is as follows:

Since HBRSEP was designed such that the 'A' pump was not designed to be powered from the emergency bus, there is no

"emergency electrical power source" and therefore, the 'A'

pump is operable as long as its normal power source is available. Additionally, since no credit is taken for the charging pumps in the UFSAR Accident Analyses and the pumps are stripped from their respective emergency buses, the emergency power sources for the 'B' and 'C' charging pumps are not required to be operable for the charging pumps to be able to perform their intended function, by definition. The Technical Specification clearly recognizes that the plant design has three charging pumps capable of providing boration. Therefore, the use of any 2 of the 3 charging pumps meets TS Sections 3.2.2 and 3.2.3 and is consistent with our plant design and CLB."

The resident inspectors did not agree with the licensee's position and requested a conference call which involved RH and NRR personnel, the resident staff and licensee personnel in order to resolve the issue. Subsequent to the call, during which the licensee stated their case, it was decided that the issue would be carried as an Unresolved Item pending NRC review of the design and licensing basis for the system. Accordingly, this issue will be tracked as URI 95-03-01, Chemical and Volume Control System Design Basis TI Followup - Operations (92901)

(CLOSED) URI 94-28-02, Mis-positioned Waste Disposal System Components Unresolved Item 94-28-02 documents the licensee's discovery of three mis-positioned waste disposal system components on December 28, 1994. The inspectors were advised that the mis positionings occurred during restoration from maintenance. The specific components involved were WD-1721 and WD-1722, RCDT Pump Discharge Line Auto Isolation Valves and the RCDT Pump A control switch. Valves WD-1721 and WD-1722 were found shut with their control switches in "Auto." The correct lineup per the operating procedure is for the valves to be open with the control switches in "Auto." The pump control switch was discovered in the "Off" position instead of the required "Auto" position. The components were restored to their proper position and an ACR was generate In response to this event, the inspectors independently reviewed the clearance, Operating Procedure OP-701, Waste Disposal Liquid, and the ACR evaluation. The inspectors also interviewed the responsible AO regarding his actions while removing the clearance

  • s and repositioning the waste disposal component *

Based on this review, the inspectors concluded that the components were mis-positioned as a result of two distinct problem Valves WD-1721 and WD-1722 being mis-positioned was the result of a poorly written clearance. The restored position specified for these valves on the clearance was "Auto." The restored position dealt only with the valves' control switch position; no reference was made to the required position of the valves themselve Thus, the AO's action to place the control switch to "Auto" satisfied the clearanc The inspectors concluded that the mis-positioning of RCDT A pump switch resulted from the failure of the AO to properly implement the clearance as written. The inspectors noted that the AO initialed for restoring the pump switch to "Auto" despite the fact that it was found in "Off."

As a result of this discrepancy, the inspectors reviewed with the AO, his actions while removing the clearance. This included a detailed, step-by-step walkdown at the waste disposal pane Based on his reenactment, his familiarity with the components, and his description of the events, the inspectors concluded that the mispositioning was the result of a non-cognitive error on the part of the AO. The AO stated that a hectic series of activities which had occurred immediately prior to the clearance restoration may have contributed to his erro The inspectors reviewed the clearance database and noted that the licensee has updated the restoration positions for the valves to require that they be open with the control switch in "Auto."

Further, the inspectors were advised that the licensee has undertaken a review of the clearance database to ensure that similar problems do not exist for other components. The corrective actions identified by the licensee also included counselling the responsible individual. A number of previous mis positioning events were the subject of a detailed licensee review, the results of which are documented in ACR 94-01335. The inspectors concluded that the corrective actions taken for these previous events have not been in place for a sufficient period of time to have prevented the AO's mis-positioning of the RCDT A pump switc The failure to properly restore the waste disposal system components represented a violation of the requirements of Operations Management Manual Procedure, OMM-005, Clearance and Test Request. However, this violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B of the Enforcement Policy. This is identified as a L

Non-Cited Violation, NCV 95-03-02:

Mis-positioned Waste Disposal System Components As Result Of Failure To Properly Implement Clearanc As a followup to this event, the inspectors also reviewed ACR 94 01335 which documented the licensee's review of 25 equipment mis position events which occurred between October 1993 and November 1994. The licensee concluded that the majority of the events were attributable to lack of self-assessment or inattention to detail on the part of associated personnel, inadequate programs and procedures, poor work practices and ineffective communication. A number of corrective actions were initiated in the Operations organization with the intent to preclude further mis-positioning The corrective actions include, but are not limited to, improving verbal communication in the control room to incorporate three way information exchange, the development of a control room switch position checklist, and the use of independent verification during the clearance process and system alignment This non-cited violation represents another data point in a chronology which suggests the evolution of a programmatic configuration control issue. The resident inspectors will continue to monitor the licensee's corrective actions for effectivenes (CLOSED) VIO 93-11-02, Failure to Follow Procedures for a Heat Trace Circuit In Alarm/Failure to Follow Procedure During Performance of OST-254 Violation 93-11-02 dealt with failures of Operations personnel to implement procedures, in response to a boric acid heat trace alarm and operator actions taken outside of procedures to open a valve during the performance of a RHR system leak chec The inspectors reviewed a written directive as well as training material provided to Operations personnel to reinforce licensee managements' expectations in the area of procedure complianc Additionally, the inspectors reviewed Operations Management Manual Procedure, OMM-001, Operations - Conduct Of Operations. The inspectors noted that appropriate guidance exists in these sources to address the issues identified by the violation. Based on this review, VIO 93-11-02 is close One noncited violation and one unresolved item were identified. Based on information obtained during the inspection, except as noted above, the area/program was adequately implemente.

MAINTENANCE Maintenance Observation (62703)

The inspectors observed safety-related maintenance activities on systems and components to ascertain that these activities were conducted in accordance with TS, approved procedures, and appropriate industry codes and standards. The inspectors

  • determined that these activities did not violate LCOs and that required redundant components were operable. The inspectors verified that required administrative, material, testing, radiological, and fire prevention controls were adhered to. In particular, the inspectors observed/reviewed the following maintenance activities detailed below:

WR/JO 95AAYL1 Investigate Problem With Bistables Being Lit Due To Work On Instrument Bus 6 WR/JO 95ABHK1 Replace Oil in Service Water Booster Pump B WR/JO 95AHKP1 Inspect MCC-5 Breakers (2 only)

WR/JO 94AQYB1 Replace Diaphragm on Valve CVC-332 WR/JO 94ASDTI Replace Diaphragm on Valve CVC-349E Loss Of Instrument Bus 6 At 10:23 a.m., on January 13, 1995, the licensee entered Abnormal Operating Procedure AOP-024, Loss Of Instrument Bus, following the unexpected activation of numerous RTGB annunciators and bistable Additionally, pressurizer control heaters were deenergized and RCS letdown was automatically isolated. Pressurizer pressure indicator PI-455 also indicated approximately 40 psig low. As a result of this unexpected performance of PI-455, the licensee entered TS 3.0. until the bistables associated with PT-455 could be tripped as require The licensee determined that these events occurred during the reinstallation of the cover for the Instrument Bus 1 panel following an inspection of the panel interior. Subsequent troubleshooting revealed that Circuit Breaker 4 on Instrument Bus 1 had an intermittent open circuit which interrupted power to Instrument Bus 6. By 4:04 p.m. the licensee had removed PT-455 from service and exited TS 3.0. Power was permanently restored to Instrument Bus 6 from a spare breaker in Instrument Bus 1 through the implementation of MOD ESR 95-00064. Following testing, all associated circuitry was restored to operation by 6:33 a.m. on January 14, 199 Immediately following notification of the event by the licensee, the inspectors responded to the control room at 11:16 a.m. on January 13, 1995. The inspectors observed that plant process parameters were stable. It was also noted that command and control in the control room were strong. The inspectors also observed that the control room retained appropriate control over subsequent troubleshooting and repair efforts. The inspectors witnessed the troubleshooting and repair efforts and perceived them to be logical and appropriately implemented. The inspectors have no further questions on these efforts. The licensee has written an ACR to address the unexpected performance of PI-45 Service Water Booster Pump Oil Change The inspectors witnessed a changeout of the oil in SWBP B on January 25, 1995. This oil change was accomplished due to cloudiness observed by the licensee in the oiler bottle assembl Overall, the conduct of the maintenance was good. The technician was well organized and accomplished the task in a methodical fashion. The inspectors noted that the technician was careful to ensure that the specified oil was installed in the pump. This included verifying the oil specified for the pump in the licensee's procedure. Further, the small containers used by the technician to transfer the oil from the oil shed to the pump were labelled with the oil purchase order number. The inspectors were advised that this technique is used to ensure that the small bottles of oil do not become cross-contaminated from use on different batches of oi However, at the pump, the inspectors noted that the technician used one of the small fill bottles to evacuate a small quantity of the freshly added oil from the pump fill assembly. While the quantity of the oil extracted was small and not visibly contaminated, the inspectors questioned the individual on the potential for this practice to contaminate the oil in the fill bottle and hence, subsequent maintenance efforts using that bottle. Following this questioning the technician stated his intention to discard the bottle after the oil chang The inspectors also questioned engineering technical support personnel on the basis for the oil specified in the licensee's procedures. The inspectors noted that the specified Texaco R & 0 68 oil had a different viscosity from the recommended oil in the pump technical manua In response, the inspectors were advised that this oil had been recommended in a site lubrication study conducted by Texaco in 1983. The licensee was unable to furnish any documentation to show their evaluation of the acceptability of this study. On January 30, 1995, the inspectors were advised that the pump vendor had subsequently informed the licensee of the acceptability of the R & 0 68 oi This is the second example identified by the inspectors in recent months of inconsistencies in the licensee's oil program. The licensee informed the inspectors on January 30, 1995, that an ACR has been generated to evaluate the basis for the oil used in safety related application Chemical And Volume Control System Valve Repairs The inspectors observed repairs necessitated by body to bonnet leakage on valves CVC-349E, Boric Acid Transfer Pump "A" Discharge Pressure PI-110 Root Isolation Valve and CVC-332, Boric Acid Transfer Pump "A" Discharge Isolation. This maintenance was performed in accordance with WR/JO 94AQYB1 and 94-ASDT1. The

  • valve diaphragms and body to bonnet studs were inspected/replaced under these ticket The inspection effort consisted of observation of most of the repair effort; witnessing a portion of the clearance restoration; review of the work tickets and valve technical manuals; review of selected documentation related to the calibration of torque wrenches; and the examination of the valve stud During the post-maintenance review, the inspectors observed that adjustment of the valve's travel stop was not specified in the work ticket instructions for CVC-332. When asked, the licensee stated this adjustment was not made to CVC-332. This adjustment affects the valve stroke and could affect the seat tightness of CVC-332. The inspectors reviewed MMM-003, Appendix A, Post Maintenance Testing, and noted that since CVC-332 is an ISI Category B Passive Valve, no post maintenance check for seat leakage or travel stop adjustment is procedurally required. The inspectors noted that the same maintenance on a non-ISI valve would have triggered a seat leakage test. A review of the system drawing indicated that CVC-332 is a normally locked open valve, hence, seat tightness of CVC-332 is not required for the CVCS system to be operable. This issue was reviewed with the responsible planner and supervisor. The inspectors were advised that travel stop adjustments are typically specified for this style valve. The failure to include this adjustment in the CVC-332 work instructions was attributed to an oversight on the part of the planner. The inspectors concluded that this oversight represented a lack of attention to detail on the part of the planner. The inspectors have no further questions on this aspect of the maintenanc Surveillance Observation (61726)

The inspectors observed certain safety-related surveillance activities on systems and components to ascertain that these activities were conducted in accordance with license requirement On a selective basis, the inspectors determined that precautions and LCOs were adhered to, the required administrative approvals and tagouts were obtained prior to test initiation, testing was accomplished by qualified personnel in accordance with an approved test procedure, test instrumentation was properly calibrated, the tests were completed at the required frequency, and that the tests conformed to TS requirements. Specifically, the inspectors witnessed and/or reviewed portions of the following test activities:

MST-902 Battery Test - Daily, 5 Days per Week

OST-10 Power Range Calorimetric During Power Operation OST-51 Reactor Coolant System Leakage Evaluation Safety Related Battery Surveillance On January 10, 1995, the inspectors observed testing of the A and B safety-related batteries in accordance with MST-902, Battery Test - Daily, 5 Days per Week, Revision 1 During review of the procedure, the inspectors noted that the acceptance criteria for the pilot cell voltage was 2.11 Vdc minimum (Attachments 8.2 and 8.3).

This acceptance criteria in MST-902 was less conservative than the criteria in MST-903, Station Battery Charge - Monthly, Revision 19, which required an equalizing charge to be performed

"if the lowest cell voltage is less than 2.13 Vdc". MST-903 was consistent with the vendor manual recommendation for an equalizing charge to be performed when the voltage is below 2.13 Vdc. The licensee addressed this issue in ACR 95-00144 and determined that the root cause of this event was an inadequate technical review of station battery requirements during the procedure revision process in February 1983. The planned corrective action is to "revise MST-902's minimum voltage acceptance criteria for "A" and "B" Station Battery pilot cells."

MST-903, Station Battery Charge - Monthly, Revision 19, Attachments 8.4 and 8.8, include the A and B Station Battery Equalizing Charge Data Sheets. During the equalizing charge of the battery, parameters (such as the equalizing charging current)

are recorded on the data sheet hourly. After three consecutive hours of charging, equalizing charging current stability is determined in accordance with step 7.6.12 or 7.10.12 (A or B battery).

This is done by dividing the most current recorded equalizing charging current by the equalizing charging current from two hours prior. Steps 7.6.12.3 and 7.10.12.3 of the procedure state that "If the dividend is less than or equal to 1.10, record the date and time Equalizing Charging Current stabilized..." Based upon an expected decreasing equalizing charging current, the dividend would always be less than one and therefore, always meet the acceptance criteria. Accordingly, the procedure was inadequate. The inspectors also noted that the range of the installed plant instrumentation cannot effectively indicate the actual equalizing charging current. Thus, the performance of step 7.6.12 or 7.10.12 resulted in dividing zero by zero resulting in useless information. The licensee initiated ACR 95-00337 to address this issu The two examples of inadequate procedures described above are a violation of Technical Specification 6.5.1.1. However, this NRC identified violation is not being cited because the criteria

specified in Section VII.B of the NRC Enforcement Policy was satisfied. This item will be tracked as non-cited violation NCV 95-03-03, Inadequate Procedures For Safety Battery Surveillanc The inspectors also concluded that a weakness existed regarding the disposition of an updated vendor manual for the battery as

"information only." The justification for not incorporating this updated manual was presented in DCF 93-U-0205 which stated "the original instructions provided at time of purchase are the governing or master document to be used to maintain that battery."

This position is not consistent with recent correspondence from the vendor. Although the vendor letter states that "...

the original flooded cell operations manual should be the governing operations manual...", the letter continues to state "...although temperature correction factors for cell voltages may not be included in your manual, it may be prudent to selectively adopt such types of changes to assist in the long life and performance of your cells."

The DCF justification for the updated manual was very general and did not address the technical differences (such as the voltage temperature correction factor) or justify any deviation in accordance with procedure PLP-038, Technical Manual/Vendor Recommendation Review Program, step 6.3.5. A discrepancy was also identified between the temperature correction factors chart for specific gravity correction contained in the licensee's surveillance testing procedures, and the vendor manua The vendor manual recommends a correction factor of 0.001 per 30 F. The licensee's procedure uses a correction factor of 0.0009 per 30 F. The procedural correction factor is positive for electrolyte temperatures above 770 F and negative for electrolyte temperatures below 770 F. Therefore, the discrepancy is non conservative when the electrolyte temperature drops below 77* The licensee initiated ACR 95-00145 to address this discrepanc The licensee plans to correct the chart to reflect the vendor recommended temperature correction factor in the following procedures:

MST-902, MST-903, MST-920, MST-921, PM-425, and CM-30 Followup - Maintenance (92902)

(CLOSED) VIO 93-11-05, Failure to Properly Maintain Maintenance Procedure CM-008 Violation 93-11-05 dealt with the inadvertent removal of a precaution from the corrective maintenance procedure to test the overspeed trip setpoint of the SDAFW pump following certain maintenance activities. The inspectors independently reviewed the revised procedure, Corrective Maintenance Procedure, CM-008, Steam

Drive Auxiliary Feedwater Pump, Turbine, and Auxiliary Maintenance. The inspectors noted that an appropriate precaution including a reference to its source are now included in the procedur In conjunction with the original related mechanical maintenance violation, the licensee conducted a review of 89 safety procedures. This review indicated that 29 of the procedures required revisions significant enough to be implemented prior to RFO 1 The licensee stated that approximately half of these procedures had information inadvertently deleted which was essential to personnel or equipment safety or the successful performance of the'procedure. The licensee indicated that the necessary revisions to the procedures had been complete The licensee conducted training to reinforce the requirement of Administrative Procedure, AP-004, Procedure Control, to ensure the references to commitments be included in procedures. The inspectors reviewed records of this trainin The inspectors reviewed the results of licensee audits conducted to ensure that on-site Nuclear Safety action items, RAIL Items, and ACR action items had been incorporated into procedures. The licensee stated that any deficiencies identified were corrected or assigned a follow on action ite Based on the results of this review, VIO 93-11-05 is close (CLOSED) 94-15-01, Failure To Properly Establish, Implement, and Maintain Maintenance Procedures Violation 94-15-01, Failure To Properly Establish, Implement, And Maintain Maintenance Procedures, dealt with three examples of failure to properly establish, implement, or maintain a maintenance procedure. The licensee determined that the reason for the violation was insufficient attention to detail and inadequate self-checking on the part of the individuals involved in each of the cited example The licensee's corrective actions included but were not limited to: the adjustment of the control room differential pressure instrument DPI-6520 scale for proper indication, counselling of personnel involved in the events, disciplinary action against the I & C technician involved in working on the incorrect BAST temperature controller, installation of a new EDG lube oil strainer pressure plate washer, and disciplinary action against the mechanic involved with the EDG lube oil strainer pressure plate washer issue. Based on the inspectors review of the licensee's corrective actions, VIO 94-15-01 is close (CLOSED) URI 94-04-04, Adequacy of Diesel Generator Maintenance In Inspection Report 94-04 the inspectors documented as Unresolved Item 94-04-04, concerns relative to the adequacy of corrective maintenance performed on the B emergency diesel generator. This maintenance ultimately lead to catastrophic damage to the engine's blower and turbochargers. The maintenance involved corrective actions to repair the B EDG air flapper valve. The inspectors continued their review of this maintenance in their next monthly inspection report, 94-08, in which the inadequacies associated with the licensee's efforts to repair the diesel were characterized and documented as one of two examples of inadequate corrective action, which collectively comprised one violation, 94-08-02. 'Accordingly, Unresolved Item 94-04-04 is close One non-cited violation was identified. Based on the information obtained during the inspection, the area/program was adequately implemente.

ENGINEERING Followup-Engineering (CLOSED) URI 94-28-05, Basis for Steam and Feedwater Flow Transmitter Calibration Values URI 94-28-05 documents the inspectors' questions concerning the basis of the numerical values used in the calibration of the steam and feedwater flow transmitters. These Rosemount transmitters provide signals to the reactor protection and the engineered safety features systems. The inspectors noted that the values for calibration of all six steam flow transmitters were identica Futhermore, despite different characteristics for each feedwater flow nozzle and for each different nozzle tap connections, only two different sets of values were used for the calibration of the six feedwater flow transmitter The inspectors reviewed an August 15, 1967, letter from the steam flow nozzle manufacturer which established the nozzle accuracy at plus or minus one percent. Further, this letter provided the setpoints which are used in the steam flow transmitter calibrations. However, the licensee was unable to provide any data which demonstrated that actual testing of the flow nozzles to verify the stated accuracy had been performe The inspectors noted from a review of Calculation Number -RNP I/INST-1040, Main Steam Flow Accuracy Calculation, dated May 16, 1994, that the licensee assumes a steam flow transmitter accuracy of 2.0%. Part of the basis for this assumption as stated in the calculation was that steam flow is normalized to feedwater flo The licensee was unable to provide any documentation that steam flow is normalized to feedwater flo On January 19, 1995, the inspectors collected steam and feedwater flows from the plant computer and RTGB indicators. The inspectors determined that the indicated steam flows and feed flow were within the tolerances specified in the Steam Flow Accuracy Calculation. This observation would tend to imply that the steam flow nozzle performance is consistent with the assumed accuracy in the calculation. The inspectors have no further questions on steam flow nozzle performanc The questions raised related to feedwater flow nozzle transmitter setpoints will be tracked as part of URI 94-27-06: Resolution Of Feedwater Nozzle Performance and Impact On Calorimetric. URI 94-28-05 is close (CLOSED) URI 94-04-03, Evaporative Air Cooler/Diesel Support Unresolved Item 94-04-03 addresses concerns relative to the evaporative air coolers (EAC) which serve to cool the diesel rooms. The immediate concern involved an event which occurred on January 20, 1994, during which the service water supply to the evaporative air coolers burst due to freezing. The licensee's immediate corrective action was to isolate service water to the cooler The inspectors asked the licensee if the coolers were required diesel generator support equipment. Although the licensee's immediate response was that they were not, the licensee was unable to completely resolve the inspectors' question due to the unavailability of supporting design documentation. Accordingly, the issue was carried as Unresolved until the licensee could verify their positio The inspectors have subsequently reviewed a post de-facto licensee analysis which was completed on May 20, 1994, and documented in Memos RNP-ES-94/0043 and RNP-ES-94/0040, which confirms the licensee's position that the coolers are not required diesel generator support equipment. Accordingly, Unresolved Item 94-04-03 is close No violations or deviations were identified. Based on the information obtained during the inspection, the area/program was adequately implemente.

PLANT SUPPORT Plant Support Activities (71750)

Security Concerns While conducting a routine protected area fence walkdown on January 5, 1995, the inspectors questioned the configuration of three vehicle gates on the protected area perimeter. The inspectors were concerned that sufficient space existed between two of the gates and the respective, adjacent fence to permit personnel access. Similarly, slack in a chain used to secure a third gate was sufficient to permit access between the two halves of the gat After reviewing these concerns, the licensee posted a watchperson as a compensatory measure for one of the gates. The inspectors were advised that the second gate was under the direct observation of security personnel in PAP West and no additional compensatory measures were necessary. The chain was tightened on the third gate. The inspectors brought this issue to the attention of the Manager of Security and the RH Security personne On January 25, 1995, the resident inspectors were on a routine plant tour, when upon entering the CAS, it was noticed that the on duty CAS operator was standing with his back to the monitoring equipment, peering through a window into the adjacent room. While the inspectors were still in the area, the CAS operator was relieved by his oncoming shift replacement. It should be noted that any alarms received by the monitoring equipment would have triggered an audible alarm, to which the operator would have responded. The inspectors brought the issue to the attention of the Manager of Security and the RH Security personne On February 2, 1995, the resident inspectors identified to the Manager of Security, inspector field observations collected during routine tours, which indicated that some security personnel might be lingering in comfortable secluded areas for extended period The Manager of Security performed security computer analysis which revealed that in some cases, guards had in fact lingered in comfortable, secluded areas for periods in excess of 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> This issue was discussed with RH Security personne Pending review of these issues by Region II Security personnel, they will be tracked as an Unresolved Item, URI 95-03-04, Security Fence And Gate Characteristics, And Security Force Performance One unresolved item was identifie.

EXIT INTERVIEW Preliminary exit findings were communicated to the licensee regarding Project Engineer inspection efforts on January 27, 199 The inspectors met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on February 10, 199 During this meeting, the inspectors summarized the scope and findings of the inspection as they are detailed in this report. The licensee representatives acknowledged the inspector's comments and did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection. Other than the position regarding acceptability of the A charging pump, as described in paragraph 3, no dissenting comments were received from the license Item Number STATUS Description/Reference Paragraph URI 95-03-01 Open CVCS Design Basis TIA (paragraph 3).

NCV 95-03-02 Open/Closed Mis-positioned Waste Disposal System Components As Result Of Failure To Properly Implement Clearance (paragraph 3).

NCV 95-03-03 Open/Closed Inadequate Procedures For Safety Battery Surveillance (paragraph 4).

URI 95-03-04 Open Security Fence And Gate Characteristics, and Security Force Performance (paragraph 6).

VIO 93-11-02 Closed Failure To Follow Procedure For a Heat Trace Circuit In Alarm/Failure To Follow Procedure During Performance of OST-254 (paragraph 3).

VIO 93-11-05 Closed Failure To Properly Maintain Maintenance Procedure CM-008 (paragraph 4).

URI 94-04-03 Closed Evaporative Air Cooler/Diesel Support (paragraph 5).

URI 94-04-04 Closed Adequacy Of Diesel Generator Maintenance (paragraph 4).

4-15-01 Closed Failure To Properly Establish, Implement And Maintain Maintenance 0I Procedures (paragraph 4).

URI 94-28-02 Closed Mis-positioned Waste Disposal System Components (paragraph 3).

URI 94-28-05 Closed Basis for Steam And Feedwater Flow Transmitter Calibration Values (paragraph 5). ACRONYMS AND INITIALISMS ACR Adverse Condition Report AO Auxiliary Operator BAST Boric Acid Storage Tank CAS Central Alarm Station CLB Current Licensing Basis CV Containment Vessel CVC Chemical and Volume Control CVCS Chemical and Volume Control System DCF Document Change Form DPI Digital Position Indication EAC Evaporative Air Cooler EDG Emergency Diesel Generator ESF Engineered Safety Feature I & C Instrumentation And Control ISI Inservice Inspection LCO Limited Condition Of Operation MOD ESR Modification Engineering Service Request MMM Maintenance Management Manual PAP Personnel Access Portal PI Pressure Indicator psig Pounds per square inch - gage RAIL Regulatory Action Item List RCDT Reactor Coolant Drain Tank RCS Reactor Coolant System RFO Refueling Outage RHR Residual Heat Removal RTGB Reactor Turbine Gage Board SDAFW System Driven Auxiliary Feedwater STS Standard Technical Specifications L

SWBP Service Water Booster Pump TIA Technical Interface Agreement TS Technical Specification URI Unresolved Item Vdc Volts Direct Current WR/JO Work Request/Job Order L