IR 05000261/1991022
| ML14178A153 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/08/1991 |
| From: | Crlenjak R, King L, Mellen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A152 | List: |
| References | |
| 50-261-91-22, NUDOCS 9110290188 | |
| Download: ML14178A153 (9) | |
Text
0- tUNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report No.:
50-261/91-22 Licensee:
Carolina Power and Light P.O. Box 1551 Raleigh, NC 27602 Docket No.-:
50-261 License No.:
DPR-23 Facility Name:
H. B. Robinson Inspection Conducted:
September 30 -
October 4, 1991 Inspectors:
1J. Melle, Reactor Inspector Date Signed c
King, Reactor Inspector Date Signed Approved by:
Crle ja,Secti Chief Daee igned Operational Program Section Operations Branch Division of Reactor Safety SUMMARY Scope:
This was a routine announced inspection in the area of Emergency Operating Procedure and Abnormal Operating Procedure followu The inspectors reviewed the licensee's program for the upgrade of Emergency and Abnormal Operating Procedure Additionally, the inspectors reviewed the licensee's resolution of the Auxiliary Feedwater net positive suction head inadequacie Results:
The inspectors found that the licensee had progressed slowly in the incorporation of comments from the NRC Emergency Operating Procedure audit.- The draft charter for the Emergency Operating Procedure upgrade was adequate to ensure that the upgraded Emergency Operating Procedures would cover the broad range of accidents and equipment failures necessary for safe shutdown of the plan The licensee had adequately addressed and corrected the previously identified Auxiliary Feedwater net positive suction head deficiencie PDR ADOCK 05000261 G
REPORT DETAILS Persons Contacted B. Beverage, Manager of Quality Control B. Biggs, Manager -
Nuclear Engineering Department
- S. Billings, Technical Aide -
Regulatory Compliance
- R. Chambers, Plant General Manager W. Dorman, Nuclear Assurance I
W. Flanagan, Manager of Operations W. Gainey, Manager of Plant Support
- J. Kloosterman, Manager of Regulatory Compliance J. Lane, System Engineer C. Moon, Project Engineer J. Palmer, Procedure Engineer
- R. Wallace, Acting Manager of Operations Other licensee employees contacted included instructors, engineers, mechanics, technicians, operators, and office personne NRC Representatives
- L. Garner, Senior Resident Inspector
- K. Jury, Resident Inspector
- Attended Exit Interview A listing of abbreviations used in this report is contained in Appendix.
Review of Emergency Operating Procedures Program The inspectors discussed the licensee's implementation of the emergency operating procedure program with plant staff. The inspectors reviewed the draft charter for the emergency operating procedure progra The charter contained the requirements for the Plant Specific Technical Guidelines, Writer's Guide, Writer's Standard, Emergency Operating Procedure User's Guide, Emergency Operating Procedure Basis Document, Emergency Operating Procedure Training Packages, Verification and Validation, and Emergency Operating Procedure Maintenance Progra The draft document contained sufficient requirements to ensure the program could be effectively implemente The implementation of the Eidergency Operating Procedure program will be reviewed after the Emergency Operating Procedure upgrades are complete This is identified as part of IFI 50-261/91-22-01: Review of completed Emergency and Abnormal Operating Procedure upgrade progra.
Management Control of Emergency Operating Procedures The inspectors discussed the schedule for completion of the Emergency Operating Procedure and Abnormal Operating Procedure upgrades with various members of the plant staf The programs that had been started appeared as though they would accomplish the required task However, the limited resources that the licensee had in place were not appropriate for the level of effort required to accomplish the tasks in a reasonable time fram The inspectors discussed this with plant management. The licensee is reviewing their allocation of resources for these tasks and will provide the particulars in a letter to Region II detailing work force requirements and a realistic end date for the projec The licensee stated that this letter would be submitted prior to the end of December 199.
Follow-up on Previous Inspection Findings (91702) (Closed)
VIO 50-261/89-11-01: Auxiliary Feedwater System Inoperable Due to Inadequate Net Positive Suction Hea The inspectors reviewed and inspected the piping changes made to the suction piping of the auxiliary feedwater pumps and determined that adequate NPSH was available when three pumps were runnin The surveillance procedures were reviewed to ensure that testing had been done to demonstrate that adequate NPSH was available during three pump operatio The inspectors reviewed the results of the test run on August 22, 1989, to gather data on the suction piping head losse The data indicated that prior to piping modifications a loss of steam driven auxiliary feedwater pump NPSH would have occurred at a condensate storage tank level of 7 percen This was substantially above the technical specification minimum condensate storage tank level of about 16 percen The auxiliary feedwater pump could not have delivered the required flow with the condensate storage tank at the Technical Specification minimum leve The licensee increased the size of the Auxiliary Feedwater suction side piping from 6 inches to 12 inches to correct identified NPSH inadequacie Modification acceptance test procedure AT-2 was performed after the licensee increased the suction piping siz Auxiliary Feedwater Water system flow rates and suction piping pressure drops were measured and compared to calculated pressure drops at the same flow rates to verify the validity of the suction piping system analytical mode A comparison of available NPSH based on the field data to required NPSH from the vendor pump curve at full-flow
conditions for each motor-driven pump individually and both pumps combined was performe The inspectors reviewed the results of the test and determined that adequate NPSH was available to support three pump operation. This item is close (Closed) IFI 50-261/89-16-01:
Develop a New Plant Specific Technical Guidelin The first revision of the Plant Specific Technical Guideline had been completed; however, because of the extensive procedural changes that were scheduled for the Emergency Operating Procedures it appeared likely that the Plant Specific Technical Guideline would require some revision The inspectors discussed the Plant Specific Technical. Guidelines with the Emergency Operating Procedure Writers and reviewed the current revision of the guideline The implementation of the Plant Specific Technical Guidelines and subsequent revisions will be reviewed when the Emergency Operating Procedure revisions are complete This is identified as part of IFI 50-261/91-22-01: Review of completed Emergency and Abnormal Operating Procedure upgrade progra (Closed)
IFI 50-261/89-16-02:
Develop an Abnormal Operating Procedure Writer's Guid The inspectors reviewed OMM-040, Writer's Standard For Operations Procedures, Revision 0, dated July 30, 199 This was a new procedure that supplemented the Writer's Guide For the Development and Revision of Single Column Format Procedures, OMM-042. OMM-042 required the use of OMM-040. OMM-041,. Writer's Guide For the Development and Revision of Flowpath and Two Column Format Procedures followed the development of OMM-040 and had some redundant materia The licensee stated that OMM-041 would be revised to delete the redundant material. The inspectors discussed the need for having both OMM-041 and OMM-042 and were told by the licensee that the decision was made to create two procedures because of the use of the single column format for Abnormal Operating Procedures. The licensee stated that they are planning to review the interface between single and dual column emergency procedures to ensure that transition back and forth between single and dual column procedures would not cause unnecessary operator confusio The implementation of the Writer's Standard and the two Writer's Guides will be reviewed when the Emergency Operating Procedure Upgrades are complete This is identified as part of IFI 50-261/91-22-01:
Review of completed Emergency and Abnormal Operating Procedure upgrade progra (Closed)
IFI 50-261/89-16-03:
Review Each Appendix D Ite The inspectors discussed the disposition of the nomenclature and labelling discrepancies noted in Appendix D of NRC Inspection Report 50-261/89-1 The licensee stated that a labelling upgrade program had recently been forme The inspectors discussed Emergency Operating Procedure and Abnormal -Operating Procedure nomenclature and labelling upgrades with staff engineer The licensee described the proposed labelling program and the corresponding procedure nomenclature change The proposed program for incorporating this nomenclature was adequat This will be reviewed when the Emergency Operating Procedures and Abnormal Operating Procedures upgrade program is complete. This is identified as part of IFI 50-261/91-22-01: Review of completed Emergency and Abnormal Operating Procedure upgrade progra (Closed) IFI 50-261/89-16-04: Review Each Appendix B Ite The inspectors discussed the disposition of the Human Factors and Technical comments listed in Appendix B of NRC Inspection Report 50-261/89-1 The licensee described their program and showed the inspectors some draft examples of Functional Restoration Procedures that had comments incorporate Based on this sample the proposed program for incorporating these comments was adequat The incorporation -of the balance of the Appendix B comments will be reviewed when the Emergency Operating Procedures and Abnormal Operating Procedures upgrade program is complete. This is identified as part of IFI 50-261/91-22-01: Review of completed Emergency and Abnormal Operating Procedure upgrade progra (Closed) IFI 50-261/89-16-05:
Review Each Appendix C Ite a The inspectors discussed the disposition of the Writer's Guide comments listed in Appendix C of NRC Inspection Report 50-261/89-1 The inspectors also reviewed OMM-041, Writer's Guide For the Development and Revision of Flowpath and Two Column Format Procedures, Revision 0, dated March 30, 199 OMM-041 replaced OMM-013 and was expanded to comply with NUREG-0899, Guidelines for the Preparation of Emergency Operating Procedures. OMM-041 corrected most of the deficiencies noted in NRC Inspection Report 50-261/89-16; however, the action verb list still did not define some critical terms such as Faulted, Intact, Ruptured, Running, and Contac The licensee stated that they would review the action verb
list to ensure it accurately defined all critical action verb Some other Appendix C items had not yet been adequately dispositioned. Examples of these are:
Placekeeping methods for procedure transition or skipped steps had not been identifie The licensee stated that these would be defined in the next revision of OMM-022, Emergency Operating Procedure User's Guid The "WHEN condition, THEN action" sequences had not been addresse The licensee stated that this probably would be addressed in the next revision of OMM-040, Writer's Standard For Operations Procedure Most Appendix C items were adequately covere Some specific examples are:
Acronyms were referenced by the Writer's Guide and listed in Engineering Design Guide. 3-05, Revision The inspectors reviewed The design guide and noted that all acronyms identified as missing from the previous report were contained within the design guide. Additionally, a sampling of acronyms from other Emergency Operating Procedures were contained in the design guid Type style, type size and margins were designated in the writer's guide, but implemented through the use of VE-PROMS. The inspectors discussed the use of the VE-PROMS system with engineering personnel and determined the process would provide the required uniformit The implementation of the Writer's Guide and the balance of the unincorporated comments will be reviewed when the Emergency Operating Procedures revisions are complete This is identified as part of IFI 50-261/91-22-01: Review of completed Emergency and Abnormal Operating Procedure upgrade progra (Closed) IFI 50-261/89-16-06: Correct Verification and Validation Deficiencie The Verification and Validation process could not begin until the first set of Emergency Operating Procedure or Abnormal Operating Procedures were complete The inspectors discussed Verification and Validation methodology with the Emergency Operating Procedure writer
and determined that the proposed method of Verification and Validation would be adequat Additionally, the inspectors reviewed OMM-043, Verification and Validation, Revision 0, dated December 28, 199 This procedure delineated the details of the Verification and Validation progra The program described in the procedure will produce an acceptable verification and validation produc This will be reviewed when the Emergency Operating Procedures and Abnormal Operating Procedures have been completed. This is identified as part of IFI 50-261/91-22-01:
Review of completed Emergency and Abnormal Operating Procedure upgrade progra (Closed)
IFI 50-261/89-16-07:
Review Memorization of Operator Immediate Action This item involved a deviation from Emergency Response Guideline background document-regarding the memorization of the immediate action step The inspectors discussed this deviation with the license The inspectors were informed that the licensee had reconsidered their objection to memorization of "those actions which the operator should be able to perform before opening and reading his emergency procedure."
The licensee revised operator training to require the memorization of actions that the operator should be able to perform before opening and reading his emergency procedur The revised training was consistent with the Emergency Response
-
Guideline The inspectors interviewed selected
operators and determined that the level of retained operator knowledge of immediate action steps may not be consistent with the Emergency Response Guidelines. The licensee stated that they would review this area to ensure that operators can perform the required immediate actions prior to referring to procedure The inspectors will review this when the Emergency Operating Procedure upgrade program is complete This is identified as part of IFI 50-261/91-22-01: Review of completed Emergency and Abnormal Operating Procedure upgrade progra (Closed) Plant Examination Report 50-261/91-300, Item 3.h: AOP-16, Excessive Plant Leakage, Step 3.1.4 required Safety Injection prior to reactor plant trip when leakage exceeded Reactor Coolant System makeup capabilit The inspectors. reviewed Abnormal Operating Procedure AOP-16, Revision The procedure had been rewritten and step 4 had been revised to require a reactor trip prior to entry into PATH-1 and subsequent Safety Injectio This item is close *
7 Exit Interview The inspection scope and findings were summarized on October 4, 1991, with those persons indicated in paragraph The NRC described the.areas inspected and discussed in detail the inspection findings. No proprietary material is contained in this repor No dissenting comments were received from the license Item Number Status Description IFI 50-261/91-22-01 Open Review of completed Emergency and Abnormal Operating Procedure upgrade progra IFI 50-261/89-11-01 Closed Auxiliary Feedwater System Inoperable Due to Inadequate *Net Positive Suction Hea IFI 50-261/89-16-01 Closed Develop a
New Plant Specific Technical Guideline IFI 50-261/89-16-04 Closed Develop an Abnormal Operating Procedure Writer's Guid IFI 50-261/89-16-03 Closed Review Each Appendix D Ite IFI 50-261/89-16-04 Closed Review Each Appendix B Ite IFI 50-261/89-16-05 Closed Review Each Appendix C Ite IFI 50-261/89-16-06 Closed Correct Verification and Validation Deficiencie IFI 50-261/89-16-07 Closed Review Memorization of Operator Immediate Action APPENDIX A Abbreviations IFI Inspector Followup Item NRC Nuclear Regulatory Commission NPSH Net Positive Suction Head VIO Violation