IR 05000413/1987014

Insp Repts 50-413/87-14 & 50-414/87-14 on 870426-0525. Violations Noted:Failure of Written Operations Procedures to Adequately Require Implementation of Security Plan Under Degraded Standby Shutdown Facility Conditions

ML20215K308
Person / Time
Site:	Catawba
Issue date:	06/08/1987
From:	Lesser M, Peebles T, Skinner P, Vandoorn P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215K269	List: IR 05000413/1987014 ML20215K266 ML20215K278 ML20215K308
References
50-413-87-14, 50-414-87-14, IEIN-86-029, IEIN-86-049, IEIN-86-052, IEIN-86-062, IEIN-86-105, IEIN-86-29, IEIN-86-49, IEIN-86-52, IEIN-86-62, NUDOCS 8706250289
Preceding documents:	ML20236L609 (5 August 1987)
Download: ML20215K308 (10)

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i A UNITED STATES '

, [' s stroo,Do .. NUCLEAR REGULATORY COMMISSION

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$ -jf 101 MARIETTA STREET,

* 's ATLANTA, GEORGI A 30323

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Report Nos. 60-413/87-14 and 50-414/87-14 l

, Licensee: , Duke Power Company  !

'422. South Church Street j h

. Charlotte, N.C. 28242 Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and NPF-52 i Facility.Name: Catawba.1 and 2

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. Inspection Conducted: April 26 - May 25, 1987 '

Inspec, tors: . u w /eM/$F')

P. T.,VanDoorn '

Date Signed P. In Sk nner'

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Dith Signed j h )t n M. S.: Lesser

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Date Signed j Approved by: h, ,& h A Mlt, A _ d&dM T.~A. Peebles,.Section Chief / 'g Date' Signe Projects. Branch 2 4 Division-of Reactor. Projects- ,

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SUMMARY '

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i Scope: This ' routine. unannounced inspection was' conducted on site inspecting in the ' areas of - review of plant" operations;' surveillance observation;-

maintenance observation; review of' licensee nonroutine event reports; followup l of previously identified items; and!. followup of Information Notices, j Results: Of the six (6) areas inspected, one apparent violation was identified in one area. (Failure of Written Operations Procedures to Adequately Require Implementation of the Security Pl an Under Degraded SSF Conditions -

paragraph 3). One Unresolved Item was also identified (paragraph-5f).

8706250289 B70609 3 ,

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REPORT DETAILS Persons Contacted Licensee Employees J. W. Hampton, Station Manager

• H. B. Barron, Operations Superintendent W. F. Beaver, Performance Engineer W. H. Bradley, QA Surveillance S. Brown, Reactor Engineer l B. F. Caldwell, Station Services Superintendent R. N. Casler, Operating Engineer R. H. Charest, Station Chemistry Supervisor

• A. Cote, Licensing Specialist 4

• T. E. Crawford, Integrated Scheduling Superintendent 1 W. P. Deal, Health Physics Supervisor i C. S. Gregory, I.& E. Support Engineer C. L. Hartzell, Compliance Engineer J. Knuti, Operating Engineer F. N. Mack, Project Services Engineer W. W. McCollough, Mechanical Maintenance Supervisor C. E. Muse, Operating Engineer F. P. Schiffley, II, Licensing Engineer

• G. T. Smith, Maintenance Superintendent J. Stackley, I. & E. Engineer D. Tower, Shift Operating Engineer

• R. F. Wardell, Technical Services Superintendent

• R. White, Chairman, Catawba Safety Review Group Other licensee employees contacted included technicians, operators, mechanics, security force members, and office personnel . ]

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• Attended exit intervie l 1 Exit Interview l

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The inspection scope and findings were summarized on May 27, 1987, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding 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 inspectio The following new items were identifie Violation 413,141/87-14-01: Failure of Written Operations Procedures to Adequately Require Implementation of the Security Plan under Degraded SSF Condition ' '

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Litensee Identified Violation 413/87-14-02: Failure to Perform Inservice

. Testing of Residual Heat Removal ~ Check Valve Unresolved Item 414/87-14-02: Nonconservative Calibration of Power Range Nuclear Instrument ..

^ Licensee Action on Previous Enforcement Matters (92702)

a .- (CLOSED) Violation 413/86-05-04: Two' Examples of Inadequate Maintenance Procedures. ~ The licensee' responded to- this item in'

correspondence dated May 5, .198 The actions described in this response were reviewed by the inspector and based.on this resiew this item is close (CLOSED) . Violation 413/86-24-02, 414/86-26-02: Failure to Provide i Adequate Procedures Resulting in a Violation of TS 4.6.1.la. The I licensee responded to this item in correspondence dated August 20, !

198 The inspector reviewed the response .and verified that corrective actions were complete (CLOSED) Unresolved Item 413/86-51-05: Inadequate Incident Investigation Report C86-161-1 and Subsequent LER 413-86-59. The licensee submitted adequate revisions ' to the above' reports which clarified the event, elaborated on the root cause, and ' identified additional and appropriate corrective action. Based on this e.ction, this item.is closed. ' (CLOSED) Violation 414/87-05-05: Failure to Comply with Technical Specification 3.6.3 Associated with Inoperable Containment Isolation'

Valve.2BB8A. The licensee. responded.to'this item'in correspondenc dated April 8, 1987. 'The inspector reviewed' the response and verified that corrective actions were complete (CLOSED) Unresolved Item 413/87-10-02: Potential Failure to Implement Procedures for a Degraded Standby Shutdown Facility (SSF). On 1 April 10,1987, the inspector noted that the Standby Shutdown Facility Standby Makeup pump for Unit 1 was logged inoperable in the '

Technical Specifications Action Item Log (TSAIL), placing the SSF in a degraded condition. The inspector pointed .out .to the Shift Supervisor that the applicable portions of the Security Plan under degraded SSF conditions had not been implemented. The Shift Supervisor verified that the Security Duty' Team Supervisor had not been informed by Operations of the degraded SSF and corrective action was immediately taken to implement the Security Plan. The SSF had been in a degraded condition from approximately 8:20 a.m. - 1:15 ,

without the required security precautions. Operations failed to notify the Security Duty Team Supervisor of the condition as required by enclosure 4.7 of OP/0/B/6100/13, Standby Shutdown Facility Operations. The licensee determined that its written procedures were inadequate in that there was no reference or requirement for Operations to implement enclosure 4.7 of OP/0/B/6100/13 when

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declaring the Standby Makeup Pump inoperabl This coutitutes a violation of Technical Specification 6.8.1, and is identified as Violation 413,414/87-14-01: Failure of Written Operations Procedures to Adequately Require Implementation of the Security Plan Under Degraded SSF Conditions, (OPEN) Unresolved Item 414/87-10-02: Review of Possible Safety l Significant Problem Involving Safety Injection System. The licensee Design Engineering Division (D/E) has evaluated the valve lineup previously performed to relieve pressure in the Safety Injection l System (NI) discharge header. The condition was apparently an ;

unanalyzed condition but the NI System was operable. Procedural guidelines were recommended to prevent contamination of the Refueling Water Storage Tank (RWST) during the recirculation phase, however, contamination of the RWST due to the existing lineup was not addresse Site health physics personnel have recently sampled the air space at the top of the RWST and have measured noble gas concentrations greater than 500 times the public MPC limit. At this concentration approximately 100,000 cubic feet per minute outflow would be needed to reach the site boundary limit. Although the tank is vented to atmosphere, appreciable outflow does not occur. This concentration was higher than expected due to the abnormal valve alignment which had been performed. Therefore site personnel have requested D/E to evaluate the situation. This item remains open pending this evaluatio One violation was identified as described in paragraph 3.e. abov . Unresolved Items *

A new unresolved item is identified in paragraph 5.f., Plant Operations Review (Units 1 & 2) (71707 and 71710) The inspectors reviewed plant operations throughout the reporting period to verify conformance with regulatory requirements, Technical Specifications (TS), and administrative controls. Control room logs, danger tag logs, Technical Specification Action Item Log, and the removal and restoration log were routinely reviewed. Shift turnovers were observed to verify that they were conducted in accordance with approved procedure The inspectors verified by observation and interviews, the measures taken to assure physical protection of the facility met current requirements. Areas inspected included the security organization, the establishment and maintenances of gates, doors, and isolation zones in the proper condition, that access control and badging were proper and procedures followe *An Unresolved Item is a matter about which more information is required to

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determine whether it is acceptable or may involve a violatio *

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In addition to the areas discussed above, the areas toured were observed for fire prevention and protection activitie These included such things as combustible material control, fire protection systems and materials, and fire protection associated with maintenance activities, The inspectors reviewed Problem Investigation Reports to determine if the licensee was appropriately documenting problems and implementing appropriate corrective actions. i b. The inspectors conducted a detailed walkdown of portions of the l Nuclear Containment Spray Systems and portions of the Residual Heat l Removal Systems for both Unit j c. Unit 1 Summary l l

The unit began the period at 100% power and ran until May 22, 1987 l when the Unit was shutdown to fix Reactor Coolant (NC) System leakage l from the C Resistance Temperature Detector bypass manifold at a valve and an instrument fitting. The Unit was restarted on May 23, 198 d. Unit 2 Summary Unit 2 began the period at 100% power also. The plant was manually a tripped from 100% power on May 6, 1987 due to loss of air cooling to )

the NC Pump motors. The loss of cooling occurred when a cooling I water valve closed while personnel were replacing a breaker. The NC !

Pumps were tripped and the plant cooled down as expected via natural )

circulation. The unit was restarted on May 7,1987. On May 8, 1987 the unit was manually tripped from 65% power due to impending 10-10 level in a steam generator (SG) from a failed closed main feedwater regulation valve. The unit was restarted on May 9, 1987, and remained on line for the remainder of the period, e. On May 1,1987 the inspector noted that Construction Division tags were being used in several areas of the plant. The inspector discussed this with Operations and Construction personnel and was assured by the plant manager that use of these tags would be discontinued for plant equipment and that only operations tags would be used. This will assure that Operations is aware of equipment status, f. On April 29, while observing shift turnover, the inspector questioned operators why Unit 2 was being held at 97% power. The inspector was told that during a power increase from 90%, the operators noted that Megawatt output from the main generator had reached its expected 100%

value while Power Range Nuclear Instruments (PRNI) and Reactor Thermal Power indicated 97%. (Reactor Thermal Power is determined from a secondary calorimetric and displayed on the Operator Aid Computer.) Calibration of the PRNI's to Reactor Thermal Power had

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...' just been completed prior to the power increase and the operators were concerned .that 'the PRNI's had potentially been calibrated in a non-conservative direction. This was later confirmed to be the case when _it was determined that the S/G Auxiliary Feedwater Nozzle Tempering Control Valve, 2CF100, had been incorrectly opened following a recent Turbine Acceptance Test. A small percentage o feedflow w's a not being accounted for by feed flow instruments, the effect being the Reactor Thermal Power calculation was approximately 3% lower than actual Reactor Thermal Power. Prior to identifying this valve error the Shift Supervisor (SS) had ordered the PRNI gains to be raised to indicate 100% power while lowering Megawatt output slightly. The SS reasoned that this action ensured the Power Range Neutron Flux High Setpoint was not in a non-conservative directio The licensee applied Technical Specification (TS) 2.2.1 to the event to determine if the High Setpoint was 'ever outside the Total i

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Allowance as determined by Equation 2.2-1. The licensee has.shown in Memorandums dated May 14, 1987 and May 19, 1987 that the Total Allowance was never exceeded. The inspector has asked for assistance from Region II in clarifying T.S. 2.2.1 and the terms in equation 2.2-1. The inspector has additionally asked the licensee for an evaluation of precautions to take prior to calibrating PRNI's. _ This is identified as Unresolved Item 414/87-14-02: Nonconservative Calibration of Power Range Nuclear Instruments pending licensee evaluation to prevent recurrence and NRC interpretation of . j No violations or deviations were identifie . Surveillance Observation (Units 1&2)(61726) 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 storage tank, emergency power systems, safety injection, emergency safeguards systems, control room ventilation, and direct current electrical power source The- ;

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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, The inspector observed the following surveillance activity:

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PT/1A/4250/028 Turbine Valve Movement Test i

The inspector reviewed the following surveillances for acceptance: j

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PT/2/A/4200/30A MSIV Inservice Test PT/2/A/4200/17 BB Valves Inservice Test

No violations or deviations were identifie . Maintenance Observations (62703) Station maintenance activities of selected systems and components were observed / reviewed to ascertain that they were conducted in accordance with requirement The inspector verified licensee conformance to the requirements in the following areas of inspection:

the activities were accomplished using approved proceduras, 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 i personnel; and materials used were properly. certified. Work requests were reviewed to determine status of outstanding jobs and to assure t that priority is assigned to safety-related equipment maintenance which may effect system performanc The inspector observed the following maintenance activities:

MP/0/A/7150/60 Seal Injection IA Filter Replecement 5273 SWR Semiannual Preventive Maintenance on 2A2 Component Cooling Pump The inspector reviewed various maintenance work requests on RHR hot !

leg suction valves and MSIV actuator , Based on a Potential Generic Item (87-02) identified by NRC, the inspector reviewed the licensee's requirements for 0-Ring lubricant i on Main Steam Isolation Valve (MSIV) air actuators. Although the l licensee has not yet developed detailed procedures for the MSIV actuators since work has not yet been required, the manuals for the MSIV's do specify the appropriate lubricant. The inspector informed l the licensee of the problem at another plant and indicated that the other plant had found that the lubricant should be applied sparingl The licensee indicated that they would consider this problem in development of the maintenance procedure No violations or deviations were identified.

( 8. Review of Licensee Nonroutine Event Reports (Units 1 & 2) (92700)

l The below listed Licensee Event Reports (LER) were reviewed to L determine if the information provided met NRC requirements. The determination included: adequacy of description, verification of 1 compliance with Technical Specifications and regulatory requirements, 3 corrective action taken, existence of potential generic problems, _ - _ _ _ _ -

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l reporting requirements satisfied, and the relative safety significance of each even Additional inplant reviews and discussion with plant personnel, as appropriate, were conducted for those reports indicated by an (*). The following LERs are closed:

*413/86-05 Re Both Trains Control Room Ventilation Inoperable l

Following Loss of Chilled Water Makeup due to Design Deficiency and Equipment Malfunction L *413/87-12 Rev,1 Unit Shutdown Resulting from PORV's Inoperability

) due to Design / Installation Deficiency and

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l l *413/87-14 Technical Specification Violation Because l Inservice Inspection of Valves was not Performed due to Management Deficiency (LIV issued, par ,b.) ,

• 413/87-15 Reactor Trip Caused by Unexpected Closure of Main  !

( Feedwater Isolation Valve due to Installation l Deficiency l l

413/87-16 Manual Opening of Reactor Trip Breakers due to l Equipment Failure 413/87-17 Inoperable Fire Barrier Penetration due to Defective Procedures

• 414/86-49' Safety Injection on Spurious Low Steam Line Pressure due to Dirty Contacts in 7300 Process Control Cabinet

• 414/87-02 Rev 1 Reactor Trip due to Accidental Shorting of Test Cable and Auxiliary Feedwater Start due to Personnel Error i

• 414/87-08 Rev. 1 Technical Specification Violation due to a Design Deficiency in the Operator Aid Computer Reactor Coolant Leakage Program (LIV issued, see Report 414/87-10)

414/87-11 Auxiliary Feedwater Auto-Start on Loss of Both Main Feedwater Pumps due to a Design Deficiency 414/87-13 Auxiliary Feedwater Auto-Start on Loss of Both Main Feedwater Pumps due to Equipment Failure 414/87-14 Unexpected Steam Generator Low Low Level Signal Actuated During Main Steam Valve Testing due to Unknown Cause

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• 414/87-16 Unit 2 ~ Shutdown due to Unidentified Leakage through Reactor Coolant Radiation Monitor Relief

' Valve LER 413/87-14 listed above involved a situation whereby both trains of the Residual Heat Removal (ND) System had to be declared

, inoperable since the Inservice Test had not been performed for~ the ND )

check valves from the RWS The licensee identified this violation I via a Testing Review Committee formed . in response to a previous violation. Therefore, the licensee is appropriately given credit for-g identifying this violatio This is Licensee Identified Violation (; 413/87-14-02: Failure to Perform Inservice Testing of Residual Heat y Removal Check Valves. This item does not require a response and is

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closed by this report since appropriate corrective actions have been-implemented, While reviewing LER 413/87-05, Rev. 1: Unit Shutdown due to Design Deficiency with Containment Air Return Fans, the inspector noted that ,

no corrective action had been defined relative to the Design i Engineering aspects of the problem. This is the second LER which was ;

i found to- be incomplete for a similar reason (ref. LER 414/86-45).

The inspector informed the licensee that these LER's would remain ,

open pending new responses and implementation of an improved- J coordination process when issues involve Design Engineering Departmen q No violations or deviations were identifie j 9. Followup of IE Notices (92701)

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The inspector reviewed the actions taken by the licensee upon receipt of ;

an:IE Notice (IEN) sent for information purposes only. The Compliance

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Engineer, at present, controls receipt and distribution of these documents j to assure appropriate personnel review the contents and determine actions j that may be required as a result. The following notices were reviewed to !

assure receipt, review by appropriate personnel, and any resulting action !

identified, documented and followed to completion:

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IE Notice 86-29 Effects of Changing Valve Motor Operated Switch Settings IE Notice 86-49 Age / Environment Induced Electrical Cable Failures IE Notice 86-52 Conductor Insulation Degradation on Foxboro Model E Controllers IE Notice 86-62 Potential Problems in Westinghouce Molded Case Circuit Breakers Equipped with a Shunt Trip IE Notice 86-105 Potential For loss of Reactor Trip Capability at .'

Intermediate Power Levels

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l 10. Previously Identified Inspector Findings (92701) l l (CLOSED) Inspector Followup Item 413/85-22-01: Review New Problem Identification Reporting and Escalation Controls Upon Implementatio The licensee has now implemented the Problem Investigation Report l program which includes an escalation proces The inspector has reviewed this program and considers the licensee l actions to be acceptable, (CLOSED) Inspector Followup Item 413/86-05-07, 414/86-07-04: l Satellite Document Control Station In the Maintenance Department Not 2 Being Maintained Up To Date. The satellite files have been modified l to remove all technical manuals. Station Directive 2.2.1, Procedure l for Records Management Revision 32 has been changed to only allow ;

equipment history, completed calibration information and purchase 'i information for test equipment to be maintained at the satellite file Based on this review, this item is closed, (CLOSED) Inspector Followup Item 413/86-47-04: Review of Licensee Action Relative to Improper Torque Valu The licensee has appropriately corrected the errant procedure. A previous evaluation had been performed which showed that no technical problem had j existed, i (OPEN) Inspector Followup Item 414/87-10-03: Review of ND Hot Leg Suction Valves Maintenance. Further review of selected work requests involving the subject valves has confirmed that these valves have stuck shut on at least three different occasions. The licensee indicated that a review would be performed to evaluate the need for an improved design or increased maintenance. This item remains open pending licensee action j No violations or deviations were identifie f i

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