IR 05000261/1990006

Operational Safety Team Insp Rept 50-261/90-06 on 900402-05. No Violations Noted.Major Areas Inspected:Review of Four Violations,One Unresolved Item & Ten Inspector Followup Items

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: IR 05000261/1990006
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,

Valve Packing

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

valve packing if

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

AFW

Auxiliary Feed Water

APP

Annunciator Panel Procedure

CCW

Component Cooling Water

CFR

Code of Federal Regulations

p

ESF

Engineering Safety Feature

DBD

Design Basis Document

DS

Dedicated Shutdown

DSP

Dedicated Shutdown Procedure

EA

Enforcement Action

HX

Heat Exchanger

I&C

Instrumentation & Calibration

IFI

Inspector Follow-up Item

IV

Independent Verification

MCC

Motor Control Center

NPSH

Net Positive Suction Head

NRC

Nuclear Regulatory Commission

NRR

Nuclear Reactor Regulation

OMM

Operation Maintenance Manual

OSTI

Operational Safety Team Inspection

PCN

Plant Change Notice

PRA

Probabilistic Risk Analysis

QA

Quality Assurance

QC

Quality Control

RAIL

Regulatory Action Item List

RP

Regulatory Procedure

RWST

Reactor Water Storage Tank

RTD

Resistance Temperature Detector

UFSAR

Updated Final Safety Analysis Report

UNR

Unresolved Item

vIo

Violation