IR 05000413/1989015

Insp Repts 50-413/89-15 & 50-414/89-15 on 890430-0527. Violation Noted Re Failure to Meet Overtime Restriction Requirements & Unlocked Valves.Major Areas Inspected:Plant Operations,Surveillance & Maint Observations & Plant Mods

ML20246B147
Person / Time
Site:	Catawba
Issue date:	06/27/1989
From:	Lesser M, William Orders, Shymlock M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246B146	List: IR 05000413/1989015 ML20246B144
References
50-413-89-15, 50-414-89-15, NUDOCS 8907070215
Download: ML20246B147 (10)

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NUCLEAR REGULATORY COMMISSION m

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101 MARIETTA ST., N.W.

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ATLANTA GEORGIA 30323 ;

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F LReport.Nos. '50-4'3/89-15 and 50-414/89-15

Licensee: Duke' Power Company 422 South Church Street Charlotte, N.C.

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. Docket Nos.: 50-413 and 50-414'

License Nos.: NPF-35 and NPF-52 i

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a Facility Name: Catawba Units ~1 and 2

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l Inspection Conducted: April 30. 1989 - May 27, 1989 Inspectors:

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l Approved by:

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Projects Branct 3A Division of Reactor rojects L

SUMMARY Scope:

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This routine, resident inspection was conducted on site in the areas of; review I

of plant operations; surveillance observation; maintenance observation; I

facility modifications; diesel fuel oil; review of licensee nonroutine event j

reports; and followup of previously identified items.

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'1 Results:

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In the areas inspected the licensee's programs were determined to be adequate.

One non cited violation (NCV) was identified and reviewed cori trning failure to meet overtime restriction requirements due to inattention and procedure errors.

Additional examples of a recently cited violation concerning unlocked valves (Inspection Report 413,414/89-09) were identified. This violation is not cited and the' licensee. is expected to include these valves in its response to the

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violation in report 89-09.

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8907070215 890627

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l PDR-ADOCK 05000413 l

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REPORT DETAILS l

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1.

Persons Contacted-Licensee Employees

• H. Barron, Operations Superintendent W. Beaver, Performance Engineer T. Crawford,' Integrated Scheduling Superintendent J. Forbes, Technical Services Superintendent

• R. Glover, Compliance Engineer T. Harrall, Design Engineering R. Jones, Maintenance Engineering Services Engineer F. Mack, Project Services Engineer

• W. McCollough, Mechanical Maintenance Engineer

• W. McCollum, Maintenance Superintendent

• T. Owen, Station Manager J. Stackley, Instrumentation and Electrical Engineer R. Wardell, Station Services Superintendent Othe iicensee employees contacted included technicians, operators, mechanics, security force members, and office personnel.

NRC Resident inspectors

• W. Orders

• M. Lesser

• Attended exit interview.

2.

cnresolved Items An Unresolved item is a matter about which more information is required to determine whether it is acceptable or may involve a violation. There was one unresolved item identified in this report (paragraph 8b).

3.

Plant Operations deview (71707 and 71710)

a.

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, the 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 procedures.

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i 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 in the proper conditions, and that access control and badging were proper and procedures 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 equipment, and fire protection associated with j

maintenance activities.

The inspectors reviewed Problem l

Investigation Reports to determine if the licensee was appropriately documenting problems and implementing corrective actions, i

b.

Unit 1 Summary (

The unit operated the entire period at or about 100% power.

Problems were experienced maintaining adequate boron concentration in the Cold Leg Accumulators (CLA) due to various CLA fill valve and/or check valve leakage.

The unit operated several times in the Action Statement for Technical Specification 3.5.1.1.1.

due to inadequate Boron Concentration, however, each time recovered without having to initiate a shutdown.

The licensee identified some valves which were i

not properly seated and initiated corrective action, however, other maintenance activities cannot be performed while at power due to

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ALARA considerations, c.

Unit 2 Summary

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The unit started the reporting period conducting core reload operations which were completed by May 1.

A series of problems and

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setbacks continued to hamper the licensee during the outage.

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The control rod for assembly C-9 experienced high forces during latch and drag tests and the.ssembly was removed from the core and the control rod replaced.

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After the refueling canal was drained, visual observation detected 15 control rods which were not properly locked.

The licensee had experienced some difficulties with the latching tool (borrowed from McGuire).

The refueling cavity was then refilled and the rods were re-latched and locked using the the Catawba latching tool. All rods were verified correctly locked.

On May 13 while attempting to fill the Cold Leg Accumulators

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with the 2A Safety injection (NI) pump, the motor breaker tripped several times on overcurrent.

Operators were unable to hand rotate the pump.

Disassembly revealed a piece of metal inside the pump casing which appeared to be a small section of I

pipe.

The piece was lodged in the inlet of the pump and l

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apparently caused the pump to seize.

The impeller was L

subsequently replaced.

The licensee has initiated an investigation (PIR 2-C89-192) to determine the source of the l

piece of metal and other possible effects.

After entering mode 4 on May 22, #1 seal leakoff flow from

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Reactor Coolant Pump (NCP) 20 exceeded 6 gpm when Reactor Ccciant pressure was raised to 1300 psig.

After several attempts to " jog" the seal, the decision was made to re-work it.

The unit was cooled down and mode 5 was entered on May 23.

The unit ended the reporting period in mid loop-operations starting work on the NCP 2D seal.

d.

Unsecured Locked Valves On the afternoon of May 17, 1989 during a tour of the Unit i diescl generator rooms, it was discovered that valves 1 RN 948 and 1 RN 953, the nuclear service water outlet throttle valves on 1Al and 1A2 diesel generator starting air compressor after coolers, were not locked in the throttled position as is required by procedure OP-0-A-6400-06C. The valves were found with locked chains around the T handles, but the chain was loosely wrapped and was easily removed.

A niember of the licensee staff was accompanying the inspector, witnessed the event and reported it to the control room. Operators subsequently secured the valves.

This event constitutes a violation of procedural requirements and accordingly, Technical Specification 6.8.1.

However, in as much as the licensee received a violation in report 50-413/89-09 item number 89-09-01, for an unsecured chain-locked valve and in consideration of the NRC's policy for not issuing a violation for an issue for which a violation has already been cited but for which the licensee has not responded with proposed corrective actions, no Notice of Violation will be issued.

Rather, the licensee is expected to include in the response to Violation 50-413/89-09-01 those corrective actions to be taken to preclude recurrence of these events.

e.

Unauthorized Overtime Problem Investigation Report (PIR) 2-C89-0202 identified an employee who worked 26 1/2 hours in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period without prior approval as required by Station Directive 3.0.8 and Technical Specification (TS) 6.2.2.f.

PIR 0-C89-0194 documented an audit of time sheets from December 4, 1988 to April 30, 1989 where numerous Quality Assurance (QA)

Department personnel exceeded working hour limits without specific authorization.

The licensee also identified QA Procedure 203.05-QA-001, which governs overtime, as being in error in that 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> of work were allowed versus the TS value of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48

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hour period.

The procedure was written using the McGuire TS instead of the Catawba TS, which were incorrectly assumed to be identical.

Licensee corrective action. incibdes counselling of supervisors concerning overtime requirements and revision of the above mentioned procedure.

These examples are characterized as a licensee identified violation of TS 6.2.2.f. Non Cited Violation (NCV) 413/89-15-01:

Overtime Requirements Violations, and is not being cited'because the criteria specified in Section V.G of the Enforcement Policy were satisfied.

One.non cited violation was identified in paragraph 3e.

4.

SurveillanceObservation(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 eqaipment was accomplished, test results met acceptance criteria 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, b.

The inspectors reviewed the following surveillance:

CP/0/A/8100/57 Diesel Fuel Oil Total Particulate Determination c.

Steam Generator Power Operated Relief Valve (SV-13) Test Failure

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On May 1,1989, while verifying the operability of ISV-13, a Steam l

i Generator Power Operated Relief Valve (PORV) the valve failed to j

open..The test procedure, PT/1/A/4200/31A, isolates instrument air l

(VI) and uses the safety related nitrogen source as motive power to j

stroke the valve. The licensee determined that the nitrogen pressure regulator had been set incorrectly and could not provide the required 80 psig.

Nitrogen supply bottles had recently been changed on April 28, 1989 using IP/1/A/3030/13, Replacing PORV Nitrogen Cylinders, and (

the licensee initially suspected this work as the root cause.

Licensee interviews with the involved technicians, however, did not l

reveal any errors or lack of understanding of the procedures.

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,y Licensee review of the procedure did reveal areas where revision would, enhance 'its use and this was completed..It should be noted u

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that the licensee had voluntarily initiated increased periodic L'

' testing of ISV-13 as a condition of operability. based on concerns with the Control Components Inc. (CCI) valves.

(Inspector _ Followup-Item 413/89-07-04).

ISV-13 had been successfully tested one week previous to this event.

I The ability of ISV-13 to function on nitrogen is currently not L

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required by Technical Specifications.

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Containment Purge Valve Testing

Information' Notice-88-73 and 88-73 Supplement 1, Direction Dependent Leak Characteristics of Containment Purge Valves, described a series of' Fisher Controls International Inc. butterfly valves of which the-

' Type C leak testing method of pressurizing between the inboard and outboard containment' isolation valves may be invalid for the inboard-valve.

In response to this the licensee wrote Problem Investigation Report (PIR) 0-C89-197 to address the concern as-the test method in question is - used.

The licensee applied Technical Specification 3.6.1.9, Action Statement a., for the inboard valve assuming the valve is inoperable due to the invalid test method.

The action-

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statement requires that with any containment purge supply. and/or exhaust isolation valve open or not sealed closed, close and/or seal closed the valve or isolate the penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, otherwise'

be in at least Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The licensee considers the penetration to be isolated with the outboard valve closed and power removed and intends to maintain the valve' closed as a short term solution.

The licensee is considering several options

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as ' a -long term solution.

This is identified;as Inspector Followup Item 413/89-15-02: -Test Method for Fisher Containment Purge (VP)

Valves, pending resolution to PIR 0-C89-197.

No violations or deviations were identified.

5.

Maintenance Observations (62703)

a.

Station maintenance activities of selected systems and components were observed / reviewed to ascertain that they were conducted in accordance with the requirements.

The inspector verified licensee conformance to the 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 was assigned to safety-related equipment maintenance which may effect system performance.

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b.

The inspectors reviewed the following maintenance activity:

CE-2227 Increase Thrust Setting on ICA-58 No violations or deviations were identified.

6.

Review of Licensee Non Routine Event Reports (92700)

a.

The below listed Licensee Event Report's (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 event.

Additional inplant reviews and I

discussion with plant personnel, as appropriate, were conducted for those reports indicated by an (*).

The following LERs are closed:

• 413/88-23 Inoperability of Both Trains of Control Room Ventilation Due to a Design Deficiency

• 413/89-08 (Rev. 1)

Reactor Trip and Safety Injection During Auxiliary Safeguards Testing 414/88-18 (Rev. 1)

Feedwater Isolation While Cycling Steam Generator Power Operated Relief

• 414/88-31 Manual Reactor Trip on Decreasing Steam Generator Level Due to Design Deficiency 414/89-06 Containment Isolation Valves Opening With Associated Radiation Monitor Inoperable No violations or deviations were identified.

7.

Diesel Fuel Oil (Tl 2515/100)

The objective of this inspection was to verify that the licensee has a program in place to purchase and store fuel oil that meets requirements to support operable diesel generators in accordance with TS.

The inspector verified that the licensee has programs in place to l=

routinely determine the quality of stored fuel oil against accepted I'

standards.

The licensee uses a fuel stabilizer (NALC0 8256) which L

inhibits sludge formation, corrosion and bacterial growth.

The licensee monitors and cleans fuel oil filters and strainers on a regular basis.

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The inspector reviewed the licensee's evaluation f or applicability of

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Information Notice 87-04 concerning a fuel oil starvation event at a i

different plant.

The evaluation was performed and documented in a licensee letter dated April 21,198, from W. Gallman to R. C. Futrell and appeared acceptable.

The inspector reviewed results of fuel oil particulate sampling on the storage tanks and determined that values were within the acceptance criteria.

The inspector reviewed the basis for the Technical Specification minimum volume of fuel oil required (77100 gallons per diesel). Duke Power Company design calculation CNC 1223.59-03-002 determined that 75768 gallons would be consumed during full load operation for seven days (includes margin)

and, therefore, acceptable.

8.

Facility Modifications (37701)

a.

(Closed)

Inspector Followup Item 413,414/87-30-10:

Review of Cause For CA Valves Sticking Closed.

The licensee experienced repetitive problems with a series of valves (CA 149, 150, 151, 152) sticking closed after operation due to actuator springs sized too large. The safety function of the valves is to close.

The licensee completed modifications CC-1809 and CE-1810 to replace both units' valves to

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reduce the spring force.

In response to recent licensee concerns of increased friction on Borg Warner valves, differential pressure testing was conducted to verify operability on the Unit 2 valves.

The licensee used restricted change 37 to OP/2/A/6250/01, Condensate and Feedwater, as the test procedure which successfully tested the valves' ability to shut under 1100 psig. Based on this the item is closed.

b.

Modification CN-20442 installed a leakoff line upstream of Safety Injection (NI) pressure boundary check valves to prevent pressure buildup and relief valve chattering due to check valve back leakage.

The modification included a flow restricting orifice to limit leakoff flow to less than 1 gallon per minute (gpm) in order to ensure check valve leakage in excess of Technical Specification limits is detected.

The safety evaluation was reviewed -to ensure that leakoff flow rate would be an acceptable loss following a safety injection. The safety evaluation also recommended emergency procedures be revised to include manual isolation of the leakoff line prior to alignment for reactor building sump recirculation following a LOCA.

The inspector

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reviewed procedures and determined that the leakoff line is normally not isolated, in spite of the fact that the leaking check valves have since been repaired. The following concerns exist:

Procedures should reflect the line normally being isolated since

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check valve back leakage is an abnormal occurrence.

The licensee used a Removal and-Restoration Tagout to isolate the line by shutting 2NI-208 which accomplishes the intent.

If 2NI-208 is opened, emergency procedure EP/2/A/5000/01,

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Reactor Trip or Safety Injection, specifies that it be shut manually.following a safety injection. However, considering the location of the valve in a locked contaminated penetration room and its location (12 feet above the floor), it is questionable that the valve can be accessed prior to reactor building sump recirculation, which will occur within 20 minutes after the safety. injection.

Furthermore, PosteLOCA radiation levels in the area of 2NI-208 are greater than 100 Rem per hour and the consequences of the valve not being isolated have not been adequately analyzed, thus raising the possibility of an unreviewed safety question.

l The licensee responded to the inspector's concerns by initiating a request to Duke Power Company Nuclear Engineering for evaluation.

This is identified as Unresolved Item 414/89-15-03: Consequences of 2NI-208 Remeining Open Following a LOCA, pending completion of the evaluation.

9.

Followup on Previous Inspection Findings (92701 and 92702)

(Closed)

Inspector Followup Item 413,414/87-30-06:

Review of Passive Safety Structures in Containment.

The licensee completed Design Study CNDS-0086 to identify Nuclear Safety Related Civil Design Features inside containment.

Each item identified was reviewed to determine if the features were inspected periodically. Action items were assigned to those which were not programmatically covered and are presently being tracked on the licensee's action list file. Based on this the item is closed.

(Closed)

Violation 413,414/88-22-01:

Failure to Follow Technical Specification Requirements for Overtime.

The licensee responded to the

above violation in correspondence dated August 8,1988; September 30, l

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1988; November 15, 1988; March 29, 1989 and May 4, 1989.

The licensee revised Station Directive 3.0.8, Control of Overtime Requirements, to provide more specific requirements and guidance for station employees performing safety related functions.

The directive identifies applicable

enployees and designated personnel authorized to approve overtime in

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advance.

Based on this, the item is closed.

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(Closed)

P2188-08:

Defective Intercooler Inlet Atapter Provided As Part of IMO Delayed Standby Diesel Engine Generator.

F'.rther discussions with

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the licensee were held pursuant to corrective actions taken for failure of-the-air distribution vane on the IB Diesel c.1 August 18, 1986.

The licensee described the results of the vane failure as a trickle leak from an intercooler tube.

The licensee evaluated the trickle leak and

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determined that it was not significant enough to have prevented the engine

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from performing its safety function and therefore, the failure was not reportable.

The licensee attributed the vane failure to welds which had not achieved full penetration into the base metal.

All vanes were inspected and repaired with full penetration welds.

Based on licensee actions this item is closed.

(Closed)

Unresolved Item 414/86-30-01:

Followup of Analysis of Bussman Type FNA Fuses For Reliability.

The replacement of all safety related Bussman type FNA fuses on Unit 2 has been completed using Littlefuse type FLQ.

This was done under Exempt Change CE-2132. The licensee intends to make complete replacement of Unit 1 fuses by July 1,1989. Based on this, the Unit 2 item is closed.

No violations or deviations were identified.

10.

Exit Interview The inspection scope and findings were summarized on May 26, 1989, with those persons indicated in paragraph 1.

The inspector described the areas inspected and discussed in detail the inspection findings listed below.

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.

Item Humber Description and Reference NCV 413/89-15-01 Overtime Requirement Violations (paragraph 3d)

IFI 413/89-15-02 Test Method For Fisher Containment Purge (VP) Valves; IEN 88-73 (paragraph 4d)

UNR 414/89-15-03 Consequences of 2NI-208 Remaining Open Following a LOCA (paragraph 4d.)

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