IR 05000261/1998012
| ML14181B041 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/12/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14181B040 | List: |
| References | |
| 50-261-98-12, NUDOCS 9902240238 | |
| Download: ML14181B041 (14) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No:
50-261 License No:
DPR-23 Report No:
50-261/98-12 Licensee:
Carolina Power & Light (CP&L)
Facility:
H. B. Robinson Unit 2 Location:
3581 West Entrance Road Hartsville, SC 29550 Dates:
December 6, 1998 - January 16, 1999 Inspectors:
B. Desai, Senior Resident Inspector A. Hutto, Resident Inspector G. MacDonald, Project Engineer J. Coley, Reactor Inspector (Section M1.1)
Approved by:
Brian R. Bonser, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure 9902240238 990212 PDR ADOCK 05000261
EXECUTIVE SUMMARY H. B. Robinson Power Plant, Unit 2 NRC Integrated Inspection Report 50-261/98-12 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 inspections by a regional based reactor inspector and a project enginee Operations
The conduct of operations was professional, risk informed, and safety-conscious. A review of licensee overtime during refueling outage 18 concluded that the licensee was meeting requirements (Section 01.1).
- Operations performance during shutdown and startup activities for a maintenance outage was well planned and executed, and error-free (Section 01.2)
A detailed system walkdown found that the Containment Spray system was appropriately configured to perform its design function (Section 02.1).
- Operator logs were detailed, covered pertinent evolutions, and in accordance with procedures. The recent transition to electronic logkeeping was well planned and operators were given sufficient training before implementation (Section 02.2).
- A clearance associated with Component Cooling Water pump maintenance provided adequate isolation conditions for personnel safety and protection of plant equipmen The clearance was implemented and restored in accordance with the licensee's procedures (Section 02.3).
- The licensee approached the Ultimate Heat Sink temperature limit during the Summer of 1998. A Notice of Enforcement Discretion (NOED) and an exigent Technical Specification (TS) amendment were granted to extend the (TS) action time. The licensee never exceeded the temperature limit and did not use the extra action statement time allowed by the NOED and the TS amendment (Section 02.4).
- A human error in not using existing procedural guidance to perform a valve line-up on a non-safety related system resulted in water intrusion into the "A" Emergency Diesel Generator (EDG) room. EDG operability was not affected (Section 02.5).
- The onsite review functions of the Plant Nuclear Safety Committee (PNSC) were conducted in accordance with TSs. During the PNSC meetings topics were thoroughly discussed and evaluated (Section 07.1).
Maintenance
Maintenance activities were conducted in accordance with applicable work documents and procedures. Personnel were properly trained and knowledgeable of their assignments (Section M1.1).
- Observed surveillance testing activities were performed adequately (Section M2.1).
- Licensee actions to repair a weld leak in the Chemical and Volume Control System were well managed and coordinated between Operations, Engineering and Maintenanc Operability determinations were thorough and conservative. Repairs were performed in accordance with procedures. One concern was identified with regard to the staging of a wooden plug required for loss of freeze seal contingency plans (Section M2.2).
Engineering
A temporary modification to jumper a portion of the "A" reactor coolant pump oil reservoir level limit switch was comprehensive and in accordance with procedures. The temporary modification provided the compensatory action for the degraded condition and restored the associated control room annunciator (Section E2.1).
Plant Support
) *
Radiation control and security practices were properly conducted. Inspected areas in the Radiological Control Area were noted to be appropriately posted and secured as necessary. The security plan was effectively implemented and compensatory actions were initiated when required (Section R1.1, S1.1).
Report Details Summary of Plant Status Robinson Unit 2 began this inspection period at full power. On January 8, the unit was shutdown to Mode 3 for maintenance. On January 10, the plant commenced a reactor startup and returned to 100 percent powe I. Operations
Conduct of Operations 0 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 routinely attended operations turnover meetings, management review meetings, and plan-of-the-day meetings to maintain awareness of overall plant operations. Operator logs, Condition Reports (CR), and instrumentation were routinely reviewed. Plant tours were conducted to verify operational safety and compliance with Technical Specifications (TS), as well as to assess plant housekeeping. In general, the inspectors concluded that the conduct of operations was risk informed, professional, and safety-consciou The inspectors reviewed a sample of plant staff working hours during refueling outage 18 (RFO 18) to determine if overtime was controlled in accordance with TS. The inspectors concluded that the licensee's use of overtime during RFO18 met the requirements of TS 5.2..2 Operator Performance During a Maintenance Outage Inspection Scope (71707, 62707)
The inspectors observed shutdown and startup activities during the mid-cycle maintenance outag Observations and Findings Robinson Unit 2 was shutdown to Mode 3, Hot Shutdown, on January 8 to conduct repairs on several components including containment isolation valve WD-1728 and leaking Reactor Coolant System (RCS) flow transmitter FT-435. The inspectors monitored portions of the shutdown activities in the control room as well as in the plan The inspectors also observed pre-shutdown briefings, pre-job briefs, management meetings, scheduling meetings, and pre-startup evolution briefing Conclusions Operation's performance during shutdown and startup activities for a maintenance outage was well planned and executed, and error fre Operational Status of Facilities and Equipment 0 Engineered Safety Feature System Walkdown Inspection Scope (71707)
The inspectors conducted a system walkdown of the Containment Spray (CS) syste Observations and Findings The inspectors conducted a system walkdown of the CS system to assess the general condition of system components, including labeling, to verify that system valve positions matched the system drawings and station operating procedures, and to assess plant housekeeping and radiological conditions around system component The inspectors determined that the CS system was capable of performing its design function for accident conditions. No misaligned valves were identified, housekeeping and component labeling were adequate. The inspectors also reviewed the applicable sections of the updated Final Safety Analysis Report (UFSAR) and identified no discrepancie Conclusions A detailed system walkdown found that the CS system was appropriately configured to perform its design functio.2 Loakeeping Inspection Scope (71707)
The inspectors reviewed the method, procedure, and impact of the recent transition to electronic logkeepin Observations and Findings The licensee recently transitioned to electronic logkeeping. This change affected the control room logs as well as the auxiliary operator logs. The inspectors reviewed.
Operations Management Manual (OMM)-001 -11, "Logkeeping," Revision 11, which delineated operations logkeeping requirements, and determined that it adequately prescribed logkeeping requirements, including contingencies when the computer system is unavailable. The inspectors also reviewed the 10 CFR 50.59 screening associated with the procedure change and found it adequat The inspectors discussed the change with operators and concluded that they generally understood the computer program. The inspectors provided minor feedback to the licensee with regard to noting the allowed TS out-of-service time When logging TS action statements. The inspectors also reviewed operator logs on a daily basis and determined them to be sufficiently detailed, covering pertinent plant evolution Conclusions Operator logs were detailed, covered pertinent evolutions, and were in accordance with procedures. The recent transition to electronic logkeeping was well planned and operators were given sufficient training before implementatio.3 Clearance Walkdown Inspection Scope (71707, 62707)
The inspectors performed a walkdown of a system clearance and reviewed other currently hanging clearance Observations and Findings The inspectors verified proper implementation of clearance, 98-01178, during a walkdown on December 28. This clearance was established to support scheduled maintenance on the "A" Component Cooling Water (CCW) pump. The inspectors verified that valves as well as electrical breakers were aligned appropriately to provide an adequate boundary for the scheduled maintenance activity. No discrepancies were identified during verification of the clearance. Upon removal of the clearance the inspectors verified the restoration positions of the affected components with the required positions established by system restoration procedures and system drawing Conclusions A clearance associated with CCW pump maintenance provided adequate isolation conditions for personnel safety and protection of plant equipment. The clearance was implemented and restored in accordance with the licensee's procedure.4 Ultimate Heat Sink (UHS) Limit a
Inspection Scope (71707)
The inspectors periodically monitored licensee compliance with the UHS requirement Observations and Findings On June 27, 1998, in anticipation of exceeding the UHS TS temperature limit the licensee requested and received a Notice of Enforcement Discretion (NOED). TS 3.7.8, Ultimate Heat Sink, limits the UHS temperature to 950F. If this limit is exceeded the TS require the plant to be in Mode 3 within six hours. On June 27, the Service Water (SW)
temperature reached 94.15oF. Consequently, the licensee requested and was granted a NOED. The NOED allowed the licensee eight hours from the time 950F was exceeded to reduce temperature to within 950F. If the temperature was not reduced to below 950F within eight hours, then the TS limit of six hours to Mode 3 and another six hours to Mode 5 would be applicable. In addition to the NOED, the licensee also requested and was granted an exigent TS amendment that was identical to the NOE This amendment was effective through September 30,1998, after which, the original TS was applicabl The inspectors determined that the licensee never exceeded the 950F limit and
'therefore never had to utilize the NOED or the exigent TS amendmen The licensee is currently evaluating the prospects for permanently raising the UHS limits to 990F. Following completion of this evaluation, the licensee plans to submit a TS change reques Conclusions The licensee approached the UHS temperature limit during the summer of 1998. A NOED and an exigent TS amendment were granted to extend the TS action time. The licensee never exceeded the temperature limit and did not use the extra action statement time allowed by the NOED and the TS amendmen. 02.5 Water Intrusion into "A" Emergency Diesel Generator (EDG) Room Inspection Scope (71707)
The inspectors reviewed the circumstances involving water intrusion into the "A" EDG roo Observation and Findings On January 6 a shift fire technician noted that water was coming out of the SW lines to the Evaporative Air Coolers (EAC) and that a small amount of water had entered the "A" EDG room via the recirculation dampers in the ceiling. The water intrusion did not affect EDG operability. SW to the EACs had been isolated previously and placed under a clearance in accordance with OP-925, "Cold Weather Operation", Revision 17. This clearance also isolated SW to the auxiliary boiler sample cooler. On January 6, when it became necessary to sample the "C" Auxiliary Boiler, the Makeup Water Treatment Operator (MWTO) with assistance from a chemist aligned a rubber hose to an available vent line to supply deionized water (DI) to the sample cooler The MWTO performed the DI water alignment from memory as opposed to using continuous use procedure OP-401, "Auxiliary Heating Steam", Revision 43. As a result, he did not close valve SW-2272, SW Supply to Boiler "C" Building, as required by the procedur This provided an open flow path for the temporary DI water to the open drains in the EAC cooler. Further, the chemist assisting the MWTO did not adequately utilize the chemistry procedure which required the MWTO to utilize OP-401 for aligning temporary cooling when freeze protection is in effec The inspectors reviewed significant CR 99-00028 that was initiated by the licensee as a result of this event. The root cause of this problem was human error in not using the existing procedure to align temporary cooling water to. the auxiliary boiler sample coole The MWTO had not realized that a procedure existed to perform the evolution involving aligning temporary cooling work to the auxiliary boiler coolers. In December 1997 weak procedural usage had resulted in a similar problem that had resulted in the wetting of "A" EDG generator control panel, causing the EDG to be inoperable. Licensee corrective action following the 1997 event included placing an instructional aid at the boiler sample cooler reminding the MWTO of the need to use OP-401. However, the MWTO did not see the instructional aid and therefore did not realize that a procedure needed to be utilized to control the evolution. The licensee counseled the individuals involved and shared the event with other plant personnel. The licensee is also considering other configuration control measures to prevent this event from occurring again. Although this event had little safety significance and was not subject to the procedures described in TS 5.4.1, Procedures, it represented poor procedural use by operators and could have resulted in rendering an EDG inoperabl Conclusions A human error in not using existing procedural guidance to perform a valve line-up on a non-safety related system resulted in water intrusion into the "A" EDG room. EDG operability was not affecte Quality Assurance In Operations 0 Plant Nuclear Safety Committee and Nuclear Assessment Section Oversight (71707)
The inspectors periodically attended Plant Nuclear Safety Committee (PNSC) meetings during the inspection report period. The presentations to the committee were thorough and the presenters readily responded to all questions. The committee members asked probing questions and were well prepared. The committee members displayed an understanding of the issues. The inspectors also reviewed Nuclear Assessment Section audits and concluded that they were appropriately focused to identify and enhance safety. The inspectors concluded that the onsite review functions of the PNSC were conducted in accordance with TSs. During the PNSC meetings topics were thoroughly discussed and evaluate II. Maintenance M1 Conduct of Maintenance M Observation of Maintenance Activities (62707)
The inspectors observed all or portions of the following work requests (WRs):
WR No. AKHU002, Calibrate Power Range Nuclear Instrumentation System, Channel N43
- 0 98-AHSWI, Calibrate Flow Transmitter 6416 (Auxiliary Feed Water System)
using PIC 302
WR No. AAZD003, Calibrate Speed Control Instruments
WR No. AAZD10003, Perform Lubrication of "C" Charging Pump Speed Control Linkage and Motor
WR No. ABIT005, Calibrate Steam Driven Auxiliary Feed Water Pressure Switches PSL-1476-1,2 using PIC 301
98-AFIJ1, Replace Inboard and Outboard Seals and Bearings on "A" CCW Pump The inspectors determined that the maintenance observed was properly approved and was included on the plan of the day. The inspectors found that the work observed was thorough, and performed with the work package present and in use. Accompanying documents such as procedures and supplemental work instructions were properly followed. Personnel were properly trained and knowledgeable of their assignment The inspectors noted that supervisors and system engineers monitored the jobs on a frequent basi M2 Maintenance and Material Condition of Facilities and Equipment M Surveillance Observations (61726)
The inspectors observed all or portions of the following surveillance tests:
OST-701-2, "Waste Disposal System Inservice Inspection Valve Test," Revision
- OST-707-2, 'Waste Disposal System ISI Valve Position Indicator Verification,"
Revision *
SP-1 446, "Containment Isolation Valves Leakage Test for WD-1 728," Revision 0 The inspectors found that the testing was performed in accordance with applicable procedure M Weld Leak in the Chemical and Volume Control System (CVCS) Piping Inspection Scope (62707, 37551)
The inspectors monitored and assessed maintenance activities associated with the repair of a weld leak in the CVCS piping between the Refueling Water Storage Tank (RWST) and the suction of the charging pump Observation and Findings On December 21 a through-wall leak of approximately 27 drops per minute was identified by the licensee in four inch CVCS piping. The leak was on a drain line weld upstream of valve LCV-1 15B, Emergency Make-up to Charging Pump Suction. LCV 115B isolates the RWST from the suction header of the charging pumps. The leak was not isolable from the RWST. TS 3.4.17, Chemical and Volume Control System, requires that two make-up water flow paths from the RWST to the charging pumps be operabl Since neither flow path was isolable from the leak the licensee initiated an operability determination for the RWST to charging pumps flow paths. The inspectors reviewed Engineering Service Request (ESR) 9800758, "CVCS Operability Determination, Line 4 CH-47 Leak." The Inspectors found the ESR to be thorough with conservative assumptions and calculations, and concluded that there were no operability concerns with the piping lea The leak repair required the use of freeze seals to isolate the leak from the charging pumps and the RWST. The inspectors monitored the work performed under work request 98-AHUN1 and special process procedure SPP-002, "Freeze Seal of Piping,"
Revision 14. The inspectors determined that the work was performed according to procedures. One problem encountered during the repair required additional work. A crack in the heat affected zone was discovered while maintenance personnel were welding the drain line to the four inch CVCS line. The cause of the crack was determined to be from vibration induced work hardening in the heat effected zone of the original weld. Instructions were implemented to grind out the crack and weld in a larger drain line coupling to accommodate the increased diameter hole in the four inch CVCS piping. Weld data reports were reviewed by the inspectors and no deficiencies were identified. All repairs were completed and operability was restored within the TS action statement allowed outage tim The inspectors identified one concern during observation of the maintenanc Procedure SP-002 required that contingency plans be established in the event the freeze seal was lost during the maintenance. This was important as the RWST could not be isolated from the leak location. The work request had written instructions for these contingencies. One contingency was to have a wood plug at the work site to plug the hole where the drain line tapped in to the four inch CVCS piping if the loss of the freeze seal was imminent. During the maintenance, just after the drain line was cut off at the four inch piping, exposing the hole, the inspectors looked for the wood plug but did not see it. The inspectors asked the mechanics performing the job about the wood
plug. After about five minutes, the plug was found under some papers in a staging area adjacent to the worksite. The inspectors concluded that the wood plug could have been staged in a location where it would have been more accessible in the event problems were encountered with the freeze seal. The licensee initiated a condition report to capture the lesson learned from this observatio Conclusions Licensee actions to repair a weld leak in the CVCS were well managed and coordinated between Operations, Engineering and Maintenance. Operability determinations were thorough and conservative. Repairs were performed in accordance with procedure One concern was identified with regard to the staging of a wooden plug required for loss of freeze seal contingency plan Ill. Engineering E2 Engineering Support of Facilities and Equipment E Reactor Coolant Pump (RCP) Oil Reservoir High/Low Level Annunciator Temporary Modification Inspection Scope (37551)
The inspectors reviewed a temporary modification package that was implemented on the "A" RCP oil reservoir high/low level annunciator during a unit shutdown to mode 3 on January 8-Observations and Findings The inspectors reviewed temporary modification ESR 98-00538 to jumper out the "A" RCP lower oil reservoir low level alarm input to the control room annunciator. The temporary modification installed a jumper on the low level alarm contact of the lower oil reservoir level switch, LC-419. This restored the high level alarm on the lower reservoir and the high and low level alarms on the upper reservoir. The temporary modification will remain in place until the next refueling outag The control room "A" RCP oil reservoir high/low annunciator APP-001 -08, had been locked-in for several months. The licensee performed a visual inspection of the actual oil level and determined that the level was adequate. The level switch, LC-419, for the lower oil reservoir was not clearing at the low level set point. Switch LC-419 is designed to alarm at 1.25 inches above normal and 1.25 inches below normal oil leve The inspectors reviewed the ESR package and the 10 CFR 50.59 evaluations associated with the modification. The inspectors noted that the evaluation was comprehensive and in accordance with procedures. The inspectors also reviewed a night order (99-003) that was written to require the operating crew to periodically monitor other available "A" RCP indications to detect degrading conditions. This included RCP
vibration, motor bearing temperature, motor current, and CCW heat exchanger outlet temperature. The inspector reviewed the night order and questioned if the periodic monitoring needed to be logged in the control room logs. The licensee responded that logging of the verification would be considere Conclusions A temporary modification to jumper a portion of the "A" RCP oil reservoir level limit switch was comprehensive and in accordance with procedures. The temporary modification provided the compensatory action for the degraded condition and restored the associated control room annunciato IV. Plant Support R1 Radiological Protection and Chemistry Controls R General Comments (71750)
The inspectors periodically toured the Radiological Control Area (RCA) during the inspection period. Radiological control practices were observed and discussed with radiological control personnel including RCA entry and exit controls, survey postings, locked high radiation area controls, and radiological area material condition. The inspectors concluded that radiation control practices were being conducted in accordance with procedures. The inspectors also toured the radwaste building and found that radwaste storage containers and laundry bags were in good condition and appropriately labeled. In addition, outside radwaste storage areas and structures were properly posted and exhibited correct labeling and effective housekeeping. The inspectors found that housekeeping throughout the plant was effective in maintaining areas free of unnecessary equipment and debris. Relatively few contaminated areas were noted and posted locked high radiation areas were properly secured against unauthorized entr S1 Conduct of Security and Safeguards Activities S General Comments (71750)
During the period, the inspectors toured the protected area and noted that the perimeter fence was intact and not compromised by erosion or disrepair. Isolation zones were maintained on both sides of the barrier and were free of objects which could shield or conceal an individual. The inspectors 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 entr 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 January 22, 1999. The licensee acknowledged the findings presented at the exit meeting. No proprietary information was identifie PARTIAL LIST OF PERSONS CONTACTED Licensee T. Cleary, Manager, Operations H. Chernoff, Supervisor, Licensing/Regulatory Programs J. Clements, Manager, Site Support Services R. Duncan, Manager, Robinson Engineering Support Services J. Fletcher, Manager, Maintenance J. Moyer, Director, Site Operations R. Steele, Manager, Outage Management R. Warden, Manager, Manager, Regulatory Affairs D. Young, Vice President, Robinson Nuclear Plant NRC B. Desai, Senior Resident Inspector A. Hutto, Resident Inspector G. MacDonald, Project Engineer J. Coley, Reactor Inspector INSPECTION PROCEDURES USED IP 37551:
Onsite Engineering IP 61726:
Surveillance Observations IP 62707:
Maintenance Observation IP 71707 Plant Operations IP 71750:
Plant Support Activities
ITEMS OPENED, CLOSED, AND DISCUSSED None