IR 05000261/1990006
| ML14176A861 | |
| Person / Time | |
|---|---|
| Site: | Robinson |
| Issue date: | 04/16/1990 |
| From: | Breslau B, Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A860 | List: |
| References | |
| 50-261-90-06, 50-261-90-6, NUDOCS 9005030085 | |
| Download: ML14176A861 (10) | |
Text
RE UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 11 101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.: 50-261/90-06 Licensee:
Carolina Power and Light Company P.O. Box 1551 Raleigh, N Docket No.: 50-261 License No.: DPR-23 Facility Name: H. B. Robinson Inspection Conducted: April 2-5, 1990 Inspector: /
/
B. Breslau, Reactor Engineer
/Date Sign d Approved by:
,
114
'
P. K41
'
/ate Signed Operational ograms ection Operations ranch Division of Reactor Safety SUMMARY Scope:
This announced inspection was conducted as a follow-up to the Operational Safety Team Inspection (OSTI)
conducted July 10-28, 1989,
Inspection Report
N /89-1 The. scope of this inspection included review of four
Violations,
one unresolved item and 10 inspector follow-up items (IFI).
Additionally, four IFIs from inspection report 87-06, two IFIs from 87-17,
and two IFIs from 88-08 were reviewe Results:
The review of the previous inspection findings indicated adequate corrective
action had been completed for 16 of the 23 item Items discussed in
paragraphs 2.i.,n.,p.,s., and t. have not completed their corrective actions,
these items will be reviewed. in a future inspectio The item discussed in
paragraph 2.k. had insufficient corrective action. The licensee's corrective
actions had not commenced for one of the corrective actions discussed in
paragraph Also, the licensee failed to meet their commitment dates for
items in paragraph v. as well as paragraphs 2.j. and FrDR
gprIC<O
i(:U-
...
REPORT DETAILS
1. Persons Contacted
Licensee employees
S. Allen, Manager, Training
- C. Baucom, Senior Specialist, Regulatory Compliance
D. Bauer, Manager, Onsite QA
- S. Clark, Supervisor, Procurement Engineering
- C. Crawford, Manager, Corporate Nuclear Safety
- C. Dietz, Manager, Robinson Nuclear Project
- S. Griggs, Technical Aide, Regulatory Compliance
E. Harris,Jr.,Manager, Onsite Nuclear Safety
M. Heath, Engineering Supervisor, Modification Projects
J. Kloosterman, Director Regulatory Compliance
- A. McCauley, Principle Engineer, Offsite Nuclear Safety
P. Odem, Project Specialist, Maintenance
- M. Page, Manager, Technical Support
- R. Smith, Manager, Maintenance
- D. Stadler, Onsite Licensing Engineer
A. Wallace, Operations Coordinator
- H. Young, Manager, QA/QC
Other Licensee employees contacted included instructors, engineers,
technicians, operators, and office personne NRC Representatives
L. Garner, Senior Resident Inspector
- K. Jury, Resident Inspector
M. Thomas, Reactor Inspector, R-II
- Attended exit interview
Acronyms used throughout this report are listed in the last paragrap. Actions on Previous Inspection Findings (92701, 92702)
a. (Closed) VIO 261/87-06-01, the licensee failed to adequately establish,
implement and maintain procedures to carry out the dedicated shutdown
capability in the event of a fire in the control room. Subsequent NRC
follow-up inspection 87-17 noted that actions taken by the licensee to
correct deficiencies associated with Appendix R Dedicated shutdown
were insufficient. The NRC issued this violation in Proposed Civil
--
Penalty (EA 87-124).
- The licensee's response of December 17,
1987, categorically denied
each specific example cited in the NOV issued in the Proposed Civil
Penalt NRC Order dated August 17,
1988, rejected the licensee's
arguments and imposed the civil monetary penalt The licensee subsequently performed enhancements to the training
by revising the initial Licensed Operator and Licensed Operator
Requalification Training cycle to include DSP training. The first
phase of this training consisted of approximately eight hours of
classroom training followed by an examinatio All licensed shift
operators successfully passed an examination prior to assuming
watch at powe The second phase consisted of eight hours of in
plant walk-through and drill type testing, including an in-plant
walkdown of all DS equipment and components addressed by the DSP Additionally, the inspector noted operator communication capabilities
were enhanced by the installation of radio repeaters and that
approximately 18 emergency lighting units were installed to provide
adequate lighting to support D The inspector's review of these enhancements/procedure changes
coupled with interviews determined that adequate actions have been
accomplishe b. (Closed) IFI 261/87-06-19, Evaluation of additional licensee emergency
switchgear short circuit current studie The inspector reviewed the licensee's Master Fault Current Calculations,
Analysis NT107-E-33F. This document determined the maximum available
fault current at the emergency switchgear E-1 and E-2 and the MCC 5/6
for the various plant operating conditions. These calculations were
determining factors in the development of PM-1004 for DB-50 breakers
and the development of PM 939 for breaker replacement in MCC 5/ The establishment of the base line fault current calculations is
considered to have satisfactorily addressed this issu c. (Closed)
UNR 261/87-06-20, DB-50 Circuit Breakers are not properly
coordinated electrically and review the acceptability of using a
PRA in lieu of equipment changeou The inspector reviewed Plant Modification M-1004, Revision 0. This
modification is waiting final approval and is planned for implemen
tation during outage 13, scheduled to commence September 8, 199 The modification recommends installation of current limiting fuses
on the load side of the breaker terminals for each DB-50 breake The primary benefit is increased reliability from increased
interrupting rating Secondary benefits are improved distribution
system voltage regulation, wide range of acceptable system operating
voltages, and elimination of a personnel and equipment safety hazard:
In the event of a fault producing current in excess of the DB-50
breaker interrupting capability, the current limiters would open firs *
This will render the affected component inoperative until blown
limiters and faulted equipment are replaced. The inspector concluded
from this review that satisfactory actions are being taken to
address this concer d. (Closed)
IFI 261/87-06-21,
Review the licensee's update of MCC 5/6
Breaker Interrupting Capacity Evaluatio The inspector reviewed the licensee's breaker interrupting capacity
evaluation (Calculation Set RN107-E-41-F, dated 5/11/87).
The licensee's
evaluation determined that all breaker types presently in use in
MCC 5/6 have sufficient interrupting capability as long as changes to
the auxiliary electrical distribution system are controlled to ensure
available fault current does not increase above the rating of 17,000
amperes symmetrical and 19,159 asymmetrical until PCN 86-609/00 is
implemente This PCN was the basis for the development of PM-939
which subsequently replaced the existing breakers with Westinghouse
FD 3000 series breaker The licensee's letter dated December 5, 1988 informed NRR of the
above change NRR letter dated March 13, 1989, noted that the
new breakers provided a current interrupt rating of 25,000 amp NRR concluded that the replacement of the breakers to be an
acceptable resolution to the concerns raised in this issu Additionally, the inspector reviewed completed PM-939,
noting that
in addition to the replacement of the existing breakers, the new
overload relays have three heater elements
(one
per phase)
compared to two for the previous relay This modification is
considered to adequately address the concerns of this issu e. (Closed)
IFI 261/87-17-01, Ramification of changes to DSP-002,
Hot
Shutdown using the Dedicated/Alternate Shutdown system, providing
the option to feed DS bus from offsite power, if available, and
impact on Appendix R requirement The licensee's reevaluation of DSP-002 determined that no negative
ramifications existed due to the procedural changes institute The licensee concluded that the procedure increases the flexibility
to mitigate an Appendix R even The licensee's actions are
considered adequat (Closed)
IFI 261/87-17-02,
Implement additional short and long
term improvements in the areas of dedicated shutdown procedures,
training and communication The inspector determined from his review of the subsequent
adequate licensee actions taken to address item 2.a. above, which
included improving operator communication capabilities by the
installation of radio repeaters and the approximately 18 emergency
lighting units installed to provide adequate lighting to support
OS, also provides adequate disposition of this ite g. (Closed)
IFI
261/88-08-02,
Inform -operations personnel during
shift turnover of lessons learned from operational event The licensee revised Operations Management Manual Procedure OMM
001, Operations -
Conduct of Operation, Revision 1 The revision
incorporated the requirement in paragraph 5.7.5 to include real time
training to assure the shift operating crews are provided important
information in a timely manne This licensee action adequately
addresses this concer (Closed)
IFI 261/88-08-04, Review implementation of written RAIL
procedur The licensee implemented
Commitment Tracking Procedure RP-007,
Revision 0 on December 29, 198 The inspector's review concluded
that the procedure provided adequate instructions for documenting
and tracking commitment Additionally, discussions with
Regulatory Compliance personnel indicated a satisfactory knowledge
of the guidance provided by this procedur This item is
considered to be satisfactorily addresse i. (Open)
VIO 261/89-11-01, The licensee failed to establish measures
to adequately assure that indications of significant Auxiliary
Feed Water System deficiencies were evaluated and the deficiencies
corrected in a timely manne This violation was issued by
EA 89-188, November 15, 198 The licensee has established Operability Determination Guideline A formal proceduralized process for these determinations is
scheduled for implementation prior to unit startup from refueling
outage 1 Additionally, the licensee has implemented prioritization guidance
to PLP-026, Corrective Action Program and a Technical Support work
management program activities, which includes a formal process to
determine significance determination and root cause analysi This
work management process will be integrated with the Corrective Action
Program. The licensee committed to implementation of both of these
program activities to be completed by June 1, 1990, and application
of these practices on a site-wide basis by December 31, 199 The
adequacy of these programs will be reviewed after a reasonable time
has been allowed for maturation of management practice j. (Closed)
VIO 261/89-11-02,
Inadequate Instructions Were Provided
to Ensure Proper Torquing of Various System Closure Fastener In
Addition,
Independent Inspection or Verification of The Torquing
of Fasteners Was Not Provide The inspector reviewed a draft maintenance procedure, which the
licensee had failed to meet the committed implementation date of
April 2, 199 The
draft procedure provides general information,
specific responsibilities, and step-by-step instructions for
determining and achieving proper torqu Additionally, the inspector reviewed the licensee's on-going
maintenance procedure review program which is being utilized to
incorporate specific torque values and independent verification
requirement The inspector also reviewed several completed maintenance
procedures
and verified that adequate torquing requirements
were include The procedure upgrade is lagging behind the
projected expectations due to unforseen work requirement The
licensee does not expect to meet the current maintenance procedure
review completion date of December 31,
1990,
a request for an
extension to this commitment will be forthcomin Based on the inspectors review of the draft torquing procedure and
the review of updated maintenance procedures,
the inspector
determined that adequate administrative torquing guidelines were
being utilize k. (Open)
VIO 261/89-11-03,
The Licensee Made Changes to The Heat
Transfer Characteristics of The Component Cooling. Water System
Heat Exchangers Which are Described in The UFSAR,
by Plugging
Tubes in Both of The Heat Exchangers, without Accomplishing the
Required Safety Evaluatio The inspector reviewed the results of the licensee's CCW heat
transfer characteristics calculation The calculations indicated
that the predicted modeled conditions,
(200 tubes and 58 tubes
were assumed to be plugged in A and B HXs), yielded satisfactory
performance of the HX The licensee was able to obtain actual
temperature and flow rate data during a cooldown and performed
subsequent calculation, the results indicated that the actual
performance was nine percent better than the modeled calculation The licensee has revised procedure CM-201,
Safety Related Heat
Exchanger Maintenance, Revision The revision requires "Prior
to plugging tubes, notify System Engineer for plug mapping and
plug type".
The revision did not incorporate the requirement for
a safety evaluation as required by 10 CFR 50.59 prior to plugging
tubes in safety related HX The licensee's actions are
considered to be insufficient to prevent recurrence of a similar
situatio The licensee committed to revise CM-201 to reflect the
requirement for performing an engineering safety evaluation to
determine how many tubes may be plugged prior to the HXs becoming
degraded to a point where they fail to meet their design criteri. (Closed)
VIO 261/89-11-04,
Failure To use correct maintenance
procedure,
failure to record the "as
found"
and "as left"
positions as required by procedure,
and failure to torque valve
packing in accordance with vendor instruction The inspector reviewed documentation that indicated attendance by
Maintenance Planners, Maintenance
Foreman,
Mechanics,
and other
appropriate members of maintenance during a procedure adherence
review sessio The reviews stressed the importance of attention
to detail, procedure adherence, and communication A review of draft maintenance procedure CM-127,
Using The Chesterton Packing System, indicated that mechanics are
instructed to contact both the maintenance foreman and planner if
valve leakage continues after reaching 115 percent of nominal torqu This procedure also requires initiation of a work request for
115 percent of nominal torque is exceeded and the
valve is successfully teste The valve will be repacked at the
next appropriate opportunit The licensee failed to meet their commitment date for completion
of their corrective action However, the licensee's corrective
actions are considered to have adequately address this violatio m. (Closed) UNR 261/89-11-05, CCW Heat Exchanger Adequacy in
Performing Its Intended Design Function As noted in paragraph 2.k., The inspector noted from his review of
the results of the licensee's CCW heat transfer characteristics
calculations, that the actual performance was nine percent better
than the modeled calculation The modeled calculation determined
HX performance as not being degrade This item appears to be
adequately addressed
n. (Open)
IFI 261/89-11-06,
Independent Verification Procedure should
be improve The licensee's actions for incorporating enhancements to plant
procedure PLP-030, Independent Verification, have not been
completed., Completion commitment date is July 1, 199 o. (Closed)
IFI 261/89-11-07,
Freeze protection measures for RWST and
steam rupture ESF Detectors are inadequat The licensee has incorporated adequate guidelines for freeze
protection within the Auxiliary Operator logs,
(inside and
outside),
and the Hot Operations lo A review of Licensee
memorandum,
File No:
15507 requires I&C to ensure all freeze
protection panels are in service and operating as necessary when
the outside temperature is 32 degrees F or less. The inspector also
noted Freeze Protection was added to the Basic Systems trainin Also,
Freeze Protection training was included in the 1990
continuing training, which was completed March 199 Licensee's
actions are consider adequat p. (Open) IFI 261/89-11-08, Annunciator Panel Procedure Weaknesse The licensee's APP system upgrade project is scheduled to be
complete prior to startup from Refueling Outage 1 Adequacy of
this project will be reviewed during a future inspectio (Closed) IFI
261/89-11-09,
Weakness
in loop Calibration of
Feedwater RTD Used in Calorimetri The inspector reviewed licensee memorandum, file no: 13510E, Dated
March 30, 199 The memorandum indicated that feedwater RTDs are
supplied by the vendor with both a specific and a generic
calibration curve. Site personnel cannot "Calibrate" an RT It
is I&C personnel's responsibility to install the RTDs,
provide RTD
curves to the site computer group so that the computer points are
adjusted to the vendor-supplied curve (Closed)
IFI 261/89-11-10,
Deficiencies were noted in Component
Cooling Water walkdow The inspector verified that the components identified as not being
properly labeled were corrected,
overranged pressure indicator,
PI-6623 was replaced with a new calibrated gauge, and
Nonconformance
report 89/036 associated with the improperly
positioned
root
isolation
valve, CC-851C, was
properly
dispositione The inspector also verified that drawing changes
were initiated for the identified discrepancie The inspector
considers the licensee's actions adequately addresses these
concern s. (Open)
261/89-11-11,
Lack of a time limit for incorporation or
evaluation of comments made in plant procedure two year revie The licensee has not completed their corrective actions,
completion is scheduled for August 31, 199 (Open)
261/89-11-12,
Weakness in operations corrective action
progra The licensee has not completed its corrective actions, completion
is scheduled for September 1,199 u. (Closed)
IFI 261/89-11-13,
Timeliness of operability review of
problems discovered in the DB The licensee's further review of this issue, noted in their
response of October 16,
1989, determined that in each case of an
-
~
item entered into the Discrepancy Resolution Program only three
issues resulted that impacted operabilit In each case the
initial review resulted in an escalation of effort within the
Discrepancy Resolution
Program concluding with a timely
notification of managemen In no case had impacts on operability resulted from the detailed
reviews that were completed several months after identification of
the potential discrepanc The licensee has determined that no basis exists to change the
program as it is presently structure This item is consider to
be adequately addresse v
(Open) IFI 261/89-11-14, Review implementation of MOD-18,
Revision 4 and MOD-13, Revision 5 in temporary modification progra The
inspector
reviewed
MOD-18, Temporary Modifications,
Revision 3, Approved February 28, 199 The procedure appears to
adequately address the weaknesses noted in the past performance of
the temporary modification progra However, this procedure has
been implemented for only one week, insufficient time has elapsed
to determine adequacy of the revise progra The adequacy will be
reviewed in a future inspectio Additionally, the licensee committed to evaluate and standardize
the safety review process at CP&L's nuclear site Following
completion of this evaluation, a site-specific procedure would be
implemented by March 2, 1990, for performance of 10 CFR 50.59
safety review At the time of this inspection, the licensee had
not started the evaluation proces The procedure upgrade was
scheduled to commence on March 15,
1990, the revised due date for
implementation of the site-specific procedure is June 15,
199 The licensee's corrective actions will be reviewed during a future
inspectio w. (Closed)
IFI 261/89-11-15, Validation of critical design parameter
in DB The licensee's response of October 16,
1989,
provided further
clarification to this issue as well as paragraph 2.u abov The
licensee determined that the program is adequately structured and
that there are no current plans to change the existing progra The inspector considers this item to be adequately addresse. Exit Interview
An exit interview was conducted on April 5, 1990, with those persons
indicated in paragraph 1 abov The inspectors described the areas
inspected and discussed in detail the inspection result Proprietary
information is not contained in this repor Dissenting comments were
not received from the license. Acronyms
APP
Annunciator Panel Procedure
Component Cooling Water
CFR
Code of Federal Regulations
p
Engineering Safety Feature
Design Basis Document
DS
Dedicated Shutdown
DSP
Dedicated Shutdown Procedure
Enforcement Action
Heat Exchanger
Instrumentation & Calibration
IFI
Inspector Follow-up Item
IV
Independent Verification
Motor Control Center
Net Positive Suction Head
NRC
Nuclear Regulatory Commission
Nuclear Reactor Regulation
OMM
Operation Maintenance Manual
OSTI
Operational Safety Team Inspection
Plant Change Notice
Probabilistic Risk Analysis
Quality Assurance
Quality Control
RAIL
Regulatory Action Item List
Regulatory Procedure
Reactor Water Storage Tank
Resistance Temperature Detector
Updated Final Safety Analysis Report
Unresolved Item
vIo
Violation