IR 05000261/1982014
| ML20054H009 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 05/25/1982 |
| From: | Burger C, Weise S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20054H001 | List: |
| References | |
| 50-261-82-14, NUDOCS 8206220489 | |
| Download: ML20054H009 (10) | |
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g"49 UNITED STATES g
k NUCLEAR REGULATORY COMMISSION
g REGION 11 5,_
- y 101 MARif TT A ST., N.W.. SUITE 3100 g
g ATLANTA, GEORGIA 30303
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Report No. 50-261/82-14 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 inspector at H. B. Robin n Unit 2 near Hartsville, South Carolina S.Teise[
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JQf M INSPECTOR:
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teSigned C.Ju/g'e[,Section
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and Resident Pro ams SUMMARY Inspection on April 11 - May 10,1982 Areas Inspected This routine, announced inspection involved 131 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 Notice followup, violation followup, and local leakrate testing and training.
Results Of the 15 areas inspected, no violations or deviations were identified in 15 areas.
8206220489 820526 PDR ADOCK 05000261
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DETAILS 1.
Persons Contacted Licensee Employees
- R. B. Starkey, Plant General Manager J. Curley, Manager Technical Support F. Gilman, Senior Specialist, Regulatory Compliance F. Lowery, Unit 2 Operations Supervisor
- W. Crawford, Manager, Operations and Maintenance R. Chambers, Unit 2 Maintenance Supervisor
- C. Wright, Specialist, Regulatory Compliance S. Crocker, Manager, Environmental and Radiation Control W. Blaisdell, Senior Specialist. Training W. Flanagan, Project Engineer
- D. Baur, Project QA/QC Specialist Other licensee employees contacted included technicians, operators, mechanics, security force members, and office personnel.
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on May 7,1982, with those persons indicated in paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings (Closed) Severity Level V Violation 81-15-04.
This item concerned the licensee's failure to test several containment isolation valves.
The inspector reviewed the CP&L response to the violation dated June 26, 1981.
Licensee Event Report 81-13 Revision 1, and Periodic Test 2.6 Revision 10, the licensee's corrective actions have been completed as committed and appear adequate.
(Closed) Deviation 81-15-06. This item concerns the licensee's failure to conduct a annual system integrity test.
The inspector reviewed the licensee's response dated June 26, 1981.
Corrective actions have been completed as described and appear adequate.
Additionally, Technical Specification 4.17 now requires this testing on a refueling periodicity.
(Closed) Severity Level IV Violation 81-19-03.
This item concerned the failure to adequately review and report safety concerns associated with
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radioactive waste processing equipment, Modification-383.
The inspector reviewed the licensee's response dated August 21, 1981, Modification Control Prc;edures ENG-5, the 1981 Annual Report on changes to the facility, Safety
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Analysis dated February 4,1982, and Safety Analysis dated March 30, 1982.
The inspector also toured the equipment outside the auxiliary building for conformance to licensee controls.
The modification and the effects of ruptures of one and three waste condensate tanks (WCT) have been evaluated for their safety impact and found not to involve an unreviewed safety question. These analyses calculated maximum allowable activity concentra-tions for nuclides of interest in radioactive waste water. While this is adequate for the modification safety review, it does not address the potential ef fects of transferring raw waste to the WCT's in question. Prior to transferring such waste water, a safety analysis will be necessary which accounts for actual nuclide concentrations with respect to the calculated maximums. The 1981 Annual Report reported Modification-383 to the Commis-sion along with other modifications which had been placed in service but not reported. The modification procedures have been revised.
Attachment 5 to ENG 5.4 requires that the personnel responsible for reporting be informed af ter the modification turnover review has been conducted. Licensee correc-tive action appeared complete and adequate, and the inspector had no further questions.
(Closed) Severity Level V Violation 82-07-01.
This item concerns the licensee's failure to conduct surveillance on the refueling water storage tank outlet valves.
The inspector reviewed the licensee's response dated April 30, 1982, Periodic Test 2.13, and the applicable General Procedures.
Corrective action is as stated and appears adequate.
(Open) Severity Level V Violation 82-07-02. This item concernt valve lineup deficiencies on the Containment Integrated Leak Rate Test (L:
T ).
The inspector reviewed the licensee's response dated April 30, i382, and Administrative Instruction (AI) Section 5.11.
One of the root causes of this violation was the fact that the CILRT valve lineups did not require individual signoffs for each action required.
AI Section 5.11 does not require that valve checkof f lists be written with individual signoff and, therefore, the corrective action to prevent recurrence is inadequate.
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l Licensee representatives committed to changing AI Section 5 to incorporate
this specific guidance on valve checkoff sheets. This item will remain open
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until these changes are approved.
4.
Unresolved Items Unresolved items are matters about which more information is required to i
determine whether they are acceptable or may involve violations or devia-l tions. New unresolved items identified during this inspection are discussed in paragraph 12, 5.
Plant Tour The inspector conducted plant tours periodically during the inspection
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interval to verify that monitoring equipment was recording as required, j
equipment was properly tagged, operations personnel were aware of plant l
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conditions, and plant housekeeping ef forts 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 perf ormed major flowpath valve lineup verifications and system status checks on the following systems:
a.
Spent fuel pit cooling system and temporary fire water cooling water supply b.
Emergency diesel generators c.
Portions of radioactive liquid waste processing system 6.
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 the organization 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 followed.
7.
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 happened.
8.
Plant Operations Review a.
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 alertness and demeanor during plant tours.
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 j
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security remained at an acceptable level.
Shift turnovers were -
observed tc ify that they were conducted in accordance with approved licensee procedures.
b.
On April 24, 1982, with the plant in cold shutdown and defueled, operators commenced a release of 'C' Waste Condensate Tank (WCT).
An alarm was received on the liquid waste radiation monitor which automatically termingted the release.
About 115 gallons of wager containing 8.6 X 10- micro Ci/ml gross activity and 2.6 X 10- micro Ci/ml tritium were released at a rate of about 20 gpm.
For this activity, the release was below ttm limits of 10 CFR 20 Appendix B.
Investigation revealed that a laboratory technician apparently counted a 'C' steam generator sample in lieu of the 'C' WCT sample, which resulted in a gross activity reading 1000 X to low.
The error appears to be human, vite procedural, and was of no safety significance to the enviroment.
frirough discussions with licensee management, the inspector deteratined that corrective action to prevent recurrence includes writing of a Plant Operating Experience Report for circulation to the plant ;taff, trairiing on this event with all laboratory tech-nicians, and modification to the computer program associated with the counting system to require technicians to remove the counted sample and re-verify its identity.
Corrective actions appear adequate and the inspector had no further questions.
9.
iiodification for Lockout of Critical Emergency Core Cooling System (ECCS)
Valves The inspector reviewed liodification-469 for ECCS valve lockout. This modification installed permissive switches in the control circuits of nine critical ECCS valves which are required for post accident transition from the safety injection phase to the recirculation phase. Additionally, the modification was to return valve control to the control room and provided redundant, independent valve position indication.
The inspector reviewed the modification for consistency with requirements set forth by NRR in letters dated November 18, 1975 and itarch 9, 1981 and in Technical Specification Amendment 64.
The inspector reviewed the licensee's implementation procedure, post-modification testing, and attendant plant procedure changes.
Additionally, portions of the installed system were inspected.
The system appeared to be installed as designed and approved, however, one potential deficiency was noted. With the valve breaker shut and control power removed, indication of valve position is available at two places on the control board.
If the breaker trips or is opened, all indication is lost since the valve position status lights go out and the ECCS Vital Valve Status will always show the valve in the ECCS initiation
position. Technical Specification 4.5.2.7 requires that these valves be verified in their proper position (from control room indication) every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when above 1000 psi. With the above design, the operator could be misled that a valve was in the proper position when, in fact, it was not.
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Additionally, surveillance and general procedure changes to accompany the modification were still under plant staff review. Resolution of this design problem and review of necessary procedural changes or additions constitute an open item (50-261/82-14-01).
Changes to Emergency Instruction-1 were reviewed and appeared adequate.
10.
Degraded Reactor Coolant Pump (RCP) Bolts On April 23, 1982 the licensee made a prompt notification to the NRC concerning the f ailure and degradation of RCP diffuser adapter to casing adapter Dolts. This notification was pursuant to both Technical Specifi-cations and 10 CFR 21. During disassembly of the 'B' RCP for the ten year inservice inspection, four of the sixteen 304S5 bolts fractured and seven were degraded. The bolts were sent to the licensee's metallurgy laboratory where it was determined that the bolt cracking was caused by chloride stress corrosiion. Several hundred ppm chloride were found on the degraded bolts.
Due to concern that the stress corrosion problem could af fect the other RCP's, the NRC issued a confirmation of action letter to CP&L on April 26, 1982.
This letter confirms CP&L's decision to inspect at least one additional reactor coolant pump for degradation.
CP&L LER 82-04 provides additional information on the bolt degradation and plan of action. Resolu-tion of the issue is mandatory prior to plant startup.
11.
Reactor Vessel In-Service Inspection (ISI) Indications a.
Ultrasonic testing (UT) on April 9, 1982, during the unit's ten year ISI, indicated two possible irregularities near or on the outside surface of the pressure vessel.
The indications are located in the plate material below the lower beltline weld about 100 degrees apart.
Westinghouse Corporation performed the pressure vessel inspection and analyzed the test data.
Additional research of the vessel was conducted by the vessel manufacturer, Combustion Engineering, and Southwest Research Institute, performer of the preoperational baseline inspection. Af ter data reduction, CP&L made a presentation to NRR and I&E on April 30, 1982.
this presentation concluded that the indica-tions were located on or very near the outside surface of the vessel, were probably made during the manufacturing or handling process, occurred in the outer surf ace of a vessel that was about one inch thicker than ASME Code requirements, and were of a size not requiring analysis in accordance with the ASME Code. These presentations and the conclusion that further investigation was unnecessary was acceptable to the NRC.
b.
On April 24, 1982, Combustion Engineering and Westinghouse determined that the drawing used for the UT of the intermediate shell vertical welds was incorrect by about 15 degrees. CP&L intends to reinspect the intermediate shell vertical welds during the refueling outage.
A report pursuant to 10 CFR 21 on the drawing error was forwarded to the NRC on April 29, 1982. The inspector reviewed the 10 CFR 21 report for
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adequacy of reporting in a timely. informative manner and whether corrective actions taken or planned appear adequate. Through discus-sions with licensee personnel, the inspector determined that in addition to the corrective action stated in the report, CP&L will update the affected drawings.
c.
As a result of the NRC Task Force on Pressurized Thermal Shock (PTS)
report dated April 20, 1982, the inspector is monitoring licensee corrective actions. These actions included specialized training on the PTS issue and appropriate revision to procedures.
The training has been started but not completed.
12.
High Employee Thermoluminescent Dosimeter (TLD) Readings On April 16, 1982, a routine reading of a contractor health physics technician's TLD indicated an exposure of 6.6 Rem. Backup pocket dosimeter readings for the period April 1 to 16 indicated an exposure of 265 mrem.
The discrepancy in the readings was originally thought to result from pre-irradiation of the TI O for calibration purposes.
On April 19, the licensee determined that the TLD had been annealed prior to issuance to the employee.
The licensee is continuing to investigate this occurrence in l
order to establish the individual's actual dose.
A review of this investigation will be conducted upon completion. The licensee committed to not allow the individual into a radiation area without prior NRC concur-rence. This item is unresolved pending further investigation and receipt of the licensee's special report on the incident. (50-261/82-14-02).
13. Refueling Maintenance This inspection required verification that major maintenance activities scheduled during the outage were conducted in accordance with approved procedures.
The inspector reviewed associated maintenance work requests, applicable Maintenance Instructions, local clearance and test requests ( LCTR), Administrative Instructions, and applicable quality assurance procedures.
The following maintenance was inspected and periodic obser-vations of work made:
a.
Residual Heat Removal (RHR) Heat Exchanger (HX) hot spot removal and primary side gasket refurbishment.
The inspector reviewed Special Procedure-409 and observed the naintenance and radiological control activities involved in cutting out a greater than 1000 Rem / hour hot snot in the drain piping of 'B' RHR HX. Equipment and personnel were well coordinated for the evolution and ALARA concerns were satisfied through use of a dry run, a personnel pre-briefing, and extensive preparation and coverage by health physics personnel. The licensee has stored the removed drain piping for investigation of the apparent high activity beta source. Gasket refurbishment was conducted in accordance with maintenance Instruction-10 Procedure 18. Problems with high
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airborne activity were combated with ventilation suction on the RHR HX room and the use of a special vacuum and filter arrangement.
The inspector verified that adequate controls existed for control of system removal from and return to service, quality assurance inspections, post-maintenance testing, housekeeping, and personnel qualification.
b.
Steam Generator Eddy Current Inspection and Tube Plugging.
The inspector reviewed the appropriate Special Procedures which incorporated plant approved Westinghouse procedures. These procedures appeared adequate to control maintenance activity and addressed quality assurance inspections and hold points, post-maintenance testing, cleanliness, and tool control.
Details of the results of this inspection will be provided in LER 82-05 and in a special report to the NRC.
Removal of the steam generators from service and return to service were accomplished in accordance with approved plant procedures.
The inspector noted no violations or deviations.
14.
Type B and C Local Leak Rate Testing (LLRT)
The inspector reviewed licensee procedures for the following LLRT's:
a.
Periodic Test (PT) 16.3 - Manometer line b.
PT 16.4 - Personnel access hatch (airlocks)
c.
PT 51 - Post-accident containment air sampling system.
These procedures appeared adequate to conduct testing, although PT 51 required several field changes to be adequately run and also initiated an inadvertent safety injection (SI) on April 26, 1982.
Due to plant conditions, the event had no safety significance.
It did point up a deficient shif t turnover in that the on-shif t operators were unaware that PT 51 was being run and that it was responsible for the SI.
The inspector independently verified portions of the valve lineups for the LLRTs, observed the testing, and reviewed test results for cnnformance to Technical Specifications.
All LLRT results were acceptable and no maintenance was required.
The inspector has one concern on the LLRT program. The firewater lines to containment presently are not covered by the LLRT program.
These lines automatically isolate on containment isolation and do not have a seal water system.
CP&L maintains that the firewater pressure of about 125 psig qualifies as a water seal.
From discussions with licensee personnel, it appears that firewater supply piping that passes through the turbine building is not seismically qualified and cannot be relied on.
An LLRT on the two penetrations appears to be required by appendix J to 10 CFR 50.
This item is open pending resolution. (50-261/82-14-03)
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Training The inspector attended several training /requalification L training sessions for licensed personnel and those seeking licenses.
Of the training observed, lesson plan objectives and program schedule and objectives appeared to be met. Discussions with licensee and contractor personnel and review of training records indicated that training was being performed in a timely manner in the areas of radiological health and safety, security, emergency plar, and fire fighting.
The inspector noted no violations or -
deviations.
16.
Review of IE Notices The inspector verified that IE Notices had been received onsite and reviewed by cognizant licensee personnel.
Selected applicable IE Notices were discussed with licensee personnel to ascertain the licensees actions on these items. The inspector also verified that IE Notices were reviewed by the Plant Nuclear Safety Committee in accordance with facility administra-tive policy. Licensee action on the following IE notices were reviewed by the inspector and are closed.
IE Notices 81-27 82-06 17.
Outstanding Items Review (Closed) Inspector Followup Item 81-22-06.
This item concerned the licensee's lack of a procedure for calibration of the auxiliary feedwate.'
flow indication system.
The inspector reviewed Periodic Test-22.3, the refueling interval component test for this system. This procedure appears adequate to meet the TMI Action Plan requirements.
(Closed) Inspector Followup Item 82-04-11. This item concerned the need to
ensure post-accident containment sample valves are opened prior to entering t
the recirculation mode during an accident.
Revision 30 to Emergency
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(Closed) Open item 81-12-03.
This item concerned systems which the inspector considered in need of independent verification, as defined in TMI Action Plan I.C.6.
the licensee has completed his review, and the inspector reviewed the present status of his concerns:
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a.
Diesel Generators - The licensee has revised Operating Procedure j
(0P)-7A and 7B and Section 7 of the Operating Work Procedures (OWP) to
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require independent verification.
Standing Order-9 Section 1.3.1.2.-
(7), however, does not require independent verification on OWP's which
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must be developed for work not covered by standing OWP' e g
b.
Boric Acid Tanks, Transfer Pumps, and Filter - The 0WP's for this equipment have been revised to require independent verification.
The above comment on Standing Order-9 Section 1.2.1.2(7) is applicable.
c.
Low Temperature Overpressure Protection (LTOPP) - The licensee's position has not changed.
d.
Standing Order-9 - With the exception of items a and b above, Section 1.3.1.2(7) corrected this.
Discussions with the Operating Supervisor indicated that the oversights in Standing Order-9 would be reviewed and corrected.
The inspector is satisfied that his concerns have been addressed.
In the case of LTOPP, sufficient additional equipment and controls exist which should ensure system operability.
(Closed) Inspector followup item 81-22-05.
The licensee has rebuilt and strengthened much of the containment access hatch operating mechanism and has refurbished the door seals. Door maintenance and use of trained hatch operators appears to be adequate corrective action to prevent breach of containment integrity.
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