IR 05000261/1981036
| ML14176A737 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 01/27/1982 |
| From: | Burger C, Weise S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A733 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.K.3.12, TASK-TM 50-261-81-36, NUDOCS 8204010405 | |
| Download: ML14176A737 (8) | |
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1 RE o
UNITED STATES I
.
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report No. 50-261/81-36 Licensee:
Carolina Power & Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name: H. B. Robinson Steam Electric Plant Docket No. 50-261 License No. DPR-23 Inspection at H. B. Robinson site near Raleigh, North Carolina Inspector: _ _
I I_________
____
.
// Z S. Weise V
.Date Signed Approved by:
C. Burge', Section Chief, Division of Resident Date Signed and Reactor Project Inspection SUMMARY Inspection on December 11, 1981 - January 10, 1982 Areas Inspected This routine, announced inspection involved 111 resident inspector-hours on site in the areas of technical specification compliance, plant tour, operations performance, reportable occurrences, housekeeping, site security, surveillance activities, maintenance activities, quality assurance practices, radiation control activities, outstanding items review, IE Circular and Notice followup, annual emergency drill, TMI Action Item review, and previous enforcement action followu Results Of the 15 areas inspected, no violations or deviations were identified in 13 areas; 3 violations were found in 2 areas (Failure to review a potential safety hazard, paragraph 10. Failure to implement procedures and perform a safety review, paragraph 9.a and Failure to establish procedures, paragraph 9.c.).
8204010405 920325 PDR ADOCK 05000261 PDR
DETAILS 1. Persons Contacted Licensee Employees R. B. Starkey, Plant General Manager
- W. Crawford, Manager, Operations and Maintenance
- J. Curley, Manager, Technical Support
- F. Lowery, Operations Supervisor Unit 2 R. Chambers, Maintenance Supervisor Unit 2
- F. Gilman, Senior Specialist, Regulatory Compliance
- C. Wright, Specialist, Regulatory Compliance
- S. Zimmerman, Manager, Planning and Scheduling
- J. Young, Director, Corporate QA/QC
- M. Page, Engineering Supervisor
- D. Baur, Project QA/QC Specialist Other licensee employees contacted included technicians, operators, mechanics, security force members, and office personne *Attended exit interview Exit Interview The inspection scope and findings were summarized on January 8, 1982 with those persons indicated in paragraph 1 above. The licensee acknowledged the violations as state. Licensee Action on Previous Inspection Findings (Closed) Unresolved item 81-32-02. This item concerns issues identified in Inspection Report 50-261/81-32. Resolution of these items is discussed in paragraph (Closed) Severity Level V Violation 81-07-08. This item dealt with the licensee's failure to make termination exposure reports to the NRC within the required time. The inspector interviewed licensee personnel and reviewed Revision 10 to Health Physics Procedure - 9. Based on this review, the inspector determined that the licensee had completed the corrective actions stated in CP&L's response letter dated July 30, 198. Unresolved Items Unresolved items were not identified during this inspectio. Plant Operations Review The inspector periodically during the inspection interval reviewed shift logs and operations records, including data sheets, instrument traces, and records of equipment malfunctions. This review included control room logs,
auxiliary logs, operating orders, standing orders, jumper logs and equipment tagout records. The inspector routinely observed operator alterness and demeanor during plant tour During abnormal events, operator performance and response actions were observed and evaluated. The inspector conducted random off-hours inspections during the reporting interval to assure that operations and security remained at an acceptable leve Shift turnovers were observed to verify that they were conducted in accordance with approved licensee procedures. The inspector had no further comment. Technical Specification Compliance During this reporting interval, the inspector verified compliance with selected limiting conditions. for operation (LCO's) and reviewed results of selected surveillance tests. These verifications were accomplished by direct observation of monitoring instrumentation, valve positions, switch positions, and review of completed logs and records. The licensee's compliance with selected LCO action statements were reviewed as they happene. Plant Tour The inspector conducted plant tours periodically during the inspection interval to verify that monitoring equipment was recording as required, equipment was properly tagged, operations personnel were aware of plant conditions, and plant housekeeping efforts were adequate. The inspector determined that appropriate radiation controls were properly established, excess equipment or material was stored properly, and combustible material was disposed of expeditiously. During tours the inspector looked for the existence of unusual fluid leaks, piping vibrations, pipe hanger and seismic restraint abnormal settings, various valve and breaker positions, equipment clearance tags and component status, adequacy of firefighting equipment, and instrument calibration dates. Some tours were conducted on backshifts. The inspector performed major flowpath valve lineup verifications and system status checks on the following systems:
a. selected containment isolation valves b. Containment Spray System c. Boration paths No violations or deviations were identifie. Physical Protection The inspector verified by observation and interview during the reporting interval that measures taken to assure the physical protection of the facility met current requirements. Areas inspected included theorgani zation of the security force, the establishment and maintenance of gates, doors and isolation zones in the proper condition, that access control and
badging was proper, that search practices were appropriate, and that escorting and communications procedures were followe. Power Operated Relief Valves (PORV's) and Block Valve Issues This inspection closes unresolved item 81-32-02 identified as a result'of the partial depressurization event of November 30, 198 a. The inspector was concerned that inadequate controls on modifications and maintenance to the PORV's contributed to their leakage and removal from service. The inspector determined that the PORV spring tension was reduced about May, 1979 following the replacement of valve internals. Modification-480, which changed the internals was reviewe The safety review done as part of the modification stated that the new plug, stem, and cage assembly would give the modified valve a faster opening time and quicker flow response. Although no documentation exists, it appears the spring tension was reduced to allow the PORV's to meet the two second opening design specification. This spring tension change was not treated as a plant modification as required by Administrative Instruction Section 6 of the licensee's Plant Operating Manua Failure to implement the modification procedures is a violation (50-261/81-36-01).
Additionally, the inspector noted that in recent PORV testing following resetting of the spring tensions to the original design value, the PORV's met the opening time requirements. Thus reducing the spring tension may not have been necessary at al b. The inspector was concerned that PORV leakage (with the block valves open) may have exceeded Technical Specification limits on reactor coolant system pressure boundary leakage. A review of daily leakage measurement data indicated that leak rates were within Technical Specification limits before the block valves were shut on plant heatu At normal plant operating temperature and pressure, the leak rates were determined with the block valves closed, so no information exist c. The inspector was concerned that modification of the PORV's springs and continued operation with the valves leaking and the block valves closed did not receive the required Plant Nuclear Safety Committee (PNSC)
review and approva The PORV's form part of the reactor coolant system pressure boundary as defined in 10 CFR 50.2. Through document review and discussions with the licensee, the inspector determined the following. The modification, as discussed in a. above, was not handled in accordance with licensee procedures and therefore was not reviewed by the PNSC. The licensee stated that the PNSC had reviewed the issue of operating with PORV leakage and with the block valves shut and had found it acceptable. That review apparently was not documente During the 1980 refueling outage the spring adjustment was determined to be responsible for PORV leakage. This determination did not
- precipitate any new PNSC review. Failure to review the PORV modifi cation and resolve its deficiencies and potential safety concerns constitutes part of the violation of paragraph (50-261/81-36-01).
Additionally, the inspector reviewed the licensee's administrative controls on operation with the PORV's leaking and the block valves shut. The plant operating manual was reviewed, and the inspector determined that no special guidance existed for operations personnel, although they were cognizant of the valve conditions and status. A review of plant procedures revealed:
1. Abnormal Procedure-19, Malfunction of Reactor Coolant System Pressure Control, assumed automatic opening of the PORV's at 2335 psig on high system pressure. This feature had been defeated at power since 197. Operating Procedure-30, Pressurizer Pressure and Spray Control, indicated the block valves should remain open. The abnormal PORV and block valve condition had existed for nearly four years without the licensee providing operator guidance on block valve usage. Technical Specifications require that such procedures be established and implemented, and failure to do so is a violation (50-261/81-36-02).
As discussed in inspection report 50-261/81-32, the licensee has since implemented Standing Order 17 to provide operator guidance on the use of the PORV block valve.
Independent Inspection The inspector noted on past plant tours that the gas analyzer (GA) has been out of service for several months. Therefore, a review of licensee corrective actions was mad FSAR section 11 describes the GA as being used to sample tanks which discharge to the waste gas vent header and to the waste gas decay tank (WGDT) being filled. The samples are automatically analyzed to determined their hydrogen and oxygen content. There should-be no significant oxygen content in any of the tanks, and an alarm warns the operator of increasing oxygen content to prevent formation of an explosive mixtur A review of maintenance work requests and auxiliary operators' logs revealed the following:
a. The GA was last overhauled and placed in working order on October 12, 1980. During the period from October 12 - December 16, 1980, the GA was out of service six times (35 days total).
The vacuum pump coupling sheared three times sequentially and water was found in the sample lines. Between December 16, 1980 and November 20, 1981, the GA has never been in service for more than two eight-hour shifts for a total
- operating time of twenty-four hours. Discussion with licensee representatives indicated that no compensatory measures to monitor for explosive gas mixtures had been institute b. Work requests were not written to report the GA out of service on its failure in March, 198 Repairs completed on April 14, 1981 indicated the GA was operational, but.it was not returned to service. The next work request stating the GA was out of service was written in September 198 When the GA was returned to service on November 19, 1981, it operated for sixteen hours before failing and indicated explosive mixtures in several tanks. The inspector concludes that the gas analyzer has suffered from inadequate repairs and inconsistency on returning it to service. Management attention.to the corrective actions being implemented appears inadequat Discussions with operational personnel indicated that water in the piping has frequently caused GA problems in the past. One method by which this water apparently enters the piping is when a containment phase A isolation occurs. During these events sealing water is injected between the sample line containment isolation valves to the Pressurizer Relief Tank (PRT)
and the Reactor Coolant Drain Tank (RCDT).
There may be other sources of water in the lines (such as overfilling tanks), or the automatic water traps may be performing inadequatel Procedures were also reviewed to ascertain guidance provided on the importance of GA operatio OP-34, Waste Disposal - Liquid, requires operators to nitrogen purge the RCDT if hydrogen concentration approaches 4%
on the GA. OP-35, Waste Disposal - Gas, requires operators to nitrogen purge the WGDT's if hydrogen concentration approaches 4% on the GA. OP-28, Charging and Volume Control, requires the operator to use the GA to monitor Volume Control Tank hydrogen and oxygen and take corrective action to maintain oxygen below 5 volume percent. OP-37, PRT Control, requires operators to vent the PRT if oxygen concentration approaches 4%. From the above, it is obvious that the gas analyzer is presently the only equipment available to monitor and warn operators of explosive mixtures in tanks containing radioactive gase Failure to maintain the GA or provide compensatory measures poses a safety hazard, which is required to be identified and reviewed by the Plant Nuclear Safety Committee (PNSC).
Failure to perform such a review is a violation (50-261/81-36-03).
Corrective action in response to the violation should also discuss the steps taken to restore the GA to service and maintain it operationa.
Licensee Event Report (LER) Followup The inspector reviewed the following LER's to verify that the report details met license requirements, identified the cause of the event, described appropriate corrective actions, adequately assessed the event, and addressed any generic implications. Corrective action and appropriate licensee review of the below events was verified. The inspector had no further comment LER Event 81-21 Inoperable Control Rods 81-23
'A' Safety Injection Pump Trip 81-2 Heat Tracing Failure 81-25
'B' Emergency Diesel Generator Failure to Start 81-28
'C'
Steam Generator Low Level Trip Bistable Inoperable 81-30
'B' Emergency Diesel Generator Rheostat Failure 1 Review of IE Circulars and Notices (IEC's and IEN's)
The inspector verified that IE Circulars and Notices had been received onsite and reviewed by cognizant licensee personne Selected applicable IE Circulars and Notices were discussed with licensee personnel to ascertain the licensees actions on these items. The inspector also verified that IE Circulars and Notices were reviewed by the Plant Nuclear Safety Committee in accordance with facility administrative policy. Licensee action on,the following IE Circulars and Notices were reviewed by the inspector and are close N/A indicates applicable to Boiling Water Reactors onl IE Circulars IE Notices 81-08 81-07 81-11 (N/A)
81-11 (N/A)
81-12 (N/A)
81-16 (N/A)
1 Outstanding Items Review (Closed) Inspector Followup Item 81-33-02. This item concerned the practice of cleaning the automatic voltage control rheostats on emergency diesel generators. The inspector verified the licensee investigated the practice and found it acceptable. The inspector had no further question (Closed) Inspector Followup Item 81-20-02. This item concerned the licensee's need to revise the Chloride Titration Procedure, CP-8, to record the standardization, blank, and sample data. The inspector reviewed Revision 1 to CP-8 and found that the Chloride Log now requires recording of this dat (Closed) Open Item 81-19-04. This item concerned an administrative limit that had not been proceduralized. The inspector reviewed Revision 25 to procedure OP-34 and found that the limit had been incorporate (Closed) Open Item 81-26-08. This item concerned discrepancies found between the licensee's procedures and as-built alarm setpoints. The licensee has reviewed and corrected the applicable Annunciator and Precautions, Limitation, and Setpoints Procedures. A spot check of other procedures found no discrepancies, and corrective action appears adequat. Annual Emergency Drill During the period December 14-15, 1981, the inspector participated in the preparation for, monitoring of, and critiquing of the Robinson emergency dril This portion of the inspection is documented in IE Inspection Report 50-261/81-2.
TMI Action Item Review TAP No. II.K.3.12, NUREG 0737. This item concerns the anticipatory reactor trip on turbine trip featur Review of the CP&L letter dated June 27, 1980 confirmed that the Robinson 2 anticipatory trip is in conformance with this item without modification. This item is closed.