IR 05000413/1987044

Insp Repts 50-413/87-44 & 50-414/87-44 on 871226-880125. Violations Noted.Major Areas Inspected:Plant Operations, Surveillance Observation,Maint Observation,Review of Licensee Nonroutine Event Repts & Refueling Activities

ML20149H373
Person / Time
Site:	Catawba
Issue date:	02/04/1988
From:	Lesser M, Peebles T, Van Doorn P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20149H352	List: IR 05000413/1987044 ML20149H349 ML20149H357
References
50-413-87-44, 50-414-87-44, NUDOCS 8802190236
Download: ML20149H373 (11)

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UNITED STATES

[60 Rio " NUCLEAR RcGULATORY COMMISSION O3s REGION 11

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..... February 4, 1988 Report Nos.: 50-413/87-44 and 50-414/87-44 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and NPF-52 Facility Name: Catawba 1 and 2 Inspection Conduc d- cember 26, 1987 - January 25, 1988 Inspectors: o// M

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Approved by: / [

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DivisionofReactorProjects SUMMARY 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 of previously identified items; review of low temperature overprassure protection, refueling activities; and Part 21 report Results: Of the nine (9) areas inspected, two apparent violations were identified in two areas. (Failure to Follow Procedure Resulting in Operation Without Emergency Power Supply for Control Room Area Ventilation paragraph 8c and failure to Maintain Auxiliary Feedwater Automatic Valves in the Flow Path Fully Open paragraph 10.)

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REPORT DETAILS Persons Contacted Licensee Employees

• B. Barron, Operations Superintendent

• F. Beaver, Performance Engineer W. H. Bradley, QA Surveillance S. W. Brown, Reactor Engineer R. N. Casler, Unit 1 Coordinator R. H. Charest, Station Chemistry Supervisor

• S. S. Cooper, Operating Engineer

• A. Cote, Licensing Specialist

• T. E. Crawford, Integrated Scheduling Superintendent W. P. Deal, Health Physics Supervisor C. S. Gregory, I. & E. Support Engineer J. W. Hampton, Station Manager

• C. L. Hartzell, Compliance Engineer F. N. Mack, Project Services :ngineer W. W. McCollough, Mechanical Maintenance Supervisor W. R. McCollum, Station Services Superintendent C. E. Muse, Unit 2 Coordinator T. B. Owen, Assistant Station Manager F. P. Schiffley, II, Licensing Engineer

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

• F. Wardell, Technical Services Superintendent J. W. Willis, Senior QA Engineer, Operations Other licensee employees contacted included technicians, operators, mechanics, security force members, and office personne * Attended exit intervie . Exit Interview The inspection scope and findings were summarized on January 22, 1988, 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 license The l licensee did not identify as proprietary any of the materials provided to '

or reviewed by the inspectors during this inspection. The following new items were identified:

J Violation 413,414/87-44-01: Failure to Maintain Auxiliary feedwater ;

Automatic Valves in the Flow Path Fully Ope j l

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Inspector Followup Item 413, 414/87-44-02: Review of Licensee Actions to Replace Vent and Drain Cap Violation 414/87-44-03: Failure to Follow Procedure Resulting in Operation Without Emergency Power Supply for Control Room Area Ventilatio . Licensee Action on Previous Enforcement Matters (92702)

(Closed) Unresolved Item 413/85-55-07: Clarification of Action Statement for TS 3. 7.10.3. The licensee has issued a Technical Specification (TS)

interpretation which appropriately clarifies how the TS will be implemented and the licensee apparently has conformed to the TS ,

requirement Therefore, this item is close +

4. Unresolved Items No new unresolved items were identifie . Plant Operations Review (Unit 1) (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 i taken to assure physical protection of the facility met current requirement Areas inspected included the security organization; the establishment and maintenance of gates, doors, and isolation zones in the proper condition; and access control and badging were proper and procedures followe In addition to the areas discussed above, the areas toured were observed for fire prevention and protection activitie These

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included such things as combustible material control, fire protection systems and materials, and fire protection associated with maintenance activitie The inspectors reviewed Problem Investigation Reports to determine if the licensee was appropriately !

documenting problems and implementing appropriate corrective action Unit 1 Summary '

Unit 1 started the report period in Mode 3 in the process of startup after EOC-2 outag An Unusual Event was declared on December 27 <

when unidentified leakage greater than the allowable value was discovered. A leak of approximately four (4) gallons per minute was discovered coming from a cracked open vent valve (1NV-499) on the .

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charging pump discharge lin The valve had been recently checked shut during post outage valve lineups. The inspectors witnessed initial criticalitv on December 29 and the unit entered Mode 1 on December 3 During power ascension at approximately 17% power operators were unable to transfer feedwater flow from the auxiliary feed nozzles to the main feed nozzles due to inability to meet ,

required feed line temperatures. The unit returned to Mode 2 in order to make a containment entry and discovered reverse purge to 3 of the 4 steam generators was isolated. The unit returned to power operations and reached 100% by January 6,1988. On January 16 the unit was forced to shutdown when it was determined that wide range resistance temperature detectors (RTO) for the reactor coolant system were not environmentally qualified. During the shutdown the reactor tripped at 1.0E-8 amps power when a control power fuse blew on one intermediate range nuclear instrument. During the cooldown a condenser circulating water (RC) piping weld failed which required the unit to enter Mode 5 for repairs. After repairs were made to the RTO's and RC piping the unit entered Mode 3 on January 23. An inadvertent safety injection occurred at 1039 when reactor coolant ;

pressure was allowed to exceed 1955 psig (safety injection unb1ccks) :

without ensuring steam line pressure was above its low pressure -

safety injection setpoin An Unusual Event was declared and the safety injection was successfully terminate Unit 1 started back up ,

on January 24. The licensee has been monitoring blowdown on 1A Steam *

Generator for a possible tube leak. Secondary activity levels have been on the order of 1.0E-7 microcuries per millilite '

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c. During Unit 1 power ascension on January 1,1988 operators were unable to meet minimum temperature requirements of the main feed lines in order to transfer main feedwater from the auxiliary feed .

nozzles to the main feed nozzle Investigation revealed the reverse purge from three (3) of the four (4) steam generators had been i isolated, although OP/1/A/6100/01, Controlling Procedure for Unit Startup, requires it prior to pressurizing the steam generators. The !

cause for the out of position valvet eas the failure to use proper administrative controls during contair, ment integrity verification As described in Catwba iluclear Station Memorandum for File dated October 3,1984, reverse purge is necessary to keep main feed containment penetrations above 115 degrees F to avoid fracture of the penetration when it is pressurized. This is to meet requirements of General Design Criterion 51, Fracture Prevention of Containment Pressure Boundary. The licensee was able to show that although the steam generators were pressurized, the penetrations were not pressurized, therefore damage to the penetration would not have occurred nor was a design evaluation required. The licensee did determine that it needed to improve its methods for ensuring reverse purge during plant heatup and will revise OP/1 (2)/A/6100/01 to require periodic monitoring of main feedwater temperature. The licensee will clarify procedures to require Removal and Restoration controls on valves that are found to be out of position during containment integrity verifications.

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! The inspectors expressed concerns to plant management regarding the adequacy of plant labeling. This concern was based on field observations of non-readable, inconsistent or absent labels on various valves and other plant equipment as well as plant events - i involving inadequate labeling. A recent Licensee Event Report (LER)  !

414/87-30, Feedwater Isolation Due to Isolating Wrong Component, i resulted from inadequate labeling. The licensee indicated that an  ;

improved labeling program has been developed in response to an INP0  ;

finding. The inspectors reviewed the licensee's plant labeling  :

program as described in Station Directive 3.0.5. , discussed labeling j efforts with the Superintendent of Technical Services and other  ;

licensee personnel and observed sample labeling. The licensee has  ;

committed to INP0 to label plant components both inside and outside- t containment by June 1989. As a result of the incident described in  !

LER 414/87-30, all safety related instrument root valves will also be j labeled with information identifying all components which might share  ;

that impulse line. The licensee s Superintendent of Operations  !

indicated that other Human Engineering (HE) improvements are also in  :

progress. An improved Emergency Procedure (EP) writers guide is  !

being utilized to review and improve HE aspects of all EP's. The new l EP's will be verified on the new simulato A'so an agreement was :

reached with Design Engineering to issue drawings for each control  :

i room gauge and controller to assure consistent HE practices including ,

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labeling are maintaine j

During a detailed walkdot,n of the Auxiliary Feedwater (CA) System,  ;

the inspectors noted that caps, required by drawings, were missing on ,

pipe nipples for vent and drain valves. Four examples were noted for  ;

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valves ICA80, 83, 148 and 211. Although this does not appear to be a safety problem, the caps are used to prevent unwanted material from entering the nipples and to protect the threaded portion of the i nipples. The licensee responded to the inspectors' concern by  :

surveying several areas for this problem. Approximately 40% of l

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required caps were found missing. The licensee indicated that additional inspections would be made, caps would be replaced and

requirements would be re-emphasized in this area. Further review of  !

licensee actions will be conducted. This is Inspector Followup Item i 413, 414/87-44-02

Review of Licensee Actions to Replace Vent and Drain Cap No violations or deviations were identified.

t 6. Surveillance Observation (Units 1 & 2) (61726)

i 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,

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safety injection, emergency safeguards systems, control room l

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ventilation, and direct current electrical power source The inspector verified that surveillance testing was performed in accordance with the a) proved 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 personne The inspectors witnessed or reviewed the following surveillances wholly or in part:

PT/2/A/4600/17 Surveillance Requirements for Unit 2 Shutdown OP/0/A/6100/06 Estimated Critical Rod Position PT/1/A/4150/10 Boron Endpoint Measurement PT/1/A/4150/118 Control Rod Wor':h Keasure by Rod Swap PT/1/A/4150/12A Isothermal Temperature Coefficient of Reactivity PT/1/A/3670/01B Diesel Generator Load Sequencer Timer Calibration Snubber Testing No violations or deviations were identifie . Maintenance Observations (Units 1& 2) (62703) 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 requirements in the following areas of inspection:

the activities were accomplished using a9 proved procedures, and functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities aerformed were accomplished by qualified personnel; and materials usec 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 performanc i

' The inspectors witnessed or reviewed the following maintenance activities wholly or in part:

24251 OPS Repair Failure of Steam Dumps to Open 19128 OPS Repair Body to Bonnet Leak on INV-291 Manipulator !

Crane Repairs j No violations or deviations were identifie !

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t 8. . Review of Licensee Nonroutine Event Reports (Units 1 & 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 Specifications and regulatory requirements, corrective. action taken, existence of potential generic problems,  ;

reporting requirements satisfied, and the relative safety  :

significance of each even Additional .inplant reviews and ;

discussion with plant personnel, as appropriate, were conducted fo i those reports indicated by an (*). The following LERs are closed: j

• 413/87-32 Both Trains of Vital Batteries Inoperable Due To l Missed Retest Requirements j

• 413/87-41 Semi Annual Non-Prelubed Start Test For Diesel ;

Generators 18 and 2B Missed j

• 413/87-44 Technical Specification Violation Due To l Personnel Error 414/87-27 Manual Reactor Trip Due To Feedwater Control Valve Circuit Card failure

• 414/87-30 feedwater Isolation Caused by Hi Hi Steam

. Generator Level Signal Due To Personnel Error and Installation Deficiency 4' In LER 413/87-41 the licensee reported missing TS surveillances on the IB and 28 diesel generators requiring non-prelubed starts once every six months. The surveillances were missed due to two different

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equipment operators failing to follow pro:edures PT/1 (2)/A/4350/028,

Diesel Generator Operability Test. The missed surveillances were discovered by the licensee ori November 17, 1987 and effective

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corrective action was taken to ensure the six month surveillance is performed in the future. Although this surveillance has not previously been missed, the licensee recently had several problems generally enforcementinvolving includingdiesel generator Licensee surveillances Identified requir'ng Violations (LIV)NRC 413/87-10-03 and 413/87-30-01 and Violations 413, 414/87-25-02 and 413/d7-42-0 These two missed surveillances referred to in LER 413/37-41 occurred in June 1987, prior to recent efforts by the licensee to upgrade management controls. It is therefore appropriate that a Notice of Violation not be issue The licensee submitted a Special Report dated December 31, 1987, reporting a valid failure on Diesel Generator 18. The inspectors informed the licensee that the report was lacking in that it did not

contain all the information required by TS 4.8.1.1.3. The licensee agreed and will submit a supplemental report. As mentioned in the t

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previous paragraph, the licensee is currently implementing corrective action to im3 rove in this are The inspectors will be closely monitoring . licensee performance for improvement in the areas of diesel generator surveillances and reportin LER 413/87-44 reported an event where both trains of the Control Room Area Ventilation System (VC/YC) were without an operable source of emergency power for approximately five hours. The system is shared between units and at the time Unit I was in Mode 5 and Unit 2 was in Mode TS 3.7.6 does not specifically state that-a train of VC/YC must have an operable emergency power supply when a unit is in Modes 1-4 although one is required. This is true of many systems in TS that are not shared between units because TS 3.8.1.1, AC Sources, provides Action Statements when an emergency power supply is inoperable. TS 3.8.1.1 requires that systems that depend on the remaining operable diesel generator be operable or the plant must be in Hot Standby (Mode 3) within eight hours. Thus, although emergency power sources are required for equipment as a condition of operability, it is not so stated in the equipments' TS because the Limiting Conditions for Operation will be enveloped by TS 3.8. This applies for Modes 1-4 only. VC/YC however is a shared system so this approach cannot be used. The licensee recognized this and implemented Operating Frocedures (eaclosure 4.13 of OP/1/A/6350/02, Diesel Generator Operations) to ensure that when a diesel generator on one unit is removed from service, the associated train of VC/YC is powered from the same train of the opposite unit, otherwise the train of VC/YC must be declared inoserable. On December 1, 1987, the operator failed to follow the asove referenced procedure but tried to interpret TS 3.7.6 and incorrectly concluded that Unit 2, while in Mode 1, did not require the operating "B" train of VC/YC to have an operable emergency power suppl Since "A" train VC/YC was inoperable the errce resulted in Unit 2 operating for approximately five hours without an emergency power supply for VC/Y The licensee intends to submit an amendment to clarify TS 3.7.6. This is identified as violation 414/87-44-03: Failure to Follow Procedure Resulting in Operation Without Emergency Power Supply for Control Room Area Ventilatio One Violation was identified as described in paragraph Sc abov . Followup of Part 21 Reports (92700) (Unit 1)

(Closed) Psrt 21 Item P2185-11: Valve Actuators on Pressurizer PWR Operated Relief Valves Discovered with 1 of 2 Required Springs. Recent licensee testing during a refueling outage has shown that spring forces are such that two springs are apparently present in the valv The inspector reviewed test data with licensee personnel and no further action appears to be necessar No violations or deviations were identifie l

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10. Previous Inspector Findings (92701)

(Closed) IFI 413, 414/87-30-05: Verify AFW Lineups Meet TS Requirements The inspectors reviewed enclosure 4.9 and 4.10 of OP/1/A/6250, Auxiliary Feedwater System (CA), to determine if the procedure for cooldown of CA piping following check valve backleakage from the steam generators, meets the requirements of TS 3/4.7.1.2. These enclosures were developed to address NRC concerns expressed in IE Bulletin 85-01. The inspectors identified a number of concerns. Under certain degraded conditions, the procedure requires the operator to shut the manual pump discharge isolation valve prior to starting the CA pump, then over a period of ten minutes the manual valve is slowly opene The inspectors were concerned that this action would constitute train inoperabilit The licensee stated that the CA system has never degraded to the point where this portion of the procedure was implemented, however did agree that this would make the train inoperable and stated the procedure would be revised to ensure appropriate controls would occur. The inspectors pointed out that the procedure does not require an independent verification of the manual valve after it is re-opened although required by Operations Management Procedure 1-5, Independent Verificatio The licensee agreed this to be a requirement and stated that it would be included in the next revision.

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The method the licensee historically has used to coci the CA piping has been to clost the affected train's automatic flow control valves, start the CA pump, then throttle CA flow through the leaking check valve to cool that piping. The licensee has never considered the train to be incperable while the valves are throttled or closed. TS surveillance 4.7.1.2.1. requires that every 31 days the licensee verify that each automatic valve in the flow path is in the fully open position whenever above 10% powe The licensee has been routinely throttling the automatic flow control valves which constitutes inoperability of the associated train since the surveillance requires them to be fully open. The inspectors reviewed records to determine the frequency that this procedure has been use ,

Since May 1987 the piping cooldown procedure has been used at least five times on Unit 1 and five times on Unit 2 for periods of less than one hour to several days. On one occasion from 4:42 p.m. Novembe- 10, 1987, until 10:29 a.m. on November 23,1987, Unit 2 operated in Moat with the flow control valves on "A" train CA continuously throttled or shut, exceeding the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action statement which recu1res plant shutdown. The inspectors reviewed the Technical S cation Action Item Log (TSAIL)

printout and determined that with 'pecif<

A" train CA in this condition, "B" train CA was logged as inoperable on 3 separate occasions the longest being from 1:55 p.m. on November 17,1987, to 9:40 p.m. on November 19, 198 The turbine driven CA pump was also logged as inoperable from 10:36 p.m. on November 19,1987, to 11:30 a.m. on November 22, 198 In other cases the inspectors noted all four flow control valves (both trains) to be either fully shut or throttled while the procedure was in use.

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The licensee has stated that although the flow control valves were throttled or shut, they would receive a signal upon C' auto start to fully open, therefore the train and system would have perfo,ned as designe It

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is noted that these valves are required to be stroke time tested by the licensee's pump and valve inservice testing program every three months and i must meet a 20 second acceptance criteria. Section 15.2.8.1 of the Final Safety Analysis Report (FSAR) assumes 135 second time ielay for CA flow under accident scenarios to account far diesel generate */ pump start times and feedwater line purging. The licensee has present1J eliminated the cause for the high temperature alarms by replacing suspect check valve The insaectors also observed problems with the licensee's program for processing Technical Specification amendments for NRC approval. As early as October 1986, Operations Management was aware that the wording of this particular TS surveillance conflicted with the CA piping cooldown procedure, however, felt they were meeting the intent of the TS, that is, automatic valves be kept open when CA is in a standby readiness mod Nevertheless, Operations forwarded a request for an amendment to Compliance in an instrumentation letter dated October 16,1986, from J. H. Knuti, to allow CA flow throttling. The amendment recuest has yet .

to be forwarded to NRC for approval. While it is recogn: 2ed that '

processing TS amendment requests for submittal is cumbersome and delays are inherent, it appears there is room for improvement with better internal communications by the licensee. Of particular concern, however was management's awareness of the need for a TS change, yet continued operation in non-compliance was allowed with the assumption that the ,

intent of the TS was being met 'nd the amendment request was being

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processe This TS was specifically worded and left no room for interpreting the intent. It was emphasized to the licensee that actions such as this are unacceptable without prior approval. Inerefore this is identified as violation 413 414/87-44-01: Failure to Maintain Aexiliary FeedwaterAutomaticValvesIntheFlowPathFullyOpe '

One violation was identified as described in paragraph 10 abov . Refueling Activities (Unit 2) (60710) The inspectors verified that TS a plicable to Mode 6 were met, proper

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radiological controls, housekeep ng and foreign material exclusion practices were met and water leve control practices were followe Unit 2 started the period in Mode 5 in its first refueling outag :

The unit entered Mode 6 on January 5,198 Fuel unload was delayed i due to problems with the manipulator hoist and the core was ;

completely unloaded by January 17. On January 25 the licensee informed the ins Generators (SGs)pector ofoutag during the the statusThree of loose parts jacking found studs wereinfound Steam i in 28 SG, a rectangular spacer piece was found in 2A SG and a semi-circular torch cut sliver found in 20 SG. Three tubes were damaged as a result of these part Visual inspections were complete ;

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and additional eddy current inspections were being considere Information was forwarded to NRC:RII for revie No viohtions or deviations were identifie . Temporary Instruction 2500/19 (25019)

The purpose of this inspection was to verify that the licensee has an effective mitigation system for low-temperature overpressure transient conditions in accordance with its commitments concerning Unresolved Safety Issue (USI) A-2 The inspectors verified that the low temperature overpressure system is in accordance with license commitments and determined thn the system is designed to prevent exceeding the 10 CFR 50 Appendix G limits for the reactor pressure vessel during plant cooldown or startup. Drawings were reviewed to verify that the system would function upon loss of normal air supply, offsite power or a single safety related component failur Documentation was reviewed to determine that the system is periodically tested in accordance with Technical Specifications and that operators have received adequate trainin The inspectors reviewed the licensee's letter to NRC of Anuary 5,1985, which included a 10 CFR 50.59 evaluation to iustify Pressurizer Power Operated Relief Valve (PORV) stroke time extension to three seconds, and verified related calculations. The evaluation involved determining that the resultant pressure overshoot from a mass or heat input to the system would not exceed design limit The following procedures and tests were reviewed for acceptance:

PT/1(2)/A/4200/23A NC Valve Inservice Test IP/1(2)/A/3222/49D Hot Leg Wide Range Temperature IP/1(2)/A/3222/52C Cold Leg Wide Range Temperature IP/1(2)/A/3222/55A(B) RCS Pressure Wide Range OP/1(2)/A/6100/02 Controlling Procedure for Unit Shutdown OP/1(2)/A/6100/02 includes operating procedures while the plant is soli Pressurizer heaters are not required to be tagged out with power removed until just prior to draining the reactor coolant system. The inspectors were concerned that the plant could be solid for a lor,g time period with pcwer available to the heaters. The licensee will consider revising the procedure to disable the heaters shortly after filling the pressurize No violaMons or deviations were identifie i I

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