IR 05000261/1997004

Insp Rept 50-261/97-04 on 970209-0322.Violations Noted. Major Areas Inspected:Operations,Maintenance,Engineering & Plant Support

ML14181A902
Person / Time
Site:	Robinson
Issue date:	04/18/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14181A898	List: IR 05000261/1997004 ML14181A900
References
50-261-97-04, 50-261-97-4, NUDOCS 9705080224
Download: ML14181A902 (22)

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos:

50-261 License Nos:

DPR-23 Report No:

50-261/97-04 Licensee:

Carolina Power & Light (CP&L)

Facility:

H. B. Robinson Unit 2 Location:

3581 West Entrance Road Hartsville, SC 29550 Dates:

February 9 - March 22, 1997 Inspectors:

B. Desai, Senior Resident Inspector J. Zeiler, Resident Inspector F. Jape, Senior Project Engineer Approved by:

M. Shymlock, Chief, Projects Branch 4 Division of Reactor Projects Enclosure 2 9705080224 970418 PDR ADOCK 05000261 a

PDR

EXECUTIVE SUMMARY H. B. Robinson Power Plant, Unit 2 NRC Inspection Report 50-261/97-04 This integrated inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a six-week period of resident inspection; in addition, it includes the results of an inspection by one Region II based project enginee Operations

Conduct of operations was professional and safety-conscious (Section 01.1).

• A control room switch, affecting the automatic capability of the Steam Dump System, was found mispositioned by the Shift Supervisor. This was identified as an Non-Cited Violation (NCV) (Section 01.2).

• Operators appropriately controlled the down and up power evolutions to maintain weir discharge temperature within limits (Section 01.3).

• Poor planning and coordination of activities contributed to the potential failure to satisfy the action statement requirements (conduct of a flux map analysis) for an inoperable power range nuclear instrument channe Following the problem, management was sensitive to the importance for timely'implementation of Technical Specification action requirements and implemented corrective actions to address root causes (Section 01.4).

• A detailed walkdown and review of the Component Cooling Water System found the system to be well maintained, conformed with plant and Updated Final Safety Analysis Report piping drawings, and was aligned in accordance with applicable operating procedures. Several minor drawing and procedure inconsistencies were noted involving the configuration control of system.vent and drain line pipe caps. An out-dated Abnormal Operating Procedure was found in the charging pump emergency cooling equipment storage container and was updated by the licensee in a timely manner (Section 02.1).

• The identification of the leak in the Service Water system by an operator was considered an indication of attention to detail and good questioning attitude (Section M1.2).

• The Plant Nuclear Safety Committee and the Nuclear Assessment Section provided strong oversight and safety focus of licensee activities (Section 07.1).

Maintenance

Observed maintenance activities were appropriately coordinated and conducted.(Section M1.1).

• The failure to follow freeze seal procedure requirements for monitoring and logging freeze pack temperatures on a service water line repair was identified as a violation (Section M1.2).

• Problems encountered during main turbine valve testing were appropriately addressed through the condition report process (Section M1.3).

• The operability impact of not having performed the Inservice Inspection (ISI) requirements for a visual examination of welding to replace a section of piping on the Residual Heat Removal to letdown line was adequately addressed. Poor work planning and coordination of ISI post maintenance test requirements resulted in the missed examination. This was identified as an NCV for failing to follow post maintenance testing procedures (Section M3.1).

Engineeringj

Good questioning attitude on the part of a system engineer identified that all required Emergency Diesel Generator fuel oil day tank water testing was not being conducted. However, it surfaced a weakness in that initial license commitments were not implemented properly. The failure to implement procedures for checking the day tanks for water was identified as an NCV (Section E1.1).

• Licensee appropriately prioritized efforts to address noise induced inadvertent bistable actuations. Engineering support related to this issue was good (Section E2.1).

Plant Support

Actions to address minor weaknesses previously identified involving the control of radiological survey data were adequately resolved (Section R8.1).

Report Details Summary of'Plant Status Unit 2 remained at power the entire inspection period completing 152 days of continuous operation. On March 5, a downpower to 50 percent was conducted to avert exceeding Weir discharge temperature limits imposed by the State of South Carolina. The Unit was returned to full power on March 9, 1997 and remained at full power for the remainder of the report perio I. Operations

Conduct of Operations 01.1 General Comments (71707)

The inspectors conducted frequent control room tours to verify proper staffing, operator attentiveness and communications, and adherence to approved procedures. The inspectors attended operation shift turnovers, management reviews, and plan-of-the-day meetings to maintain awareness of overall plant operations. Operator logs were reviewed to verify operational safety and compliance with Technical Specifications (TSs).

Instrumentation, computer indications, and safety system lineups were periodically reviewed from Control Room to assess operability. Frequent plant tours were conducted to observe equipment status and housekeepin Condition Reports (CRs) were routinely reviewed to assure that potential safety concerns and equipment problems were reported and resolve In general, the conduct of operations was professional and safety conscious. Good plant equipment material conditions and housekeeping were noted throughout the report period. Specific events and noteworthy observations are detailed in the sections belo.2 Mispositioned Control Room Switch a. Inspection Scope On March 3, 1997, an oncoming Shift Supervisor, Operations (SSO), noted that the control room steam dump control switch was in the "OFF" position. The switch was returned to its required "ON" position. With the steam dump control switch mispositioned, the automatic Reactor Coolant System (RCS) Tavg control using the condenser and atmospheric steam dump valves was not available. A condition report (CR N ) was initiated as a result of this inciden b. Observations and Findings The inspector reviewed and discussed the event with the licensee. The steam dump control switch had been placed in the "OFF" position the previous night in accordance with Maintenance Surveillance Test (MST)

015, First Stage Pressure (monthly), to prevent inadvertent steam dump operation during the performance of the MST. The restoration step in MST-15 associated with the steam dump control switch indicated that the operator may place the switch as desired. This step gave the

flexibility to the operator to determine the position of the switch based on plant condition (outage, shutdown, power operation. etc.).

However, the operator performing the evolution did not recognize the need to return the switch to the required "ON" position for current plant condition. A contributing cause, in addition to the "non specific" instruction was that the operator had performed this MST for the first time. The inspector noted that this same switch was mispositioned in 199 As corrective action, the licensee discussed the event with the shift personne Further, a procedure enhancement to specifically identify the required switch position is planned during the next revisio Additionally, the Shift Technical Advisors (STAs) were sensitized to this event to enable them to potentially identify similar future conditions during their board walkdown c. Conclusions The inspector determined that even though the switch was in the "off" position, manual capability and the capability through the Rod Control System to control Tavg was available to the operator if a transient had occurred. The failure to have the steam dump control switch in the required position is identified as a Violation. This licensee identified and corrected violation is being treated as an Non-Cited Violation (NCV) consistent with section VII.B.1 of the NRC Enforcement Policy. This NCV will be documented as 50-261/97-04-01: Mispositioned Control Room Switch. The identification of the condition by the oncoming SSO was considered as an example of good attention to detail during board walkdow.3 Unit 2 Down Power a. Inspection Scope (71707)

On March 5, 1997 at approximately 2:00 pm, Robinson Unit 2 initiated a down power to approximately 50 percen b. Observations and Findings The down power was initiated to avert exceeding the daily average "Weir" discharge temperature limit of 82.4 degrees F for the current period, which ended on March 8, 1997. During the down power, the licensee performed secondary side maintenance and also performed a surveillance involving Turbine Control Valves. The Weir discharge limits were approached due to unusually mild late winter conditions. The Unit was returned to full power by March 9 at which time a new period as well as different Weir discharge temperature limits became applicable. The unit is not currently power limited to meet applicable temperature limits due to relatively cooler temperature Robinson has applied for a new permit which contains one-maximum year round temperature limit. This application is under review by South

Carolina Department of Health and Environmental Control (DHEC) and issuance is expected in June 1997. The new limit is expected to eliminate fall and spring temperature limit problem c. Conclusions The inspector concluded that plant operators appropriately controlled the down and subsequent up power evolution.4 Failure to Complete TS LCO Action Statement in Allowed Time a. Inspection Scope (71707)

The inspector reviewed the circumstances involving the licensee's failure to complete a flux map within the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Limited Condition of Operation (LCO) action statement of TS Table 3.5-2 for an inoperable Nuclear Instrument Power Range Channe b. Observations and Findings On March 13, 1997, at 8:50 a.m., Nuclear Instrument Power Range Channel N-44, was declared inoperable due to a malfunctioning high voltage power supply. With one inoperable power range channel, Action 2.b of TS Table 3.5-2 required that power be restricted to 75 percent or Quadrant Power Tilt Ratio (QPTR) be monitored via a reactor flux map within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to confirm that power was consistent with indicated QPTR. The licensee intended to conduct the flux map since it was expected that replacement of the high voltage power supply could not be completed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> due to parts availability; however, both of these activities were pursued in paralle At approximately 4:00 p.m., reactor engineering personnel began to take flux map data. Data collection was completed several hours later; however, due to anomalies in the data resulting from the ongoing maintenance activities to replace the high voltage power supply, analysis of the data was not completed until 11:00 p.m. Therefore, the flux map was not completed within the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> action statemen At approximately 6:15 p.m. that same day, maintenance had completed the high voltage power supply replacement activity, including channel calibration of N-44. The operations Shift Supervisor decided to wait until the next shift to complete the prescribed post maintenance testing associated with Operations Surveillance Test (OST)-005, Nuclear Instrumentation Power Range, in order to return N-44 to service. Based on times specified in the operator logs, this testing was completed on the following shift at 8:57 p.m., and N-44 was declared back in service at 9:07 At the end of the report period, the licensee was still reviewing whether the TS LCO action statement was exceeded. While OST-005 was not completed within the required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the channel calibration conducted earlier by maintenance following the power supply replacement

may have been sufficient post maintenance testing necessary to consider the channel operabl The inspector noted that activities associated with completing the flux map analysis and repair of N-44 were poorly planned and coordinate Operations attention was not clearly focused on ensuring that either the repair or flux map analysis was completed within the allowed tim Reactor engineering personnel started data collection well into the action statement period even though it was recognized that repair activities were not expected to be completed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. While flux data analysis problems were not expected by engineering and operations based on previous flux map performances, they neglected to adequately consider the impact of maintenance work being conducted in conjunction with data collection and did not allow enough extra time for unanticipated problem The inspector noted that management was sensitive to the weaknesses that were evident from this incident. CR 97-00637 was initiated and management directed that a team be formed to identify and address the root cause of problems leading to the potential TS violation. The inspector plans to review both the licensee's corrective actions to address the root causes of this incident and the adequacy of post maintenance testing performed in order to determine whether a TS violation occurre c. Conclusions The inspector concluded that poor planning and coordination of activities contributed to the potential failure to satisfy the action statement requirements for an inoperable power range nuclear instrument channe Following the problem, management was sensitive to the importance of meeting TS action statement requirements and implemented effective corrective actions to address root cause Operational Status of Facilities and Equipment 02.1 Engineered Safety Feature Walkdown of Component Cooling Water System a. Inspection Scope (71707)

The inspector performed a walkdown of accessible portions of the Component Cooling Water (CCW) System. The actual plant configuration was compared to plant drawings, system lineup procedure, and Updated Final Safety Analysis Report (UFSAR) description and figures. The status of outstanding maintenance was reviewed to verify CCW System readiness for performing its safety related functio b. Observations and Findings The inspector determined that CCW flow diagrams in the UFSAR (Figures 9.2.2-1 through 2-3) and plant piping diagrams (Plant Drawing No. 5379 376, Sheets 1-4) were generally accurate and reflected the as-built

plant configuration. However, differences were identified in that the drawings did not depict pipe caps installed at the end of piping sections downstream of vent and drain valves. In some cases, the drawings depicted these pipe caps, but for the majority, the drawings had a "D" where the pipe cap would normally be located indicating that the piping was routed to a drain. This drawing inconsistency was discussed with the system engineer who initiated Engineering Service Request (ESR)97-182 to update the affected drawings. The inspector determined that similar problems existed to varying degrees with other system piping drawing Based on a walkdown of selected portions of the CCW System outside containment, the inspector determined that major flowpath valves were properly positioned in accordance with Operating Procedure (OP)-306, Component Cooling Water System, Revision 23. The inspector observed that material condition and housekeeping were being maintained at good levels in all areas accessed. A minor weakness was identified with OP 306 with regard to consistency in the configuration control of pipe caps. Several vent and drain line pipe caps were not listed in the procedure lineup verification checklist, consequently, installation of these pipe caps were not being verified. The inspector selected several pipe caps not listed in the procedure and verified that they were in fact installed during the plant walkdown. No discrepancies were identifie While conducting an inventory of equipment contained in the charging pump emergency connection storage box, the inspector found an out-dated copy of Abnormal Operating Procedure (AOP)-14, Component Cooling Water System Malfunction. The current revision of AOP-14 was 15, however, the copy found was Revision 14. The licensee took immediate actions to replace the procedure with the correct revision and initiated CR 97 00365 to investigate the cause of the discrepancy. The inspector determined that the applicable part of AOP-14 used to implement emergency cooling water to the charging pumps had not changed between revisions, therefore, the actual safety significance of the discrepancy was minima The inspector reviewed all open work items (Action and Work Requests)

for the CCW System. None of the items reviewed were considered a significant compromise to system operability or performanc c. Conclusions The inspector concluded that the CCW System was well maintained, conformed with plant and UFSAR piping drawings, and was aligned in accordance with applicable operating procedures. No major discrepancies were identified; however, several minor drawing and procedure configuration inconsistencies were noted with system vent and drain line pipe caps. An out-dated Abnormal Operating Procedure was found in the charging pump emergency cooling equipment storage containe Quality Assurance In Operations 07.1 Plant Nuclear Safety Committee and Nuclear Assessment Section Oversight a. Inspection Scope (40500)

The inspector evaluated certain activities of the Plant Nuclear Safety Committee (PNSC) and Nuclear Assessment Section (NAS) to determine whether the onsite review functions were conducted in accordance with TS and other regulatory requirement b. Observations and Findings The inspector periodically attended PNSC meetings during the report period. The presentations were thorough and the presenters readily responded to all questions. The committee members asked probing questions and were well prepared. The committee members displayed understanding of the issues and potential risk Further, the inspector reviewed NAS audits and concluded that they were appropriately focused to identify and enhance safet c. Conclusions The inspector concluded that the onsite review functions of the PNSC were conducted in accordance with TSs. The PNSC meeting attended by the inspector was well coordinated and meeting topics were thoroughly discussed and evaluated. NAS continued to provide strong oversight of licensee activitie Miscellaneous Operations Issues (92901)

08.1 (CLOSED) Violation 50-261/95-23-02, Operator Fails to Follow OMM. and Procedure OP-301 was Inadequate: Following a thorough review of this event, it was concluded that the violation resulted from a lack of communications between Control Room personnel during configuration changes. The end result was an unplanned opening of a relief valve on the Chemical and Volume Control System. Corrective action, as presented in the licensee's response, dated October 18, 1995, and accepted by the NRC on October 25, 1995 were verified by the inspector. The corrective actions taken included improvements in affected procedures, programmatic changes to the corrective action process and improvements in the classroom and simulator training related to this event. Additional emphasis was also placed on the requirement for three-way communications described in OMM-001, Operations Conduct of Operation II. Maintenance M1 Conduct of Maintenance M1.1 General Comments a. Inspection Scope (61726 and 62707)

The inspector observed all or portions of the following maintenance related WRs/JOs and reviewed the associated documentation:

WR/JO 96-AFINi Inspection of Boric Acid Degradation on Studs of Valve SI-844B, Containment Spray Pump B Suction WR/JO 97-MADJ1 Replace Condenser to Control Room Water Cooled Condensing Unit (WCCU)-1B

WR/JO 97-AAQB3 Retrieval of Loose Part in Spent Fuel Pool Heat Exchanger b. Observations and Findings The inspector observed that these activities were performed by personnel who were experienced and knowledgeable of their assigned tasks. Work procedures were present at the work location and being adhered t Procedures provided sufficient detail and guidance for the intended activities. Activities were properly authorized and coordinated with operations prior to start. Test equipment in use was calibrated, procedure prerequisites were met, and system restoration was complete Particularly noteworthy was the close monitoring and observation of work activities by both the work supervisors and system engineers for the WCCU-1B compressor replacement and spent fuel pool heat exchanger loose part retrieval. The inspector also observed that good radiation control measures were implemented for the heat exchanger activitie c. Conclusions The inspectors concluded that routine maintenance activities were performed satisfactoril M1.2 Freeze Seal Repairs on Service Water System a. Inspection Scope (62707)

The inspector reviewed engineering and maintenance support activities related to freeze seal repairs on the service water (SW) system. The repair, involving cutout and replacement of a portion of the one inch hypochlorite supply line to the SW header, was initiated when an operator identified leakage of less than one drop per five minute perio b. Observations and Findings Upon noticing the leakage, operations immediately notified engineerin Following inspection, presence of minor corrosion was noted, and the pipe flaw appeared to be a through wall/pin hole. The line is a one inch, schedule 40, 316 stainless steel and is classified as safety class 3, and it functions to provide chlorination to the SW system at specific intervals to reduce biological fouling. An operability determination was initiated by the licensee due to the pipe's pressure boundary function. The operability concluded that the system was operable; however, contingent on a time bound action statement of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The operability determination addressed key elements including the ability of the SW system to perform its intended function during a worst case severance of the affected SW line. This necessitated repairs, and since the leak was non-isolable, a decision to utilize a freeze seal was mad The inspector reviewed the operability determination as well as portions of the repairs. The repairs activity was conducted on a Saturday (outside normal working hours) and included the cut-out and replacement of the affected line, including the use of a freeze plug. The freeze plug activities were conducted in accordance with procedure SPP-002, Freeze Plugging of Piping Not Requiring Brittle Fracture. During this observation, the inspector noted that SPP-002 step 7.4.2, required that the freeze pack temperature be monitored and logged at 15 minute intervals. While the temperature of the pack was monitored, the inspector noted that the crew was not recording the data as required by step 7.4.2 of SPP-002. The inspector discussed this with the maintenance job supervisor, who upon further review, initiated the required recordings. Further, during licensee review of the incident the following inspector observations, it was identified that SPP-002 steps 7.3.3, 7.3.8, and 7.3.9, also required that three thermocouples be utilized to monitor freeze pack temperatures. Contrary to this requirement, the crew was only utilizing two thermocouples. The activity was completed and successfully post maintenance tested. The inspector walked down portions of the SW system, including the replaced portion of the piping. No additional leaks or degradation was note c. Conclusions The inspector concluded that the identification of the leak by the operator was considered an indication of good questioning attitude. The failure to follow maintenance procedure requirements for monitoring and logging freeze pack temperatures in accordance with SPP-002 was identified as a Violation. This issue will be documented as Violation 50-261/97-04-02: Failure to Follow Procedure SPP-002 for Properly Monitoring and Logging Freeze Pack Temperatures. Following the NRC exit meeting associated with this report, the Nuclear Assessment Section initiated an audit of licensee activities with special emphasis on shift performance outside normal working hour M1.3 Turbine Valve Testing a. Inspection Scope (62707)

During performance of surveillance test OST-551, Turbine Valve and Trip Functional, on March 5, 1997, the 2A Moisture Separator Reheater (MSR)

intercept valve MS-21L did not close upon demand. The inspector reviewed and discussed the condition to determine closure capability of the intercept valv b. Observations and Findings The licensee initiated CR 97-00571 to address this issue. During this investigation, the licensee identified that the test Solenoid Operated Valve (SOV) for the intercept valve had failed. The SOVs' internal 0-ring had disintegrated and the plunger and body mating surfaces were found to be slightly scored. Further, it was noted that incorrect 0 ring material (Buna-N) was used in the SOV, which was incompatible with the Electro-Hydraulic Fluid (EHC).

The licensee is of the opinion that the disintegrated 0-ring material had wedged between the SOV plunger and body, preventing the plunger from movin The failure of the SOV did not affect the operability and closure capability of the intercept valve as required by TS Table 4.1-3, in that, this SOV is only utilized during testing. Further, the SOV was replaced and the intercept was subsequently tested satisfactoril As part of corrective actions, the licensee plans to establish Preventive Maintenance to periodically changeout the test SOV Additionally, the licensee plans to ensure that other SOVs in stock do not have the incorrect 0-ring materia Conclusions The inspector concluded that the licensee appropriately initiated a CR to identify and address problems experienced during performance of turbine valve testin M3 Maintenance Procedures and Documentation M3.1 Failure to Perform ISI Required Visual Examination of Piping Welds a. Inspection Scope (61726 and 62707)

On February 26, 1997, the licensee identified that a visual examination of welds in accordance with American Society of Mechanical Engineers (ASME) Code Section XI Inservice Inspection (ISI) requirements was not performed following the replacement of a section of Class 2 piping in the Residual Heat Removal (RHR) system to charging letdown line. The inspector reviewed the licensee's operability determination for the missed ISI inspection and the circumstances related to the missed inspectio b. Observations and Findings The inspector reviewed Engineering Service Request 97-00122, which documented the licensee's evaluation of the operability determination of the RHR letdown piping. The piping replacement was conducted during Refueling Outage 17 in October, 1997, and the piping was returned to service without having completed the visual examination. A total of four welds were not examined following replacement of a small section of 2-inch piping between valves RHR-760 and HCV-142. The licensee determined that the piping was still operable without having performed the examination based on the following major points: 1) a liquid penetrant exam (PT) was performed in accordance with ISI requirements and no flaws were detected, 2) a system leakage test was performed and no leakage was identified, and 3) the section of piping is normally isolated and depressurized at power. The inspector determined that the licensee had adequately evaluated the letdown line operability which concluded that there was adequate confidence in the structural integrity of the piping. The licensee planned to perform the visual examination at a later date after evaluating the proper configuration to support pressurization of the pipin The inspector determined that this problem was the result of poor work planning/coordination and inattention to detail by the maintenance planners and ISI engineers who developed the work request packag Maintenance Manual Procedure (MMM)-003A, Post Maintenance Testing, describes the process for establishing correct post maintenance testing following maintenance activities. The procedure requires that all ISI post maintenance testing be identified and recorded in the work request, i.e., on the Post Maintenance Test Requirement (PMTR) data-sheet. When the work request package for the pipe replacement was developed, the visual examination requirement was not included on the PMTR data-shee The inspector concluded that the licensee failed to follow MMM-003A resulting in the Letdown piping being returned to service without performing the visual examinatio The licensee attributed the failure to specify all the ISI test requirements on the PMTR to lack of clear responsibility regarding who actually initiates the PMTR data-sheet. Previous arrangements existed between engineering and maintenance planners where either could initiate the data-sheet. The licensee plans to develop more specific guidance and requirements on how ISI test requirements should be specified and revise MMM-003A, as well as other applicable procedures to state specifically who is responsible for the specification of PMT Conclusions The inspector concluded that the licensee had adequately evaluated the safety impact of not having performed the visual examination. Poor work planning and coordination of ISI test requirements between maintenance planning and engineering resulted in the failure to prescribe all of the post maintenance test requirements. The failure to follow the requirements of MMM-003A was identified as a violation. This licensee-

identified and corrected violation is being treated as a NCV consistent with Section VII.B.1 of the NRC Enforcement Policy. This NCV will be documented as NCV 50-261/97-04-03:

Failure to Prescribe ISI Test Requirements in Work Request Packag M8 Miscellaneous Maintenance Issues (92902)

M8.1 (CLOSED) Violation 50-261/95-06-01, Failure to Follow and an Inadequate Operations and Maintenance Procedure: The inspector verified that the corrective actions described in the licensee's response, dated May 17, 1995, and accepted by the NRC on May 24, 1995, to be completed. The corrective actions taken were designed to improve performance in the areas of procedure adherence, procedure adequacy, and communication These actions were recognized as being effective by the NRC at a meeting on April 25, 1995 to discuss the Performance Evaluation Section. A declining trend in the number of deficiencies due to personal error and inadequate procedures was demonstrate M (CLOSED) Violation 50-261/95-30-01, Inadequate Accumulator level Calibration Procedure:

This violation involved an inadequate accumulator level calibration procedure, resulting in actual water volume being slightly less than indicated. The licensee assembled a team to investigate the root cause of this discovery. The root cause investigation was comprehensive and adequately resolved the proble The inspector verified the corrective actions described in the licensee's response, dated February 21, 1996, and accepted by the NRC on March 13, 1996, to be complete. The level instrumentation was recalibrated and restored to service promptly upon discovery of the error. Full compliance was achieved on December 18, 1995 and no further problems have been identifie Note that this subject is discussed in LER 95-009-00, -01 which is closed in this repor M (CLOSED) LER 50-261/95-09-00, -01, Condition Prohibited by Technical Specifications due to Inoperable Safety Injection Accumulator: These LERs identified a condition where the plant was operating with the indication of level in the accumulators in error. A Notice of violation was issued for this event (50-261/95-30-01) which is discussed and closed in this report (Section M8.2). Consequently, LER 95-009-00, -01 are closed based on the review of the corrective actions for the violatio M8.4 (CLOSED) LER 50-261/97-03-00, Condition Prohibited by Technical Specifications Due to Safeguards System Relay Replacement: This LER involved the licensee's entry into the action statement of TS 3.0 to replace a test relay in the B train of Engineered Safety Function Actuation System (ESFAS). The relay allowed testing of the ESFAS main steamline isolation circuitry which failed during earlier ESFAS testin In order to replace the relay, and still maintain functional capability of the rest of the B train of ESFAS, a jumper was installed in the ESFAS control circuitry to maintain power to the other ESFAS relays in

parallel with the main steamline ESFAS relay. Since this jumper was not seismically qualified, the B train of ESFAS was considered inoperabl With no TS allowable outage time associated with ESFAS, the licensee entered the action statement of TS 3.0 while the jumper was installe The licensee has previously submitted a TS change request to the NRC to convert the current TS to the Improved Standard TS (ISTS).

The ISTS provides an allowable outage time for a single train of ESFAS to be inoperable. This LER was close III. Engineering El Conduct of Engineering E1.1 Failure to Check EDG Fuel Oil Day Tanks for Water a. Inspection Scope (37551)

On February 13, 1997, the licensee identified that the Emergency Diesel Generator (EDG) fuel oil day tanks were not being checked for water on a monthly basis as committed to in Regulatory Guide (RG) 1.137, Fuel-Oil Systems for Standby Diesel Generators, Revision 1. The inspector reviewed the circumstances involving the missed commitment and implementation of corrective actions described in CR 97-0026 b. Observations and Findings The inspector reviewed UFSAR 1.8, Conformance to NRC Regulatory Guides, which discusses the licensee's commitment to conform with the requirements of RG 1.137. Paragraph C.2.e requires the day tanks be checked for water, monthly, and after each operation of the EDGs, where the period of operation is one hour or longer. Robinson committed to the provisions of Paragraph C.2, with several exceptions. None of these exceptions included provisions for not testing the day tanks. The licensee determined that this testing was most likely missed due to a lack of attention to detail during initial implementation of the R The inspector reviewed the remaining fuel oil testing commitments contained in RG 1.137 and did not identify any other discrepancies. The inspector noted that existing provisions had been properly implemented for monthly testing of the Diesel Fuel Oil Storage Tank (DFOST), which supplies fuel oil to the day tanks. This testing provided the potential for detecting water that might be transferred to the day tanks. In addition, testing is conducted whenever fuel oil is transferred to the DFOST. Therefore, the actual safety consequences of this testing discrepancy was considered minima Upon discovery of the non-compliance, both day tanks were tested for water and the results showed no detectable amounts present. The inspector verified that applicable operating and surveillance procedures were revised by the licensee to include future testing of the day tank c. Conclusions The inspector concluded that the identification of this issue was an example of good questioning attitude on the part of the system enginee However, it surfaced a weakness in that initial UFSAR commitments were not implemented properly. The failure to implement procedures for checking the EDG fuel oil day tanks for water in accordance with RG 1.137 was identified as a violation of TS 6.5.1.1. This licensee identified and corrected violation is being treated as an NCV consistent with Section VII.B.1 of the NRC Enforcement Policy. This NCV will be documented as NCV 50-261/97-04-04: Failure to Implement Procedures for Monthly Water Sampling of EDG Fuel Oil Day Tank E2 Engineering Support of Facilities and Equipment E2.1 Inadvertent Bistable Actuations a. Inspection Scope (37551)

The inspector noted that in the last several weeks, inadvertent bistables actuations associated with the Hagan process instrumentation system on the Reactor Protection System (RPS) and Engineered Safety Features (ESF) systems continued to occur during performance of certain evolutions and surveillances. While no reactor trip or inadvertent ESF actuation manifested, the inspector expressed concern to licensee management. The licensee also simultaneously recognized the need to address this issue and formed a team to address and resolve the proble b. Observations and Findings Licensee team reviewed inadvertent bistable actuation related condition reports (CR) for years 1995, 1996, and 1997, work requests (WR) for years 1996 and 1997, and performed testing on the Hagan test racks. The licensee also procured services of CHAR Services, Inc., (vendor) to assist the team with the investigatio The team, following review of applicable data, including, that gathered during testing conducted on February 24 through 26, 1997, concluded that the cause of the inadvertent bistable actuations was induced electrical noise into the Hagan process instrumentation system. The electrical noise problem is exacerbated by the design of the Hagan modules which has a single 20 pin "Elco" connector on the back of the module. All signal leads, control leads, and power leads run through the connector, and are in close proximity, resulting in "intra" module electrical coupling. Further, the inspector was also informed that the licensee had also observed "inter" module coupling by virtue of Hagan modules in close proximit The team recommended that noise suppression techniques such as metal oxide varistors and resistor capacitor snubbers be installed parallel to the noise generating relays. The team also recommended that capacitors be installed in certain cases at the Hagan comparator signal inputs, to

suppress noise. Current licensee plans are to install snubber/filters on Rack-50 (non-safety) and determine success in arresting the noise related inadvertent bistable actuations. Further, this issue is being carried as the number 1 item on the "Top Ten" priority item lis Additionally, the licensee is continuing to monitor and appropriately document circumstances surrounding future inadvertent bistable actuations, for analysi c. Conclusions The inspector concluded that licensee appropriately prioritized efforts to address noise induced inadvertent bistable actuations. Engineering support related to this issue was good. The inspector plans to monitor licensee action relating to resolution of this issu E7 Quality Assurance in Engineering Activities E7.1 Special UFSAR Review A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares plant practices, procedures and/or parameters to the UFSAR descriptions. While performing the inspection discussed in this report, the inspector reviewed selected portions of the UFSAR that related to the areas inspected. The inspector verified that for the select portions of the UFSAR reviewed, the UFSAR wording was consistent with the observed plant practices, procedures and/or parameter E8 Miscellaneous Engineering Issues (92903)

E (CLOSED) IFI 50-261/95-21-02, Reactor Failed to Achieve Critically due to Errors in Estimated Critical Position Calculation: During a reactor startup on July 1, 1995, critically could not be achieved prior to exceeding the administrative limit of -500 pcm on the estimated critical position (ECP). Startup was terminated, all rods were inserted and an investigation was commence The principal contributing cause was identified as the computer code used to calculate the power defect and Samarium modeling. These errors overestimated the value of the Xenon decay and resulted in an error in the computer-generated ECP. A secondary cause was due to the boron concentration used in the ECP was from the previous day and some dilution had taken place. Both errors resulted in a conservative calculatio The investigation determined the ECP error was not due to an actual core problem, such as core misloading or fuel misdesign. Currently Robinson uses a new computer code, called POWERTRAX, to calculate ECP. The calculation performed for restart from RF 18 was within the allowable -,

+500 pc E8.2 (CLOSED) IFI 50-261/95-20-03, Justification for Absence of Overpressure Protection on Tubeside of Service Water System:

During an inspection of the Service Water system, the inspector questioned RNP's interpretation of ASME Code Section VIII which requires protective devices for pressure vessels. Robinson uses administrative controls in lieu of protective devices on Section VIII components.. The code allows for individual components which are isolable from normal system overpressure protection to be reviewed to determine whether additional protection is necessar When the affected components are isolated, they are isolated from the pressure source and are not exposed to other pressure sources. When the components are isolated, the system is under positive control to prevent overpressurization of trapped service wate A similar concern was raised at several other NRC Region II facilities and is currently being reviewed by NRR. Upon completion of the technical review, this issue may be reopened for further study at Robinson. In the meantime, this issue is closed based on the positive administrative controls currently in plac I Plant Support R1 Radiological Protection and Chemistry Controls (71750)

R1.1 Tours of the Radiological Control Area (RCA)

The inspectors periodically toured the RCA.during the inspection perio Radiological control practices were observed and discussed with radiological control personnel including RCA entry and exit, survey postings, locked high radiation areas, and radiological area material conditions. The inspectors concluded that radiation control practices were prope R8 Miscellaneous Radiation Protection and Control Issues (92904)

R (Closed)

Unresolved Item (URI) 50-261/97-01-07, Complete Review of Licensee Controls of Radiological Survey Data:

This issue involved several minor weaknesses identified in the licensee's control of radiological survey data, including the following: 1) a shift radiation technician was unfamiliar with the location of current survey data and used out-dated information for a briefing, 2) active special Radiation Work Permits (RWPs) posted at the entrance to the RCA did not contain the most recent survey data attached to them, and 3) routine radiological survey data was not being evaluated in a timely manner to effect updates of RWPs impacted by changing radiological condition The licensee initiated CR 97-00319 to address the inspector's concern The following actions associated with the above three items were completed by the licensee:

Item 1:

All informal and formal training provided to new shift radiation technicians was reviewed. All formal qualifications were

found to be met. Additional training was identified in certain areas in order to re-enforce expectation Item 2: Out-dated radiological survey data was removed from special RWPs posted on the RWP board at the RCA entrance. A survey map book was developed and placed at the entrance to the RCA. This book contained.

the current radiological surveys for all areas of the RCA. Special RWPs were revised to require workers to review the survey map book prior to conducting work in the applicable plant location. This book was to be updated as soon as new surveys became available. The licensee plans to revise radiological control procedures to reflect this process, as well as describe other radiological control processes that were not well delineate Item 3:

The licensee revised the formal review process for evaluating new routine radiological survey data and their impact on RWP Previously, these evaluations were being performed at the completion of all surveys for a given frequency, i.e., monthly, quarterly, annual, etc. In order to expedite the process and ensure RWPs were revised in a timely manner, these evaluations were to completed as soon as practical after completio The inspector concluded that the licensee had adequately addressed the weaknesses identified. This URI was close S1 Conduct of Security and Safeguards Activities (71750)

S1.1 General Comments During the period, the inspector toured the protected area and noted that the perimeter fence was intact and not compromised by erosion nor disrepair. Isolation zones were maintained on both sides of the barrier and were free of objects which could shield or conceal an individua The inspector periodically observed personnel, packages, and vehicles entering the protected area and verified that necessary searches, visitor escorting, and special purpose detectors were used as applicable prior to entry. Lighting of the perimeter and of the protected area was acceptable and met illumination requirement V. Management Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on March 31, 1997. The inspectors asked-the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie PARTIAL LIST OF PERSONS CONTACTED Licensee H. Chernoff, Supervisor, Licensing/Regulatory Programs J. Clements, Manager, Site Support Services D. Crook, Senior Specialist, Licensing/Regulatory Compliance C. Hinnant, Vice President, Robinson Nuclear Plant J. Keenan, Director, Site Operations B. Meyer, Manager, Operations G. Miller, Manager, Robinson Engineering Support Services R. Moore, Manager, Outage Management D. Stoddard, Manager, Operating Experience Assessment R. Warden, Manager, Nuclear Assessment Section T. Wilkerson, Manager, Regulatory Affairs D. Young, General Manager, Robinson Plant NRC B. Desai, Senior Resident Inspector J. Zeiler, Resident Inspector

INSPECTION PROCEDURES USED IP 37551:

Onsite Engineering IP 40500:

Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726:

Surveillance Observations IP 62707:

Maintenance Observation IP 71707:

Plant Operations IP 71750:

Plant Support Activities IP 92901:

Followup - Operations IP 92902:

Followup - Maintenance IP 92903:

Followup - Engineering IP 92904:

Followup - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED Opgned iypg Item Number Status Description and Reference NCV 50-261/97-04-01 Open Mispositioned Control Room Switch (Section 01.2)

VIO 50-261/97-04-02 Open Failure to Follow Procedure SPP-002 for Properly Monitoring and Logging Freeze Pack Temperatures (Section M1.2)

NCV 50-261/97-04-03 Open Failure to Prescribe ISI Test Requirements in Work Request Package (Section M3.1)

NCV 50-261/97-04-04 Open Failure to Implement Procedures for Monthly Water Sampling of EDG Fuel Oil Day Tanks (Section E1.1)

Closed TM Item Number Status Description and Reference VIO 50-261/95-23-02 Closed Operator Fails to Follow OMM, and Procedure OP-301 was Inadequate (Section 08.1)

VIO 50-261/95-06-01 Closed Failure to Follow and an Inadequate Operations and Maintenance Procedure (Section M8.1)

VIO 50-261/95-30-01 Closed Inadequate Accumulator level Calibration Procedure (Section M8.2)

LER 50-261/95-09-00 Closed Condition Prohibited by Technical Specifications due to Inoperable Safety Injection Accumulator (Section M8.3)

LER 50-261/95-09-01 Closed Condition Prohibited by Technical Specifications due to Inoperable Safety Injection Accumulator (Section M8.3)

LER 50-261/97-03-00 Closed Condition Prohibited by Technical Specifications Due to Safeguards System Relay Replacement (Section M8.4)

IFI 50-261/95-21-02 Closed Reactor Failed to Achieve Critically due to Errors in Estimated Critical Position Calculation (Section E8.1)

IFI 50-261/95-20-03 Closed Justification for absence of overpressure protection on tubeside of Service Water System (E8.2)

NCV 50-261/97-04-01 Closed Mispositioned Control Room Switch (Section 01.2)

NCV 50-261/97-04-03 Closed Failure to Prescribe ISI Test Requirements in Work Request Package (Section M3.1)

NCV 50-261/97-04-04 Closed Failure to Meet Commitments for Monthly Water Samp ling of EDG Fuel Oil Day Tanks (Section E1.1)

URI 50-261/97-01-07 Closed Complete Review of Licensee Controls of Radiological Survey Data (Section R8.1)

Discussed

!Me Item Number Status Description and Reference None