IR 05000413/1989030
| ML19332C049 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/07/1989 |
| From: | Jape F, Matt Thomas NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19332C044 | List: |
| References | |
| 50-413-89-30, 50-414-89-30, NUDOCS 8911220244 | |
| Download: ML19332C049 (12) | |
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M Nrog'o-UNITED STATES -
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NUCLEAR REGULATORY COMMISSION '
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n REGION 11
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101 MARIETTA STREET N.W.
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. ATLANTA, GEORGI A 30323 l
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Report Nos.:- 50-413/89-30 and 50-414/89-30
. Licensee: Duke Power Company.
k 422 South Church Street
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. Charlotte, NC. 28242
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. Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and NPF-52-
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Facility Name:
Catawba 1 and 2 Inspection Conducted: October 2-6, 1989
Inspector:
v> h M>uf4,
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M. Thomas,:T@am Leader Date Signe F Team Members S. Ninh
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R. Wright L. Zerr
~ Accompanying Personnel:
F. Jape Approved by:
CIA 4 h/d4 A/7/
Quality Performance Section[/- /
F. Jape,4ection Chief Date Signed Division of Reactor Safety
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SUMMARY
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Scope:
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This routine, unannounced inspection was in the-areas of design, design changes. plant modification', and licensee action on previously identified
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inspection findings.
Results:.
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Independent reviews of completed NSM packages were performed to determine their adequacy.
NSMs were prepared and installed in.accordance with DE program
requireme 2s and applicable industry codes and standards.
Safety evaluations I
performed in accordance with the requirements of 10 CFR 50.59 were thorough and technically adequate.
Adequate engineering support is being provided to Nuclear Production by engineering personnel as is evident by the coordinated efforts in the resolution and reduction in the number of SPRs and TSMs.
Another positive indication of the licensee's on-going efforts to improve
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engineering support is the establishment of system and component experts within J
the plant Performance and Maintenance Engineering groups.
8911220244 891115 f
PDR ADOCK 05000413
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One weakness was identified with the implementation of a TSM which resulted in the following non-cited-violation being identified and reviewed during this
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inspection: NCV 414/89-30-01, fa11ure to follow procedur? during the implement-ationofaTSM.(paragraph 4).
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Another weakness noted. by the inspectors concerned the length of. time and amount of effort expended to develop adequate corrective. actions to correct a nuisance alarm-involving the D/P across the strainers in the suction piping to the FD' pumps.
No other violations were-identified in the areas inspected.
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REPORT DETAILS 1.
Persons Contacte:d Licensee Employees
- J. Aycock, Projects Engineer, Mechanical / Civil J. Barbour, QA Director Operations W. Beaver, Performance Manager
- W. Bradley, QA Verification Manager
- R. Casler, Operations Superintendent
- T. Crawford, Integrated Scheduling Superintendent f*J. Forbes, Technical Services Superintendent
- T. Harrall, Design Engineering Site Office
- R. Jones, Maintenance Engineering Services Manager
- V. King, Compliance Staff R. Mack, Projects Manager
- S. Martin, Projects Staff
- G. Rogers, Projects Engineer, Instrumentation / Electrical
- Z. Taylor, Test Engineer Other licensee. employees contacted during - this inspection included engineers, operators, technicians, and administrative personnel.
Other Organizations NRC Resident. Inspectors
- W. Orders, Senior Resident Inspector
- M. Lesser, Resident Inspector
- Attended. exit interview
- Contacted via telephone on October 12, 1989 Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2.
Design, Design Change, and Modifications (37700, 37828)
I a.
The inspectors reviewed the NSMs listed below to determine the adequacy of the safety evaluations performed to meet 10 CFR 50.59 requirements; verify that the NSMs were prepared and installed in accordance with DE program requirements and applicable industry codes and standards; verify that the NSMs were reviewed and approved in accordance with TS and administrative controls; ensure the subject modifications were installed (for those physically inspectable) in accordance with the applicable NSM packages; applicable plant operating documents (drawings, plant procedures, FSAR, TS, etc.) were revised to reflect the subject modifications; the modifications were reviewed and incorporated into operations training program as
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applicable; and post modification test requirement were specified and adequate testing was performed.
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(1) NSM CN-10608, Revision 0, Revise Control Circuits for valves to l
block them from repositioning when an SI signal is received
with controls at-the ASP.
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The package that the inspector selected for review was:CN-10608
which revised the control circuits for a number of valves
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(NI-9A, NI-10B, KC-56A, KC-81B, NF-228A, NF-233B, NF-234A, j
.1NW61B, etc.) to block them from repositioning when a safety injection signal is received with control at the auxiliary i
thutdown panels (ASP).
Repositioning of these valves makes a
controlled safe cooldown from the ASP's difficult.
The
inspector reviewed the completed modification and determined that it meets with NRC's guidance on the subject. The post modific-ation test was well designed, and barring an actual J
shutdown /cooldown from the ASP, represents a good integrated test
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of the modifications.
However the inspector expressed concern over the length of tine it took the licensee to implement these modifications.
On March 4,1985 the station. problem' report i
suggested that this modification be performed during the first refueling of Unit 1, where as the actual modification wasn't
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completed. until 1989.
Based on this modification and the subsequent tests the inspector determined there is sufficient justification for closing open item 413/85-04-03 which is' listed
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in paragraph 6.a.
(2) NSM CN-10881, Revise Tank Level Instrument Scheme for the Boric
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Acid Tank (BAT) by Utilizing a References Leg-Type Installation.
This NSM was initiated to modify the BAT level instrumentation to more accurately indicate the boric acid l evel ~.
The level of the Unit 1 BAT was not being accurately indicated by the installed differential pressure (level.)
transmitter, due to the fact that the tank was not always vented to the atmosphere,
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Radwaste chemistry required the tank vent to be locked closed to prevent gaseous release. Consequently, inaccuracy occurred as a result of pressure buildup under the tank's diaphragm which was was not capable of handling a.two phase (liquid-gas) g design sensed as additional liquid level.
Since the existin system, erroneous tank level indications were received by the control
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room, auxiliary shutdown panels, and process control cabinets.
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Accurate BAT levels are essential to prevent Technical Specification (TS) violations discussed in sections 3.1.2.1,
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3.1.2.2, 3.1.2.5 and 3.1.2.6 of the Catawba TS. To ensure that a minimum volume of borated water was contained in the BAT per TS 3.1.2.6 (Modes 1, 2, 3, and 4) and per TS 3.1.2.5 (Modes 5 and 6) only one of the two existing instrumentation channels was taken out of service at a time. To correct the deficiency, the low pressure tap of the differential pressure transmitter was connected to the gas space under the diaphragm providing a reverse acting transmitter system that measured only the pressure due to the liquid level.
A pressure gauge was added by VN
- CP 0094 to allow monitoring the tank gas space pressure.
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Four additional VNs were. written on this modification, two
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VNf CC2603 and CC2597) as a. result of interferences, one j
VN #CC2606)'to improve the initial modification design and one VN #CP239) apparently due to an oversight of an electrical drawing that needed to be changed. The new tubing fittings and valves were properly hydrostatically tested per implementation
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procedures as specified by drawing CN-1499-NV 22.02, Revision A, i
Note.15.
Post modification testing included calibration of the
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pressure transmitters-and performance of string checks. for -
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loops-INV 5740, 5741, 6070 and 6071 as necessary. This testing was performed-per Work Request hos.-12111NSM-1 and 12112NSM-1.
The implementation of this modification did not. require any
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change to the TS~or create any unreviewed safety questions.
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Inspection of this modification to the -tbove listed review
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criteria -resulted in no violations or deviations being l"
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identified.
(3) NSM CN-11014 Revision 0,
Relocate Letdown Relief Valve INV014.
VNfCE-1207 was implemented to replace the old relief valve with the new identical valve due toLthe valve
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lifting erratically and causing high flow to the pressurizer relief tank. Since the valve was replaced and the problem still existed. NSM CN-11014 was developed and installed in response to the existing' problem. The NSM provided the design to eliminate the' erratic. operation of the valve due to its present location near the letdown flow orifice.
The design objective included relocating relief valve INV014 to a more suitable area without affecting its function or capabilities; and deleting valve INC263, a construction drain valve no longer required-for plant
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operations.
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The inspectors reviewed the above NSM package and determined that the safety evaluation performed in accordance with the requirements of 10 CFR 50.59 was detailed.and thorough; the i
design basis calculation No. CNC-1206.02-83-0039, Rigorous stress analysis of piping math model NV-01 and the design basis - calculation No. CNC-1206.12-29-1044, Catawba Unit 1 piping supports for math model NV-01 were partially verified and found to be acceptable. The post modification test requirements were. reviewed and found to be satisfactory; and the affected procedures and drawings were updated to reflect the change.
t (4) NSM CN-20486, Revision 0, Replace Diesel Generator Emergency Trips This NSM was written to replace the vendor supplied pneumatic shutdown logic system on the EDGs with a DPC designed electrical logic system.
The pneumatic shutdown logic system on the EDGs had proven unreliable and led to forced shutdowns, outage extensions, and extended EDG down time.
The modification deleted the pneumatic logic for the LO-L0 Lube Oil and Overspeed trips and replaced it with electrical logic. Modification of the Unit 1 EDG was performed under NSM CN-11104, Revision 0.
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i The inspectors concluded from reviewing the above NSMs'that the-quality and technical content of the information contained in the NSMs. reviewed was good.
System and/or component functions and
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performance requirements were clearly stated.
The safety
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evaluations were detailed and thorough.
The post modification test requirements specified for the applicable NSMs were. adequate.
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There was evidence of discussions and interface between site
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personnel and DE personnel.
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Exempt Changes
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The licensee utilizes _ the exempt change process to perform minor permanent changes or resolve minor discrepancies. The exempt changes are normally prepared on-site by the Project Services-Group, but are
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reviewed by DE prior to implementation. The inspectors reviewed the exempt changes in accordance the criteria discussed above for NSMs.
The following exempt changes were reviewed.
(1) CECN-1019 The inspector randomly chose CECN-1019, FD Check Valve Internals just one of several packages (pector found this package to be Removal, for review.
The-ins i.e. CE-0101, - 0466,-0501,
-0502,-0589,-1345,-1346) developed to correct a " nuisance" alarm involving the D/P across the strainers in the suction piping to the FD pumps.
o A number of corrective actions have been proposed and implemented over the past several years in an attempt to correct the nuisance alarm rather than correcting the problem which is causing the alarm.
Engineering recommendations have consisted primarily of raising the setpoint in order to clear the alarm, and upon further
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evaluation, the subsequent lowering of the setpoint due to filter
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crush point and NPSH considerations.
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Prior to CECN-1019 the latest engineering recommendation was to
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return the D/P setpoint back to the original recommended setpoint of 3.5 psid. CE-1019 removed check valve internals for
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spring loaded check valves 1FD25 and IFD65, which are located in
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the diesel generator fuel pump suction lines, to reduce the NPSH
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for the pumps. These check valves are fortuitously located in a high point of the fuel oil system and thus lend themselves to
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removal because the Day Tank Technical Specifications level maintains a flooded pump suction.
l-L While the inspector was reviewing CE-1019, CE-2464 and 2463 were generated.
These notices state that the D/G engine driven fuel
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l oil pump strainer D/P pressure switch is too low and provides L
instruction to raise the setpoints 0.5 psid.
The 10CFR50.59 evaluation states that the present setpoints (3.5 psid increasing) are lower than the D/P experienced when new strainers are used, thus creating unnecessary alarm annunciations and strainer change outs.
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t Design Engineering reviewed calculation CN0-1223.59-03-0006 and found that after removing IFD25 and IFD65 valve internals and using minimum fuel oil day tank level-that the setpoints could--
be raised to 4.0 psid increasing.
This is higher than the initial. recommended setpoint based on system configuration.
Design Engineering also states that the lono term solution =to the problem.is to: replace the strainers with a model with a lower D/P.
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The inspector believes that the previous corrective actions have
not been effective to correct a design problem involving
the undersizing of the suction strainers.
The corrective actions have instead been-focused on removing a nuisance alarm.
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It is the inspector's understanding that the long tenu corrective i
action now involves replacing the existing strainers with
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strainers that have a lower D/P.
The inspector feels that the
- length of time and the. amount of effort expended to finally reach this conclusion demonstrates a weakness in resolving this issue
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in a timely manner.
(2). CNCE - 2141, Modification to Replace the Failed Level Transmitter (Tag No. 2RNLT7400) in'the Nuclear Service Water' Intake Pit A.
The subject modification replaces a failed and no longer manufactured
. Robertshaw.(RS) capacitance-to-current level transmitter (model 158-82-B1)
that was used with remotely mounted probe assemblies-with the manufacturers.
present direct replacement Model 158A-B2-Bl. Review of the Technical Service and. Maintenance Manuci entitled, = " Level - Tel Model 158A" and RS's letter to DPC dated February 10, 1988,. disclosed this direct
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replacement transmitter was an acceptable replacement per its application, and the triaxial cable (Part No. 032-953-03X-XX) from the failed level-transmitter was still a current production part which could
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be reused for connection of the sensing' probe to the 158A-B2-B1 transmitter assembly.
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The-inspector verified that the instrumentation manual and affected drawings
were current to reflect the installation.
The service water system will still operate as designed with no decrease in the margin of safety.
Consequently, nc FSAR or TS changes were deemed necessary. Documentation involving the installation of the-158A-B2-B1 transmitter, the functional and post-mod testing conducted (calibration of the subject' transmitter, string check, comparison to another pit level channel and to the measured level) was examined by the inspector and as detailed in Work Request No. 3167NSM.
This modification will not increase the probability or consequenses of an accident or equipment malfunction previously evaluated or different than any
already evaluated in the FSAR.
Inspection of the modification to the above listed review criteria resulted in no violations or deviations being identified.
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(3) CNCE-1957, Removal of Yalve Intermals for ICA129 During a transient event there was a nuclear service water to auxi_liary
- feedwater swapover due to low pressures experienced in the suction line for. the auxiliary feedwater pumps.
This problem was attributed to
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several factors. - one of which was the pressure drop created by check
valve ~1CA129 just upstream of the pressure switches.
To help alleviate some of the pressure losses' in the suction line to the auxiliary feedwater pumps, the valve disc for ICA129 was permanently removed by Work Request No. 3005 NSM.
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Removal of the check-valve internals is a typical maintenance activity covered by existing procedures.
Upon completion of the work the subject valve was visually. inspected and no leaks were detected.
No other functional tests were required other than those performed for routine valve maintenance.
Review of drawing CN-1592-1.0, Revision 9, disclosed i
the subject check valve was not required for normal system operation and
. was not part of the pump and valve in-service testing program.
Chtck valves ICA8, ICA10, and-1CA12 provide the protection needed to prevent L
' diversion of nuclear service water to nonessential locations should a
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L swapover occur.
Removing the valve internals in ICA129 will not have any l
affect on the probability, consequences or possibility of new or-previously
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evaluated. accidents.
It was. determined that the slight reduction in
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wefght of valve ICA129 after removing the disc would not adversely affect
the stress analysis of the system. The margin of safety, as defined in the
. bases of the TS, will not be reduced since system operation should be improved by this modification.
Inspection of this modification.to the r
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above listed review criteria resulted in no violations or deviations being
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identified.
3.
= StationProblemReports(SPRs)
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A SPR is used to notify management of the need to correct a problem or
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potential problem which may include making a change to a component, structure, system or drawing.
Any plant staff member can initiate a SPR and the appropriate Superintendent is responsible for approval of SPRs L
in his area of responsibility after review ano consideration of benefit and risk evaluation when applicable.
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- The Projects Services engineering section has primary responsibility to i
review all approved SFRs for completeness, to maintain all SPRs up-to-date und to determine the proper method of resolution (e.g. NSM, CEVi., WR, or no action).
The inspectors reviewed the licensee's SPR backlog status in an effort to assess how engincering on-site staff responds to concerns / problems identified in the plant.
A review of the SPR backlog revealed that as of September 1, 1989, 830 SPRs were generated during the current SALP i
period and approximately 280 SPRs are still outstanding.
Of the 280 outstanding SPRs, 20 SPRs were older than one year. Some date back as far as two or three years old.
For example, CNSPR (102047 was generated and approved on September 16, 1986.
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The CSPR: documented failure of. a remote operator on valve IWG-158 in a
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high radiation area and concerned a potential for increasing personnel radiation exposure.
The inspectors raised a question over the potential ALARA issue and the timely resolution of this problem. There was a lack of documentation-which caused the-inspectors to question whether the problem had been addressed.
Licensee personnel stated that, although there was no
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supporting documentation, the SPR had been reviewed and it was determined that there was no ALARA~ issue because personnel were only required to be in the area'to operate the valve once every six months for approximately five to ten minutes.
The SPR was being har.dled in conjunction with the
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overall redesign of the waste gas system, which will remove the remote operator-in question and install a handwheel on the valve.
NSM#CN-50334
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has been initiated to replace the remote operator.
The SPR.is still
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outstanding and awaiting completion of NSM#CN-50334.
Overall SPRs appeared to be resolved in a timely manner.
However, the
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. licensee management is actively pursuing means to reduce the existing backlog.
For example, several meetings have been held between the Superintendents and-the Station Manager since March 1989, to discuss which of these inactive SPRs, NSMs and CEVHS needed to-be worked and to schedule them.
-No violations or deviations were identified.
4.
TemporaryStationModifications(TSMs)
Seven active TSMs were randomly selected to determine the effectiveness of the control process and documentation of TSMs.
The following seven TSMs were reviewed:
TSM - WR #-
Description 005347 Chem Install chemical addition system to RN pump pit A 005348 Chem Install chemical addition system to RN pump pit B L
026482 OPS Install Seal Cap on Valve INC76 L-leak repair
044975 OPS Remove fuses to disable VP Valves 001517 MES Remove internals from Valve 2SA-16 00302 MES Remove a jumper cell 132 of 1 DG BB 00321 MES Replace 0-Rings in MC solenoids l
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f Based on review of the above. TSMs. E the. inspectors identified one v
discrepancy involving the station management approval for TSM - WR #044975 OPS.
The TSM was categorized as a QA condition 1 and was installed
without the station manager or appropriate superintendent approval.
-Section 6.2.3 of Station Directive 4.4.5, Temporary Station Mocification, Revisions 9. and 10, states in part that QA-1 TSMs shall be approved by the station manager or appropriate superintendent prior to installation.
Failure of the licensee to follow the plant approved procedure is identified as a violation, NCV 414/89-30-01, failure to follow procedure during implementation of TSM-WRf044975.
Licensee management was informed of the discrepancy and immediate corrective action was taken to adhere to the
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procedure during the inspection.
Licensee personnel also stated that-Unit 1 NSM 11045 and Unit 2 NSM 20432 had already been developed and will be implemented during the next refueling out.oge for the respective Unit.
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The NSMs will install a permanent key operated switch to disconnect the power from the subject valves rather than the temporary removal of the
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fuses.
This NRC identified violation is not being cited in a NOV because
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the criteria specified in Section V. A. of the NRC enforcement policy were satisfied.
During review of TSM-WRf026482 OPS,.the inspectors raised questions
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over the difference between the TSM description and the actual work performed.
The TSM required installing a seal cap on valve INC76 by seal
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welding the: pipe cap to the vent nipple to prevent packing. leaks and to secure leakage-past the seat.
However, a category 1 tight seal type was actually implemented instead of the seal weld type because the welding could not be performed due to inaccessible area. Based on the information
'and justification provided by the licensee, the inspectors concluded that the category 1 tight seal was acceptable for this particular application.
Therefore, the actual work performed was within the original scope of the TSM.
The quality and technical content of the information contained in the TSMs reviewed were good.
The safety evaluations performed in accordance
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with the requirements of 10CFR50.59 were adequate. The post modification tests were performed and found to be acceptable for the applicable TSMs.
The affected control room drawings were properly referenced to appropriate TSMs.
The station goal is to maintain the number of TSM's to no more than 60 and the number of TSM's. greater than one year to no more then 30 for both units. As of October 2, 1989, the inspector reviewed the status of the active TSMs and noted that the number has decreased from 165 to 102 and the number of active TSM's greater than one year has also decreased from 68 to 48 during the current SALP period.
The reduction of active TSMs and the duration of time has shown an evidence that the licensee is making an
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effort to achieve their goal.
L Overall the licensee's TSM program has shown an improvement during the current SALP period.
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L5; Audits /Surveillances The inspector reviewed the following audits /surveillances:
AuditDE-88-01-(GO),
Design Engineering Department Activities
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Audit'NP-89-19 (CN),
Correctve Action / Station Modifications-
- Surveillance CN-89-8, Temporary Station Modifications-Surveillance CN-89-10,' Nuclear Station Modifications Surveillance CN-89-19, Nuclear Station Modifications L
These_ audits / surveillance ~ were revieweo to verify _ that the licensee was continuing to implenent a program to evaluate the adequacy of-Catawba's Design, Design Modification, and Corrective Action, Programs.
Although descrepancies were identified by the subject audits /surveillances the-Catawba Station Design, Modification and Corrective Action Programs appear to be safisfactory.
In -general, prompt, effective corrective actions appear to have been taken and the Station Modification Program appears to-
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meet or exceed all Quality Program requirements 'and Station guidelines.
The Catawba QA Director.of Operations Department manages a QC Supervisor, two QA Technical Support Managers and a QA Verification Manager.
The QA
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Verification Manager. Supervises eight QA Verification Specialists who
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perform numerous site activity surveillances. These station surveillances supplenent the required TS and FSAR audits and are not required by the licensee's QA program.
They are extremely beneficial in that they are conducted on a more frequent basis than audits and provide more in the way of performance based inspections of site activies.
6.
ActiononPreviousInspectionFindings(92701)
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(Closed) Inspector Followup Item 413/85-04-03:
Resolution of
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Control Circuit Design Error Identified During Loss of Control Room
_i Functional Test.
The resolution of this item is discussed in paragraph 2.a.(1).
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(Closed) Inspector Followup Item 413,414,/88-29-02:
Inadequate Procedure Guidance for 10 CFR 21 Reportability Determinations. 'The-inspectors reviewed Station Directive 2.8.1,- Problem Investigation
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Process and Regulatory Reporting, Rev.11. The procedure now provides detailed guidance for performing 10 CFR 21 evaluations and assigns
this responsibility to the Catawba Compliance Group.
This item is considered closed.
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7.
Exit Interview The inspection scope and results were summarized on October 6, and by telephone on October 12, 1989, with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results listed below. Proprietary information is not contained in this report.
Licensee comments and additional information relative to questions raised by the inspectors concerning resolution of TSM-0264820PS and SPR-CNPR02047 were discussed during the exit.
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The - inspectors reviewed the information with Regional Supervision subsequent.to the exit.
The inspectors. informed licensee personnel. by telephone on.0ctober 12, 1989, that the additional ~ information resolved
- the inspector's questions on the above TSM and SPR.
Failure to follow procedure related to the disposition of'TSM-044975 OPS
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was identified as a violation NCV 414/89-30-01.
However, this SL-V violation neets the criteria of Section V.A of NRC Enforcement Policy and will not be cited in a NOV (paragraph 4).
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Weakness' concerning the length of time and amount of effort expended to
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develop adequate corrective actions to correct a nuisance alarm involving the D/P across the strainers in the. suction piping to the FD pumps (paragraph 2.b.(1)).
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8.
Acronyms and Initialisms
- ALARA As Low as Reasonably Achievable
- ASP Auxiliary Shutdown Panel BAT Boric Acid-Tank CEVN Exempt Change Variation Notice CFR Code of. Federal Regulations CN Catawba Neclear CNCE-Exempt Change DE Design Engineering D/P Differential Pressure DPC Duke Power Company EDG Emergency Diesel Generators FD Diesel Generator Fuel Oil System FSAR-
' Final-Safety Analysis Report NCV Non-Cited Violation
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NOV Notice of Violation NPSH Net Positive Suction Head
NSM Nuclear. Station Modification
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PSID-Pounds per Square Inch Differential QA-Quality Assurance L
- QC Quality Control RC Robertshaw SI Safety Injection SPR Station Problem Report
. TS.
Technical Specification TSM.
Temporary Station Modification VN Variation Notice WR Work Request
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