IR 05000413/1986015

Insp Repts 50-413/86-15 & 50-414/86-16 on 860226-0325. Violations Noted:Tech Spec 3.2.1 Not Followed & Details for Safety Evaluation Not Documented Per 10CFR50.59

ML20206C957
Person / Time
Site:	Catawba
Issue date:	06/05/1986
From:	Brownlee V, Skinner P, Van Doorn P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206C894	List: IR 05000413/1986015 ML20206C891 ML20206C913
References
50-413-86-15, 50-414-86-16, NUDOCS 8606190609
Download: ML20206C957 (11)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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101 MARIETTA STREET.N.W.

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Report Nos.:

50-413/86-15 and 50-414/86-16 Licensee: Duke Power Company 422 South Church Street

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Charlotte, NC 28242 Docket Nos.:

50-413 and 50-414 License Nos.:

NPF-35 and NPF-48

Facility Name: Catawba 1 and 2 Inspection Conducted:

F bruary 26 - March 25, 1986

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Inspectors:

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afgSfgned Approved by:

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V.~L. Bdownlee, Section Chtef D~ ate Signed Projects Branch 3 Division of Reactor Projects SUMMARY

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Scope: This routine, unannounced inspection was conducted at the site in the areas of review of licensee event reports (Units 1 and 2); review of inspector

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identified items (Units 1 and 2); plant operations licensee identified items-

(Unit' 2); preparation for refueling (Unit 1); surveillance observation (Units 1

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and 2); maintenance observation (Units 1 and 2); preoperational test ' program implementation (Unit 2); and observation of initial fuel loading (Unit 2),

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Results: Of the ten areas inspected, two apparent violations were identified in two areas (Failure to follow Technical Specification 3.2.1.,

paragraph-5.g; Failure to document required details for. safety evaluation per 10 CFR 50.59

requirements, paragraph 7e).

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REPORT DETAILS

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1.

Persons Contacted Licensee Employees

• J. W. Hampton, Station Manager E. M. Couch, Construction Maintenance Central Manager

• H. B. Barron, Operations Superintendent W. F. Beaver, Performance Engineer W. H. Bradley, QA Surveillance

• A. S. Bhatnager, Performance Engineer T. B. Bright, Construction Engineering Manager

• S. Brown, Reactor Engineer B. F. Caldwell, Station Services Superintendent J. W. Cox, Superintendent, Technical Services T. E. Crawford, Operations Engineer

• B. East, I&E Engineer J. R. Ferguson, Assistant Operating Engineer

• C. L. Hartzell, Licensing and Projects Engineer R. A. Jones, Test Engineer J. Knuti, Operating Engineer

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• P. G. LeRoy, Licensing Engineer W. W. McCollough, Mechnical Maintenance Supervisor W. R. McCullum, Superintendent, Integrated Scheduling C. E. Muse, Operating Engineer

• K. W. Reynolds, Construction Maintenance F. P. Schiffley, II, Licensing Engineer

• G. T. Smith, Maintenance Superintendent D. Tower, Operating Engineer

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J. W. Willis, Senior QA Engineer, Operations Other licensee employees contacted included technicians, operators, mechanics, segurity force members, and office personnel.

• Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on March 25, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings.

No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.

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3.

Licensee Action on Previous Enforcement Matters (Units 1 & 2)

(92701 and 92702)

a.

(0 pen) Unresolved Item 414/85-56-02: Evaluation of Cold Spring in Safety Related Piping.

This item involves allegations of cold springing made to licensee personnel.

The technical aspects of this issue had been previously reviewed.

The inspector reviewed the licensee's final report of the investigation which included affidavits of feedback interviews.

No additional concerns were expressed by the employees which had expressed concerns relative to cold soring. This item remains open pending the licensee's personnel action.

b.

(Closed) Unresolved Item 413/85-43-03: Correction and Investigation of problems Associated with Locking Methods for Plant Valves. Guidance and training has now been provided to operators on proper methods for locking valves. This is covered by Operations Management Procedures 2-33, Valve and Breaker Position Verification and Valve Operation and had been incorporated into the training curriculum for nuclear equipment operators.

c.

(Closed) Violation 413/85-43-01:

Failure to Follow QA Procedure for Control of Nonconforming Items.

The response for this item was submitted on December 6,1985.

The inspector verified completion of corrective actions described in the response and considers licensee actions to be acceptable.

d.

(Closed) Violation 414/85-56-01:

Failure to Follow Procedure for Nonconforming Items - Water Hammer in Containment Spray System. The responses for this item were submitted on January 10, 1986 and February 24, 1986.

The Inspector verified completion of corrective actions identified in the responses and considers licensee actions to be acceptable.

e.

(Closed) Violation 413/85-48-01:

Entry Into an Operational Mode with

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Outstanding Work Open. The licensee's response to this violation was contained in Duke Power Company letter to Region II dated January 10, 1986. The inspector reviewed the corrective actions identified in this letter and considers the actions to be acceptable.

4.

Unresolved Items *

New unresolved items are identified in paragraph 5.e, 5.f, 7.c, and 7.d.

5.

Plant Operations Review (Units 1 & 2) (71707 and 71710)

a.

The inspectors reviewed plant operations throughout the reporting period to verify conformance with regulatory requirew its. Technical Specifications (TS), and administrative controls.

Cci.. ol room logs, danger tag logs, Technical Specification Action Item Log, and the

• An Unresolved Item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviation.

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remov'al and restoration log were routinely reviewed.

Shift turnovers were observed to verify that they were conducted in accordance with approved procedures.

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The inspectors verified by observation and interviews, that the measures taken to assure physical protection of the facility met current requirements.

Areas inspected included the security organization, the establishment and maintenance of gates, doors, and isolation zones that access control and badging were proper and procedures were followed.

In addition to the areas discussed above, the areas toured were observed for fire prevention and protection activities. These included such things as combustible material control, fire protection systems and materials, and fire protection associated with maintenance activities.

b.

On March 10, 1986, the licensee requested a 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> extension to the time allowed under the Action statement of TS 3/4.7.7 for the Auxiliary Building Filtered Exhaust System.

This request was made due to required replacement of the carbon bed.

The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed by the Action statement was not sufficient to replace the carbon and also perform the required testing. Relief of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was granted based on discussions between NRR, Region II, the Resident Inspectors and the licensee.

The licensee has addressed this issue in a letter to Region II dated March 10, 1986.

c.

The inspector observed cable pulling of a Unit 2 electrical cable for conformance to procedural requirements.

The cable specifically observed was No. 2KC804 for the Component Cooling System to the Auxiliary Shutdown Panel.

The inspector observed a craftsman

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carelessly stepping on small diameter piping and insulation during this operation. Although no damage occurred, the inspector cautioned the leading man for this activity and mentioned this problem to licensee management.

d.

During a review of the operation of Diesel Generator IB conducted in January 1986 (See inspection report 50-413/85-55, 50-414/85-68), the inspector identified to the licensee a diesel start attempt that appeared to be a valid failure but was identified as an invalid test.

Subsequent investigation by the licensee confirmed that this was a valid failure and in addition the diesel had been left in an inoperable status without taking compensatory actions required by TS.

This had been documented with corrective actions in Licensee Event Report 86-10.

Since this finding occurred as part of the investigation begun in January, the inspector has requested the licensee address this valid failure and the failure to take compensatory action for the out of service condition as part of the response to violation 50-413/85-55-0 '

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e.

On March 10, 1986, the licensee identified that one channel of Automatic Turbine Trip on Reactor Trip had been inoperable since December 20, 1985. This was identified by a reactor engineer as a result of re-reviews of past reactor trip reports.

The inspector discussed the process of the initial reviews required by station directives and the guidance provided therein with licensee management.

Although the present procedures appear to be adequate for an experi-enced individual, the procedure may not adequately cover required details for an individual that is less experienced.

The licensee is committed to reviewing this procedure and the training provided to personnel that conduct these reviews to determine if additional training and guidance should be provided.

Pending completion of this determination and review of the results by the inspector, this is identified as a Unresolved Item 413/86-15-04:

Review of Training and Guidance for Performing Reactcr Trip Reviews.

f.

During general plant observations in Unit 2 on March 14, 1986, the inspector noted two (2) electrays which appear to be overfilled with electrical cables.

These electrays are above the Ventilation Condensate Drain Tank in the Auxiliary Feedwater pump room.

The licensee was asked to evaluate this problem. Nonconforming Item Report CN-399 was written to track this item.

This item remains unresolved pending further licensee and NRC review.

This is Unresolved Item 414/85-16-03:

Evaluation of Apparent Electrical Cable Overfill in Electray in the Unit 2 Auxiliary Feedwater Pump Room.

g.

On March 17, 1986, the licensee identified that ten (10) bellows type penetrations had not been tested within twenty-four (24) months as required by TS 4.6.1.2h.

As a result of this, at 3:10 p.m.,

the unit commenced reducing power at a rate of 10*4 per hour.

Axial Flux Difference (AFD) went outside the TS operating limits at 3:25 p.m. but, this was not recognized due to a malfunction of the Operator Aid Computer (OAC).

Although other instrumentation existed to identify that AFD was not within prescribed requirements, the operators, including performance engineering personnel, continued to monitor the OAC.

At 6:19 p.m.,

the reactor operator noticed that the AFD instrumentation, which is on the panel' adjacent to the OAC, were pegged low. Power was reduced to less than 50*4 as required by TS at 6:25 p.m.

At 6:40 p.m.,

the bellows testing was completed and the unit exited the TS action that initiated the reduction in power.

A<., a result of this AFD problem, the licensee violated the Action requirements of TS 3.2.1.

as follows:

(1) Action item a. requires that with the indicated AFD outside of the target band and thermal power greater than or equal to 90*4 of rated thermal power, within fifteen (15) minutes either restore the indicated AFD to within the target band limits or reduce thermal power to less than 90%. Since it was not recognized that AFD was outside the target band power was not reduced to less than 90% until about 4:15 p.m.

This exceeded the TS requirement by approximately forty-five (45) minute _ -.

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(2) Action item b. requires that with the indicated AFD outside the acceptable operation limit of Figure 3.2-1 and with thermal power less than 90% but equal to or greater than 50% of rated thermal power, reduce power to less than 50% of rated thermal power within thirty (30) minutes and set the Power Range Neutron Flux-High Setpoints to less than or equal to 55% of rated thermal power within the next four (4) hours. Since the AFD indication was not identified, power was not reduced to less than 50% within thirty (30) minutes. In addition, the power range instruments were not reset to less than or equal to 55% as specified within the required four (4) hours.

The above event is identified as a Violation 413/85-15-02:

Failure to follow required actions of TS 3.2.1.

No violations or deviations were identified except as noted above.

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6.

Surveillance Observation (Units 1 and 2) (61726)

a.

During the inspection period, the inspector verified plant operations were in compliance with various TS requirements.

Typical of these requirements were confirmation of compliance with the TS for reactor coolant chemistry, refueling water tank, emergency power systems, safety injection, emergency safeguards systems, control room ventilation, and direct current electrical power sources.

The inspector verified that surveillance testing was performed in accordance with the approved written procedures, test instrumentation was calibrated, limiting conditions for operation were met, appropriate removal and restoration of the affected equipment was accomplished test results met requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.

Typical of the surveillance items that were witnessed in part or in full were various calibrations of the nuclear instrumentation, auxiliary feedwater system testing, turbine stop valve testing, and residual heat removal system testing.

b.

The inspector received a copy of a memorandum to R. W. Starostecki, Region I from W. T.

Russell, ONRR, dated March 7, 1986, subject:

Technical Specification Interpretation Concerning Surveillance Testing Methods for Diesel Generator Lockout Features. The conclusions reached in this memo as to the proper method to conduct surveillance testing of these features were reviewed against the methods provided in PT/1/A/4350/15A and ISB, Diesel Generator 1A (18) Periodic Test. This review indicated that the method used by these procedures do perform this testing as detailed in the above memo.

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c.

During a routine review of TS the inspector noted a typographical error in Table 3.6-2.a and 3.6-2.b.

In these tables under column 3 valve SA-1# is. identified as SM-1#. This was discussed with the licensee and with the Catawba licensing project manager in NRR. The licensee has included a correction for this error in a letter to NRR dated March 7, 1986, containing amendments to Unit 1 and 2 Technical Specifications.

No violations or deviations were identified 7.

Maintenance Observations (Units 1 and 2) (62703)

a.

Station maintenance activities of selected systems and components were

observed / reviewed to ascertain that they were conducted in accordance with requirements. The inspector verified licensee conformance to the

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requirements in the following areas of inspection: the activities were accomplished using approved procedures, and functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities performed were accomplished by qualified personnel; and materials used were properly certified. Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may effect system perfor-mance, b.

The inspector requested the licensee to determine whether updated information relative to Woodward Governors has been specifically requested from appropriate vendors. This request is based on recent NRC information indicating that the manufacturer only supplies this information if specifically requested. The licensee is reviewing this matter.

This is Inspector Followup Item 413/85-15-01, 414/85-16-01:

Verification that Licensee is Obtaining Updated Information Relative to

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Woodward Governors.

c.

On January 3, 1986, the licensee identified four pipe supports that were pulled loose from their structural attachments on the steam line

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(SA) to the Auxiliary Feedwater Pump Turbine (CAPT).

A regional specialist inspector investigated this occurrence (see Inspection Report 50-413/86-06 and 50-414/86-08).

Several Duke Power Company memoranda were written in regard to the investigation of this occurrence.

The inspector reviewed these memos and has requested the licensee address several areas that do not appear to have been included. The areas that are questioned are as follows:

(1) One memo states that the steam lines are heat traced to prevent steam from condensing.

It also says that the system will be declared inoperable if the temperature drops below 220 F.

Figure 10.3.2-2 of the Final Safety Analysis Report (FSAR) Note 15 states that the heat tracing is to maintain the temperature of the line -

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at 2550 F.

There appears to be an inconsistency between these two doce ents.

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(2) All the memoranda that were reviewed by the inspector addressed damage due to water hammer or steam hammer.

If this line is allowed to cool to approximately 220 F and the steam valves suddenly opened, it appears that there could be damage due to thermal shock in addition to water / steam hammer.

(3) One of the memo's address actions to be taken if the temperature in the pipe decreases to less than 220 F.

Discussions with operations personnel on shift indicate a lack of guidance or awareness that design has specified actions to be taken for this problem.

The above items are identified as Unresolved 413/86-15-03; Questions Concerning Engineering Analysis of SA Support / Restraint Failures, pending additional review and discussion by the inspector with licensee personnel, d.

The FSAR, Sections 15.1.4.1 and 15.1.5.1 state that part of the protection provided for the accidents, associated with these sections, is a feedwater isolation signal that will rapidly close all feedwater control valves and backup feedwater isolation valves, trip the main feedwater pumps, and close the feedwater pump discharge valves. The inspector reviewed various documentation to determine the method used to perform these functions.

The licensee identified that during the construction period, the feedwater pump discharge valves had been removed.

This was accomplished by Variation Notice (VN) #50047. This finding is being identified as an Unresolved Item 414/86-16-04: Review of design change VN50047, Removal of Automatic Closure of 2 CF-10 and 2 CF-17, pending additional review by the inspector.

e.

In addition to the removal of the Automatic Closure of the feedwater pump discharge valves as discussed in 7d above, the feedwater pump turbine trip feature was also removed on Unit 2.

This change was performed in accordance with Nuclear Station Modification (NSM)

CN20084. The inspector reviewed the safety evaluation associated with the NSM which is required by 10 CFR 50.59. This safety evaluation stated no unreviewed safety question was judged to be involved or created by this modification.

In addition, it referenced only Chapter 7.0 of the FSAR as being reviewed.

10 CFR 50.59 (b) requires that the records of changes to the facility include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question. There was no bases provided in this NSM safety evaluation and no reference to the accidents described in Section 15.1.4.1 and 15.1.5.1 for which these features were identified to provide protection. This is identified as a Violation 414/86-16-02: Failure to provide the bases for determining that a change to the facility does not involve an unreviewed safety question.

No violations or deviations were identified except as noted above.

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Review of Licensee Nonroutine Event Reports (Units 1 and 2) (92700)

The below listed Licensee Event Reports (LER) were reviewed to determine if the information provided met NRC requirements. The determination included:

adequacy of description, verification of compliance with Technical Specifi-cations and regulatory requirements, corrective action taken, existence of potential generic problems, reporting requirements satisfied, and the relative safety significance of each event. Additional implant reviews and discussion with plant personnel, as appropriate, were conducted for those reports indicated by an (*).

The following LERs are closed:

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LER 413/84-03 and Control Rod Drive Assemblies Removed

413/84-03 Rev 1 Improperly LER 413/85-57 Comparison of Digital Rod Position to Demand Position Not Performed l

LER 413/85-65 Auto-Start of Auxiliary Feedwater

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During Testing of Reactor Trip Breakers

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LER 413/85-66 Mode Changes Made With Inoperable

Equipment Due to Mishandling Work Requests LER 413/85-67 Reactor Trip on Loss of Main Feedwater

Pump Due to Design Deficiency No violations of deviations were identified.

9.

Information Meetings with Local Officials (Units 1 and 2) (94600)

A meeting was held with local Rock Hill city government officials on March 4, 1986.

This meeting was conducted to familiarize the local officials with the mission of the NRC, to introduce key NRC personnel associated with Catawba, to discuss lines of communications available between local officials and the NRC, and to discuss the status of the facility and related community concerns with these local officials. A copy of general information was provided to the mayor and council members.

The following local officials were present:

Betty J. Rhea, Mayor Bidwell Ivey, Councilman

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Henry T. Wood, Councilman 10.

Preparation for Refueling (Unit 1) (60705)

The inspector reviewed preparations for refueling of Unit 1 presently scheduled to commence in August 1986.

This review was concerned only with the receipt, inspection and storage of new fuel in the fuel storage area.

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This process was performed in accordance with approved procedures and used

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instrumentation that had been recently calibrated in accordance with calibration requirements.

In addition, the inspector reviewed training records of various personnel handling the new fuel and crane operations.

Four fuel assemblies were observed (D-04, 0-19, D-26 and D-34).

No violations or deviations were identified.

11.

Inspector Witnessing of Initial Fuel Loading (Unit 2) (72524)

The inspectors witnessed fuel loading operations to verify that a well coordinated effort was conducted in accordance with procedure and - TS Requirements. The inspectors witnessed the installation of the first five bundles, the last 13 bundles and additional bundles on an intermittent

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basis.

No violations or deviations were identified.

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Preoperational Test Program Implementation Verification (Unit 2) (71302)

The inspector witnessed operational aspects of portions of selected tests associated with the preoperation program to verify that activities were well controlled, coordinated and performed in accordance with applicable procedures. Included in this review were thermocouple calibrations and running of Diesel Generator 2A for governor trouble shooting.

No violations or deviations were identified.

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Licensee Identified Items 50.55(e) (Unit 2) (W3)

(Closed) CDR 414/86-02: Diesel Generawor Valve Spring Failures. The report for this item was submitted on January 16, 1986.

The inspector verified I

that the licensee has performed appropriate inspections of the affected springs and has a long term plan to provide replacement springs. Licensee

actions are acceptable.

No violations or deviations were identified.

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14.

Previously Identified Inspector Findings (Units 1 and 2) (92701)

a.

(Closed) Inspector Followup Item 413/85-52-01, 414/85-62-01: Revision of OMP 3-1 for Senior Operator License Applications. The licensee has implemented a procedure change correcting the subject procedure. This action is acceptable.

b.

(Closed) Inspector Followup Item 414/84-42-02: Downgrading Operator Candidate Exam Results.

This item is closed based on previous inspections described in NRC Report No. 50-413/85-12.

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(Closed) Inspector Followup Item 414/84-42-04: Need to Improve NED Qual Checklist Record Keeping.

This item is closed based on previous

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inspections described in NRC Report No. 50-413/85-1 *

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d.

(Closed) Inspector Followup Item 413/84-93-05, 414/84-42-05: Review Catawba Requalification Program to Ensure it Meets Requirements of 10 CFR 55.

The inspector reviewed the licensees operator requalification program entitled Requalification Program for NRC Licensed Personnel Revision 1, dated November 27, 1984.

This review indicates that the requalification program meets the requirements of 10 CFR 55. This item.is closed.

e.

(Closed) Inspector Followup Item 413/84-93-03, 414/84-42-03: Develop Program to Ensure Licensed Personnel Periodically Perform Licensed Duties. Operations Manaaement Procedure 3-5, Revision 3, Maintenance of Operating Experience for NRC License (R0/SRO) Renewal contains guidance and documentation requirements for maintenance of licensed personnel. This identifies the frequency at which a person must stand a prescribed duty in order to maintain his licensed position. Based on the inspectors review of this procedure this item is closed.

No violations or deviations were identified.

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