IR 05000413/1990009
| ML20043A943 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/08/1990 |
| From: | Hopkins P, Lesser M, William Orders, Shymlock M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20043A937 | List: |
| References | |
| 50-413-90-09, 50-414-90-09, NUDOCS 9005230319 | |
| Preceding documents: |
|
| Download: ML20043A943 (17) | |
Text
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- o NUCL EAR REGULATORY COMMISSION
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, .7 REllON il -.. , b-101 MARIETTA STREET.fd W.
e ,b f-ATLANTA, GEORGI A 30323 ' ,
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',,,,../. . < " ', . s / Report Nos. 50-413/90-09 and 50-414/90-09 , -[ Licerae: Duke Power Company.
. 422 South Church Street j Charlotte, N.C.
28242 ' < . , Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and NPF-52 '
} Facility Name: Catawba Units 1 and 2 Inspection Conducted: March 4, 1990.- April'13, 1990 , , Inspectors: //#//[M2, f
N.T.0~rders,SeniorRgdentInspector ' Ddte Signed \\ . /A VA 17t d sh/9o l' -.M. 5. Lesse . w &p t Inspector rhko-Resid /Da(e Signed- '
P.C.Hopkins,Resipnt-Inspector Ga # 3igned Approved by: Y O~Y 90 M. B. ShymlosJ Chief Date Signed L Projects Section 3A . ' ' Division of Reactor Projects ' SUMMARY Scope: This routine, resident inspection was conducted in the areas of review of plant operations; surveillance-observation; maintenance ~ , observation; review 'of licensee. event reports; review of refueling activities; followup of events and followup of previously identified t items.
.; Results: One violatior, is. identified-involving four examples of inadequate procedures or tailure to follow procedures resulting in an incorrect , power supply being removed during a VC/YC functional test, inoperable' P-12 interlock ' channels,. excessive cooldown of the-Unit-1.. " pressurizer, and failure 'to initiate an engineering evaluation after
.. the excessive cooldown. (Paragraph 2.b)- One violation was identified involving two examples of inadequate configuration control resulting in a failure to. return the Steam , ' Generator: Power ' Operated Relief Valve '(PORV) block valves. to the ! ' correct position; and 'a f:ilure to return Nuclear-Service Water > valves which supply assured makeup water to the Containment 4 Isolation 'i , , "x ' l 9005'230319 900510 D " ' PDR ADOCK 05000413 ' ' ~ ' " O PDC J i; f . L'- 4 ; g l.'
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, Valve Injection ' Water System'-to the -correct;,'p'sition.L '! o ' (Paragraph 2.b;) , . . ~ .. Three non-cited violations (NCVs) were. identified and reviewed during this inspection:= ,. Inadequate containment purge system surveillance procedure.
- (Paragraph 3.d) valve. ~(Paragraph' 3.e) perable manual cont'ainment isolation ~ Failure -to isolate' ino <- Defective SSF surveillance procedure. (Paragraph 3.f) - , '
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i REPORT DETAILS 1.
Persons Contacted- - Licensee Employees W. Beaver, Performance Manager
- S. Bradshaw, Compliance B. Caldwell,1 station Services Superintendent
' ***R. Casler, Operations Superintendent T. Crawford, Integrated Scheduling Superintendent
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- B. Ferguron, Operations. Engineer Lj
- J. Forbes, Technical -Services Superintendent i
- **J. Glenn, Compliance ! R." Glover, Compliance Manager
T.-Harrall, Design. Engineering R. Jones, Maintenance Engineering Services Engineer-F. Mack, Project Services Manager
- W. McCollum, Maintenance Superintendent'
- T. Owen, Station Manager
' ]] Other licensee employees contacted included technicians, operators, mechanics,' security force members..and office personnel.
NRC Resident Inspectors
- W. Orders
- M. Lesser-
- P. Hopkins
- J. Zeiler Accompanying NRC Personnel
- R. Spence, NRC Operations Officer
- Attended exit interview on April 6, 1990.
- Attended exit interview on April 20, 1990.
- Attended both exits, t
2.
Plant Operations Review'(71707 and 71710) a.
The inspectors reviewed plant. operations.and refueling outage activi-ties throughout the' reporting period to verify conformance with
regulatory requirements Technical-Specifications -(TS)', and adminis-trative controls.
Control Room logs, Technical Specification Action.
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Item Logs,'and the removal and restoration (R&R) log were routinely reviewed.
Shift turnovers were observed to verify that they-were conducted in acccedance with approved procedures.- Daily' plant status-meetings were routinely attended, j y _ _ _ _ _ _.. -,..... - -. -,,.........,. ..,,,,,,,,,- -
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The inspectors verified by observation and interviews that licensee- . . measures taken to assure physical protection of: the fccility met: -! - current ' requirements.
Areas : inspected included.the. security;
organization,athe establishment and maintenance of gates, doors, and isolation _ zones in the' proper conditions, and that accessicontrol and badging _were proper and procedures were followed.
.; ! In addition to the areas " discussed above. the areas toured: were- .l observed for - fire - prevention and--protection activities and - radiological control l p(ractices.PIRs) _ to determine -if-the licensee was lappro-The-inspectors-reviewed Problem Investigation Reports
priately documenting problems and implementing corrective actions.
y b.
Unit 1 Summary _ ' ! Unit 1 began the report period in Mode 6, coHinuing> the ~ refueling j outage-which began on January 27.
Core rt.ioad was completed on ! March 4,- Mode 5 was entered on March 12 and on March 19, reactor, a coolant (NC). system fill and ve'nt was initiated. On Marr.h 20, during M the. fill and vent process, an unmon_itored NC system. pressure . d excursion occurred due in part to NC system pressure instrumentation.
., being valved out. This resulted in the inoperability. of: not.only the- [ NC system pressure-indication in-the control room but:also the Low .j _ Temperature Overpressure Protection? System whichTis? fed. by the 1same ' pressure signals.- A Region:11 team was dispatched to investigate the a event, the findings of which are _ documented in NRC Inspection Report f 413, 414/90-10.
On April 2, the plant entered Mode 4. Unit heatup-continued and Mode 3 was entered on April-Sth. _ At 5:45 a.m., that.
q same morning, the licensee found all four steam-generator PORV-block-
valves closed. The val'ves had apparently been left; closed during ESF i testing on March 28.
Details pertaining: to these mispositioned. valves are described below.
At' 2:40 p.m.T that same day, the Unit' ' l: entered TS 3.0.3 when the licensee determined that both trains-of the-Containment Isolatian Valve Injection Water NW') system were Manual Nuclear Service Water (RN)({ valves (IRN493'an inoperable.
, 1RN494)' on each of two lines to: the Containment Isolation Valve ! Injection Water (NW) surge chambers were found closed which in turn i rendered both trains of NW' inoperable.
The_ Unit exited.TS 3.0.3 at-j 2:57 a.m.Lwhen the valves were opened.
Details Hrtaining to these' _, mispositioned valves are described below.
On April 9, at 8:47_ a.m., j - the Unit experienced an NC system cooldown and subsequent P-12,-Lo-Lo i average temperature (Tavg) actuation. ' The event was attributed' to l test equipment problems, while conducting. resistance temperature ! detector (RTD) cross calibrations. -The-procedure used to conduct. the ! cross calibrations rendered all' four channels of the P-12 interlock.
J inoperable during the test performance.
Details'of the event are l discussed -below.. On April lith, during an NC system walkdown a leak
was found on the reactor v=ssel head.
The Unit began cooldowr, and
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depressurization, to facilitate necessary repairs, entering' Mode 4.at: 6:00 p.m... on Apt 'l _12th and Mode 5 -at - 6:10 a.m., on the following -. - morning._~ At the end-of this report the Unit: remained in Mode 5 with' ' maintenance in progress.- ESF Walkdown The inspectors conducted aIdetailed walkdown of-ihe NW System.
Valve lineup-procedures and drawings were :used-to confirm as-built configuration.. To the extent practicable, valves in-the flow path were verified to be,.in - the -proper position.. Several ~ missing. valve -labels were identified.on Unit:1.
Power _ supply circuit breaker labelling for two solenoid valves were' also .noted to be in. error.
These deficiencies were; brought;to the attention of the system engineer for resolution.
VC/YC Trip.
On March 23,1990,-with. Unit 1 in Mode: 5,- and Unit 2 in Mode 1, 97% power, the chiller for B. train Control: Room Area / Chilled
Water (VC/YC), a common control-area HVAC system,' tripped.
Since the A train of -VC/YC had: alreadyE been removed from-service, Unit 2L was placed in TS 3.0.3.
The chiller trip was caused by. an by a non-licensed operator (NLO) shifting. power supplies on the chillers while performing Section 4.8 of OP/0/A/6450/11. - Control ~ Room Area. Ventilation / Chilled-Water ? , System. The A train chiller breaker had been racked :out' earlier f to facilitate switching the power supply cables located in local
termint: Sax 1TB0XO345 intorder to power the VC/YC. system from ' an openble diesel ; fed - bus..The' NLO mistakenly went to the. B- ! train ~ terminal. box, ITBOX0346.
When the NLO disconnected' the i _ power. cable'in 1TB0X0346, an elec+.rical flash occurred and the B i train chiller tripped.. The NLO had lifted:the. power lead-for the running train,; contrary to the instructions -delineated in Enclosure 4.8 item 2.2.4, of the, procedure._ This is a - - violation, Failure To Follow Procedures. Resulting in An ' Inoperable VC/YC System.
This violation is one-of'four examples which collectively constitute violation 413/90-09-01.
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Steam Generator.PORV Operability- - 0n April 5..-1990, Unit 1 was in_ Mode 3 heating up in ' i prepara!. ion for.startup testing with the iam generators being relied upon for decap heat removal. Dur, . review of the Mode ) 3 Critical Parameter Checklist, which contains the status-of- !: important plant parameters, the licensee discovered that.the ' main steam PORY block valves (ISV-258, 26B, 27A, and 28A) were L closed. - The valves were cpened end PIP.1-C90-115 was initiated
to determine why the valves had not been opened prior to l . j -- il f q > , i h _;.
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! .j entering Mode 4, an operat k g mode.where the PORC s are required to be operable.
The resultant investigation revealed that the PORV block. valves were closed'during 'ESF testing of the PORVs on- -Ma'rch 28 when the Unit was in Mode 5.. The ESF. test; procedure : )f did' not indicate a required -position' for-the block; valves but - , operations personnel-determined -that it wasLnecessary.to close.' r ! z them before the PORVsiwere to.be opened -ini order to prevent depleting; the vacuum established--in the condenser.: The blockf q valves were closed without generating an R&Ritagout or, making la 4' Control-. Room Open Item; entry.
Operations. Management Procedure (OMP) 2-17. Control Room 4 and-Unit Supervisor,t.ogbooks.: requires j .a Control Room.OpenEItem" entry to be made for controlling the-T status of equipment in an "Out of; Normal" position '. As a result- ' of-not having~ generated an: R&R or: making an'0 pen Items entry, l operations failed to open; the-block ? valves, following the ESF - H The valves' remained closed for three days'While the unit.' test.. : '
was in an operating mode requiring. P0RV - operabilit.y..' DuriW : ' this time the _ plant operatings crew'was unaware that the:PORV block valves were closed.
10 CFR 50, Appendix B, Criterion XIV, Inspection,. Test' and.
Operating Status, requires in part that measures-be established for indicating the operating} status of structures,' systems and j , compor.ents.
Theiabove event.is considered a violation of these i requirements and isz one of two examples which:..c'ollectively- , constitute violation 50-413/90-09-05.. This violation is a
further. example-of a ' violation _ previously Lidentified in-
Inspection Report 413,414/90-10. and, wil1J not t.be cited j separately.
The steam generator PORVs.are use'd to remove. heat from4the NC < system when the' plant is started. up -or shutdown'with the main-j condenser 'not available -or~ in case of - a steam generator ! overpressure condition..The motor-operated PORV block valves
are located directly upstream of.~ their^ associated: PORVland-can be controlled from the control room.
TS 3.7.1.6 requires three steam generator PdRV's to -bef operable " in Modes 1 through 4.
The Mode 4 requirement snly applies 'if
- l the steam generators are being used for decay hat removal. ' The I
resident inspectors questioned the -licensee's~ contention that the PORV's were capable of performing their intended function with the block valves closed.
This contention -.is : based primarily on the. Bases for TS 1.7.1.6 which states: Concurrent , . with the - requirement that a apecific n' umber of PORV' Se ! operable. is t'ae requirement that the associated P0M 'iock -
valves be open or operable."
The licensee interpreted this to imply that closing the PORV block -valves. does not' render the , - PORV's inoperable-as long as the block valves are operable and ' could be ' opened from the control room.. NRR wabconsulted-regarding 'the operability of the PORVs with the block valves closed. NRR concurred with licensee's-interpretation.- i ,
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' Containment Valve Injecti.on Water System Inoperability At 2:40 p.m. on April ' 5,1990, with' Unit 'l in Mode 3, the - l licensee discovered that.Nuclearo Service; Wateri(RW) ; Valves l t 1RN493 and 1RN494 which should1 have been open, were closed.
These valves supply assuredsmakeup water to the. Containment = j Valve -injection Water System (NW).
A review <of. work'that had
transpired leading up to the identification of,the mispositi_oneds "j valves _ revealed that _ operations had confirmed them to be in the ' correct position, open, on March 29. On March 30,_however, the ' valves.were closed pursuant-to an R&R-to facilitate measuring RN ' q ~ ' flow to the NW system, an.Levolution;which' required 1that the - - , asscciated piping be disconnected.
TheLontainmentValveInjectionWaterSystem.(NW)is' designed,to a prevent leakage of the containment atmosphere pasticertain gate-
valves used for containment: isolation by injecting-seal WaterJat _
a pressure exceeding: containment accident' pressure between the ' two seating surfaces :of flex wedgeEgate valves.
The system? consists of two independent. redundant trains,' each of which contain a surge chamber filled'with water and pressurized withi l ni trogen. 'One' main header exits leach chamber and splits"into
' several branch headers to supply ' seal water. to associated j - valves.
An assured makeup water source is provided from-the essential.
I! header of the - Nuclear. Service Water System. ' This supply is) ' intended to ensure a supply adequate to 1ast at-;1 east'30 days following a ' postulated-accident based on predetermined. leakage: . rates of - valves ' served : by NW.
The mistake which led -to-the_
,: - valve; L oing left closed,i was:an : erroneous R&R; entry which
returned the' valves-to-the; closed positionLfollowing the afore-- ! mentioned flow verification.. Operations 1 Management Procedure; I ' (OMP) 2-18 Tagout Removal and Restornion1 Procedure, L requires that the Return. Position-of equipment that hastbeensremoved from , service be that equipment's " normal" position'as denned in the
- _- a)plicable procedure.- In this : case,the applicable procedure is . t tie Operating Procedure for the RN: system which states that the
normal position for both valves in question is op'en.
. ! The erroneous R&R led-to a conditica in which the operating status of the NW system was not knw -in that with ethe two' RN-valves closed, the NW system did not have an assured makeup ~ source available, and therefore was inoperable.
.j , 10 CFR 50, Appendix. B, Criterion-XIV, Inspection,. Test - and. ' - , Operating Status, requires -in -part that: measures.be established
for indicating the operating status of structures, systems and - ! components.
The abovF event is considered a violation of these ' requiraments and is. the -second of' two' examples which collec-tively constitute violation 50-413/90-09-05.
This violation is
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- spection Report-413,414/90-10 and - will not-be cited
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Unexpected Cooldown Following RTD Cross Calibration Test' At approximately_8:47 a.m. on. April; 9,1990, Unit '1'experinced' L an unexpected NC system cooldown and subsequent 1ESF actuation of" j
the P-12,' Lo-Lo <Tavg ' interlock (553 F).
Unit l'was in Mode 3= .l - ' with NC system Tavg at:557*F.
At the time of the event, Instru- =! ment and Electrical: (IAE) technicians were conducting RTD cross-- l calibrations per procedure IP/1/A/3231/01,. Incore Thermocouple; i and RTD Cross. Calibrations. ; The test involved inserting < wide ' l and narrow range RTD test signals which were intended to be- -! - equivalent to 557*F into each NC loop's Tavg circuit.; However.
l due to a problem in the test equipment,.a Tavg signal equivalent; ' to 545 F was injected.; Since the steam dumps were in the steam-pressure. control. mode, the erroneous Tavg input generated a P-12.
. y . signal which caused the stet.m dumps-to close and resultedtin an: J actual-NC-Tavg increase.
Steam pressure continued to. increase-j which increased the ' demand signal to the steam dumps during: thel J 15 minute test duration. ' At - the : end of the: test,l the actual ~ l ' ' Tavg input was reinstated. - This > reset the: P-12 interlock, and ' y - the sttams dumps opened;due to= the - 30% ' demand, which had been ! generated.
NC system Tavg quickly.zdecreased to 547*F causing a-i real P-12 actuation.- Operations personnel were quick-to respond i to the event and within approximately 15 minutes Unit' stability-a was regained and Tavg was restored above.the - 553 F, P-12 l setpoint. The event was. reported in LER 413/90-25.
j q In ~a subsequent investigation the~ licensee discovered that they ! had unknowingly entered TS 3.0.'3 due to all four channels of. the P-12 interlock being rendered inoperable during thelest.
TS - Table 3.3-3, ESF Actuation System : Instrumentation, Item 18.c s requires a minimum of three channels of the' Lo-Lo Tevg, P-12 i interlock be operable in Modes 1,. 2, and 3.
In addition,=TS-Table 3.3-10, Accident Monitoring Listrumentation. Items 2 and 3 - a require a minimum of one operable channel ofmhot and cold leg: , wide range temperature instrumentation bo. operable in : Modes 1,
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, 2. and 3.
The inspectors reviewed the '.est-procedure an' I determined that -it was inadequatefin th c it removed, all RTD
signals from service providing - input - to; required ESF - ) instrumentation channels rendering them inoperable inoperable.. d
This matter is identified as a violation,' Inadequate Procedure
- Resulting In Inoperable ESF Instrumentation Channels.
This i violation is one of four exaples which collectively constitute l violation _413/90-09-01.
The'licensae' plant to revise procedure - ' IP/1/A/3231/01, whereby, RTD's in only one NC system loop :will' ! be tested at a time.
Further_NRC review relative to the test - ! equipment problem and of operations personnel. performance during j the test will be conducted as part 'of f,110wup to LER 413/90-25.
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-7 Sustained Control Room Observation The-abovc events' considered collectively, led to an NRC concern - with plant configuration; control.
This'in turn led NRC manage-ment to place Lthe Unit under sustained-: control room and plant-observation by ' resident and regional-inspectors. NRC' personnel , performed extended observations of -Control Room ' activities, ' conducted l system = wandowns and plant tours _ Operator perfor-i mance, Control-_ Room decorum, awareness of plant status,. response.
q . to -alarms-and.use of operational procedures were monitored.- -! - Several plant status and. shift meetings were. attended to deter-I I mine that1 the: licensee' adequately _ disseminated information -- -i regarding day-to-day plantLactivities and planned future activi _ , ties _ appii,:able to the' staff. There' appeared to be a' heightened
awareness and concern among_the plant staff.
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Unit 2 Summary' l On April. 13.1990, Unit 2 completed 96 days in Mode 1.. A planned . refueling outage for Unit' 2. will begin on about June-9,1990.
. d Two violations 'were identified.
' 3.
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 w safety _ injection,. emergency sa. ater tank, emergency power systems, feguards systems,- control room ventila-tion, and direct current electrical power sources., The inspector- - verified that surveillance testing was performed in accordance with j! the' approved written _ procedures, _ test instrumentation were calibrated. limiting conditions for' operation were met, appropriate.
j removal and restoration of the affected equipment was. accomplished, j test results met acceptance viteria and were reviewed by personnel i - other than the individua~l ~ directing 'the test, and. that - any deficiencies identified during.the testing were properly reviewed and i resolved by appropriate mam gement personnel.
~ , b.
The inspectors witnessed or reviewed the following surveillances: $ PT/1/A/4700/01 Periodic Test' Performance i Verification.- i PT/1/A/4600/16 VC/YC Air Pressure Filter A.' Test j PT/1/A/4200/02B Cold Shutdown Inside Containment lutegrity Verification
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PT/1/A/4200/06C NS Valve Lineup Verification l ~PT/1/A/4350/10DG Op rating Parameters < PT/1/A/4600/02E Mooe 5' Periodic Surveillance Items.
PT/2/B/9100/52 .2 EMF'34 Flow Verification; .PT/2/A/4450/16 VQ System Cumulative Purge' Time PT/2/A/4600/02A Mode 1 Periodic Sarveillance-Item.
c PT/2/A/4450/11B-Unit 2 DG C0 _ Weekly Test H
/T/2/A/4600/02A Mode 3 Deri051c Surveillance ' ' PT/2/A/4200/01El Upper Containment PALRT PT/2/A/4600/06A Boron Injection Valve Lineup Verification. $
- PT/2/B/4250/02B Weekly Main Turbine Valve-Movement Test PT/2/A/4150/01D NC System Leakage Calculationi j
PT/2/A/4350/03 Electrical' Power Source Alignment: Verification' <
c.
Steam Generator Surveillance i q 'The licensee accomplished extensive steam generator (SG) eody current ' (EC) surveillance during;the Unit 1 outage.
Full-~1ength EC inspec- ! tions were completed on all four steam generators.
A 100% Motorized
Rotating Pancake, Coil (MRPC) EC test'of the Hot Leg tube sheet'on all i four SG's was also accomplished.
This was done in response to prob-j lems found at McGuire and certain Europaan plants.; An ?MRPC
inspection was also completed in various special interest. areas such ! as previous defect areas, new indications' detected by the full length ' inspection and the' Row 1 "U" b~end: area,' .Associcted with the problem identified-at McGuire the licensee'puiled { two tubes from "C" SG which contained indications at the 2nd -and 3rd
tube support plate areas.. The ' tubes were ' transported to the~ B&Wo
Research Center, located in Lynchburg, Virginia,' for evaluation.
l As a result of EC testing the following number of tubes were plugged l during the outage:
i S/G Tubes - : A
j B
' C
D
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Failure to Perform Technical Specification Surveillance on VP Systems J, On February 12, 1990, the' licensee. identified that the : Containment l Purge (VP) Systems on both Catawba' units were not being properly', I tested in accordance with Technical' Specification surveillance " ' 4.9.4.2.a.
The surveillance requires that flow be initiated through " l l I ' I I i_ i
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. the filters and activated carbon.adsorbers and operated for 10 hours with heaters on.
This is to verify VP operability andito prevent moisture buildup in the adsorbers and filters. -'The test procedure, PT/1(2)/A/4450/01, Containment Purge Periodic Test, was determined'to be inadequate _in that :it failed to ensure that the' heaters were e energized.-The heater. controls respond automatically to high relative humidity and actual * relative humidity during! testing was typically - = not hi@ enough! to activate the heaters.. The deficiency s was identified daring'a procedure-review which is-part of an ongoing effort to improve the operation of : the : facility's - ventilation.
systems.-.This review was_ initiated. as-a result of previous ventilation system problems. ' Licensee corrective actions relative to q this ~ event includet procedurel _ revisions;. verification of VP-operability, modification-proposals to facilitate testinC,. review of: other-safety related. ventilation system procedures and-continued review of ventilation system design basis by Design. Engineering.. The event 'we ' reported in LER 413/90-09.
The failure to perform ther requirm u rveillances resulted in the VP' systems of both units'being
- inoperable 'foi extended periods.
During.- these priods Lof- _T inoperability, cord alterations or. movement of_ irradiated fuel within A the containment occurred;-. activities which -are in violation of the Limiting Condition for OperationLof TS 3.9.4, Containmentz Building Penetration.
- After careful review' of the_ sefety: analysis performed relative ?to this event,. it i was - determined that the. event.wasinot safety significant.- Accordingly,'this licensee-identified violation 4 is not' being cited because criteria specified in SectionT V.G.1 of'the Enforcement Policy were satisfied.
This. is: documented as a licensee
identified Non-Cited Violation NCV 413/90-09-02: Technical i Specification. Surveillance 4.9.4.2a. Violation, ' Inadequate Test Procedure.
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Failure to Isolate Inoperable Containment: Isolation Valve' On-January 30, 1990, the' licensee was performing surveillance testing on the Unit 2 Auxiliary Feedwater' Turbine Driven Pump (CAPT).- The test -requires that steam be - supplied individually! from each of two sources.
In' order to accomplish this, the' CAPT is declared inoperable then steam from the 2B 'and.2C steami generators are isolated one :att a time and ' the pump is tested.
During the. test, operators were unable to close 2SA-4, Steam Generator 2B Isolation to - CAPT, due to a damaged stem nut and-bearing assembly..The open valve did not affect operability of the CAPT, however the licensee failed. to - recognize that 2SA-4 is a Technical 1 Specification required' ! Contair. ment. Isolation Valve.
The action statement requires that an l ' inoperable containment isolation valve be restored to operable status within.4 hours or the penetration'is to be isolated within 4 hours.
This action was - not-performed. On~ February 5. 'a Senior ~Re' actor Operator identified the discrepancy and the acticn statement was ~ invoked.
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Valve 2SA-4 is a manual containment isolation valve and the licensee determined that a common misunderstanding by several operations personnel _ involved the belief that the in-line - automatic valves- _ served' the isolation function. Accordingly, this ~ TS. violation -is attributed in part-to.inadequete training provided-on the. containment-isolation valves in this particular system.
A review of the licensee's Emergency Procedures determined that 2SA 4 is not required -to be. isolated during. any-accidents-including _the Steam Penerator Tube. Rupture.
Theslicensee reported.the event in Licensee. Event Report 414/90-02.
This. licensee identified violation - is not being cited because criteria specified'in Section V.G.1 of the NRC Enforcement Policy were satisfied.
This-is. documented > as a licensee identified Non-Cited LViolation, NCV 414/90-09-03:' Failure-
F to. Isolate Inoperable Manual Containment Isolation Valve.
f.- Failure To Perform' Surveillance on SSF Instrumentation- , On February 5,1990, Unit.1,. was in Mode -.6 and in' the process of, refueling. :and-Unit 2 was in Mode 1,_97% steady state.. At approxi-j ~ - mately 2:00pm the license ~e, discovered that: the; Standby Shutdown _ Facility (SSF) wide range reactor coolant. system (NC) was required to ! have - had a monthly channeli check per - Technica1L Specification
4.7.13.6 The problem was attributed to an inadequate' procedure, in .\\ that when a modification package was' initiated to add wide range NC - ' temperature indication to the SSF, the indications were. overlooked _ _i and not placed into the surveillance procedure.
The licereeotook ! prompt action to remediate future repetitions o' this type;by-
revising the procedure and verifying the instrument.
The: licensee j will report this item in' an -LER 413-90-10.~ This licensee identified a violation is - not being. cited becauseL criteria specified in Section V.G.1 of the NRC Enforcement Policy were' satisfied. 'This:is. l documented as~ licensee. Identified Non-Cited Violation, NCV 413-90-09-04: Defective Procedure.
Three Non-Cited Violations were -identified.
' 4.
MaintenanceObservations(62703).
Station maintenance activities of selected systems _and components a.
were observed / reviewed to -ascertain that-they were conducted.in accordance with the requirements.
The inspector verified licensee i conformance to the requirements in the following_ areas of inspection: the activities were _accomplisheo using approved procedures, and i , 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 proper.ly certified. Work. requests i were reviewed to determine status of outstanding jobs and;to assure that priority-was assigned to safety-relatej equipment maintenance I which may effect system-performance.
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? .' f . ,. , -11-l b; The inspectors. witnessed or' reviewed the following maintenance , activities: 010258 SWRL Calibration of 2 CAPS 5130 "A" .. Train - i ~ 010026 SWR . Perform Partial String. Check of 2 - ' Calipers 5090 and 5091-
'013027 lNS2 Prefabricate and install hangers - on CA 002673 MES Disatsemble valve and inspect;for' i wear, valve # KC 0166. !! 002703 MES Calibration Loop 1forl BB. recovery - , of Heat Exchanges flow controller (LP760).. . ,
044250 0PS Repair lift: poles' broken on 2A ! Fan DE j 00374 MES Replace contact carrier screws in? ,{ 2EMXK- .006342. MNT Replace 4L: and 4R Cylinder t exhaust sensor on DG i 010738 SWR- - Verify' Speed governor' Control: .l Knob settingJon DG.- l 002449 SEC: Inspect and repair PAP' Door;
Alarming Device:.. ! 046110 OPS-Inspect and repair packing' leak .j on valve 2HV59 and body bonnet .l . No violations or deviations were identified.
j 5.
Events Followup (93702) -l
Uncontrolled Pressurizer Cooldown-i L l On March-25,-1990, Unit 1 was in the process of conducting Train A Engi-
neering Safeguards Features-(EST) Testing in accordance with-d ' PT/1/A/4200/09 E;F Actuation Periodic Test.
Initia1Jconditions of the h plant included pressurizer pressure and temperature at 190 psig', 380 F l L with a bubble established, pressurizer level' at 48%, and reactor coolan. .l - -(ystem hot leg temperature at 135'F.NV) was operating providing flow-to the?j E s The.1B Centrifugal. Charging Pump { test was to verify Train A ESF equipment response ~ to a "LOCA Coincident' with Blackout" signal and then again to "LOCA" without Blackout.
At approximately 10:30 p.m. the first test was initiated.a Upon receiving-l the test signal,1NI-9, Centrifugal Charging (NV) Pump; Cold Leg Injection-f , i Isolation -Valve,. responded properly by opening which 'in turn allowed l L injection flow -of' 480gpm from the 1B NV Pump. The 1A NV Pamp started and ! was appropriately isolated from the NC System by procedure and operated in .j ! l ' recirculation..The injection continued for 10 minutes until. pressurizer
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1 ? evel approached 80% when the Operator at the' Controls '(0ATC) reset the.
) l sdfety. injection signal and shut 1NI-9. During this period'approximately J 4000 gallons was injected into the cold legs. ' NC System Water at.135 F, l was forced inte the pressurizer causing pressurizer water temperature <to- ]E ' drop from 380*F to 145'F in 10 minutes.: Similarly, the pressurizer. surge.
line: temperature dropped. from 285*F to 135 F'during the same time. -; Pres-surizer temperature.then recovered to 330'F durIng the next 30 minutes due ' to the' combination of heatup from the pressurizer metal and -increased y - letdown flow to reduce pressurizer level.; A second transient with.similar i results: occurred on March 26 when the second ESF' test was'run.
j -! ' Technical: Specificationr3.4.9.2 requires that the pressurizer temperature . be limited to a' maximum heatup of-~100'F in any 1 hour period and a maximum c cooldown of 200*F in any 1-hour period.
The above transients violated both of the limits.
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A review of the' background associated with-this' test revealed thatjit had ! 'been run on ainumber of occasions in Mode.5.
The only difference being the valve line up associated with-the-NC pump seal water flow requirement necessitated - by running the NC - pumps.; Since seal water had not been
required in Mode 5 both NV pumps had previously-been tested:in recircula - a . tion.
With train B;11ned up to provide.NC-seal flow, wheni the test was i initiated, the injection through INI-9_ occurred.. The inspectors reviewed the test procedure 1to. determine-its adequacy. The j procedure lists the required unit-test status as Mode 5.
Precaution 6.10 . ~ , l states:
.: " Ensure that the Control Room Operators are aware that thestime delay-J for ECCS Res'et has been defeated and ECCS may be reset at any time if.
f desired."
i , ' The body of the test as delineated in section :12.'1.0, basically consists; of initiating the LOCA/ Blackout signal' andL having Performance personnel l - verify proper load shedding and sequencing of loads.onto the ESF bus, i Operators then reset Fhase A. Phase B, and.ECCS signals-and recover the J plant using AP/1/A/5500/05, ECCS' Actuation During Plant _ Shutdown'. 'The-procedure does not specify a time for resetting the signals and securing - i injection flow. Similarly, the limits and precautions did not address the potential for pres 3urizer level. increase and resultant pressurizer a temperature cooldnwn.
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"The acceptance criteria associated with~ the equipment involved in -the event only included, verification. that INI-9 opened within -20.8. seconds; It appers' that the affects on pressurizer temperature and level of
injecting 480 gpm into the cold legs were not adequately considered when-
the procedure was written.
In fact there was no reason-to inject water - for 10 minutes during the test and flow could have - been secured immediately after INI-9 opened.
While the procedure allowed for this i !) 'I J
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P , [ option in precaution '6.10,: section 12.1.0 failed to ensure that the f ' injection of flow into the cold Llegs did" not: result inn an excessive' l cooldown.- This. is identified as a-violation for an. inadequate procedure, ' , . in that-PT/1/A/4200/09 was inadequate to; prevent an. excessive.cooldown_of , the pressurizer following test initiation.. This: violation is one'of four ! ' examplestwhich ::ollectively constitute Violation '413/90-09-01.
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Prior to-the first. test, the operators were aware that pressurizer level would increase and wert concerned that excessive: injection could bring the j plant close to a: solid condition.. Since the procedure did not specify a maximum pressurizer. level. or a time requirement to secure' injection,-the:
- . operators: consulted with the performance test engineer for. guidance. 'The- < engineer' informed the: operators thatithelintent of. the procedure was to , -reset-the ECCS signal - after the--sequencer. had timed :out (12 minutes), ~ L however, -advised them 'of Ltheir_ options as given in precaution l 6.10.
l During the first test the operators monitored the -pressurizer level increase by using:a cold calibrated levelLinstrument and data curves'to , obtain ; actual level at the' existing; pressurizer temperature.- After 10-
- l-minutes.of injection, operators determined ? level. to 80% and' based on a concerns for going solid, reset the ECCS signal' and isolated INI-9.- It i_ was noted that the pressurizer had cooled down to:145 F,' and also that it-l' had subsequ'ently heated back up..LThe; operators observed that the heatup occurred without ~ the ' use ofJ pressurizer heaters ' or operatingj Reactor - Coolant Pumps, and that pressurizer __ pressure _~ and -vapor temperature -had L remained stable.. Based -on this, the operators concluded that water had i stratified and that the ' cold volume' had-been localized in the lower ' . portion of the pressurizer.
The operators concluded that:the pressurizer metal: temperature had not been affectedrand thatathe cooldown and heatup - . ~ limits on the pressurizer had _not' been violated.: This' conclusion was-
unfounded since no direct. indication of. pressurizer metal exists;and. an engineering analysis of the transient'had not been. performed.
The operators: remained concerned and' consulted the Technical Specifi- - , cation.'. They. concluded that plant conditions were well below:the :500L psig: l limit imposed by the TS. Action' Statement.
Based upon}this'they decided to go ahead with the second test.
They. evaluated methods to-reduce the effects of the transient, -however incorrectly. believed that a procedure , change would be' required to reset-ECCS and shut.1NI-9 earlier in the test.
f Operators failed to consult ~ with the test-engineer : relative to: their t concerns on the pressurizer cooldown.- _ Station. Directive 3.1.14, Operability' Determination, requires that if responsible personnel believe a component operable but' have concerns relative-to it (as was the case in this event) necessary actions shall be . l taken expeditiously to resolve the concerns and' confirm operability.
) L These actions in::lude engineering. evaluations ~ The. operators faileo to
. adequately evaluate the transiert or request assistance in that evaluation prior to authorizing the second test. Accordingly, this is identified as i a violation _ for failing to follow the requirements of Station Directive , 3.'1.14. 'This violation is one of four examples which collectively constitute Violation 41?/90-09-01.
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. A-14: i Subsequently, the> licensee requested. a contractor'.to perforra an ) ' engineering evaluation-to determine structural -integrity L of the - - pressurizer based-on the realized thermal stresses. :The temperature and:
pressure: data for ;the two-transients were reviewed. and comparedMth i events'at ten other plants which experienced similar transients.invo ving ~ < a-large insurge and rapid cooling of-the lower shell'of the pressu'izeb . 't and subsequent heatup.: ~ Additionally _ the contractor applied evaluat;ons of.
historical operating records performed as part of = a transient andifatigue' cycle monitoring program.' ' Based on. the r,eview,. the contractor--judged.that a the allowable ~ pressurizer fatigue-life has not been approached to-date and- ' that structural integrity has not. been-compromised.
- A - detailed - .
- engineering. evaluation,- including fatigue and fracture" analysis,: to-J determine the specific effect on design life will be performed by May 15,x
1990.
' " -l One1 violation was identified.
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Followup on Previous Inspection Findings-(92701'and 92702): (Closed). Inspector Followup Item 414/89-07-05: 2NM-190 Valve Failure Cause: ' Determination i The licensee: conducteds testing onL the valve' which11ncluded full stro'ke. j open and close operat_ ion wnile monitoring motor. current and switches to j' verify-limit switch. setup. Output thrust wasialso measured. DThe measured thrust'was sufficiently higher then design required 'hrust to overcome any_ e effects of possible J inadequate lubrication.- -In spite - of L these .
troubleshooting efforts, the cause for the failure to give > full ilosed ' indication on demand was not-identified.- Thel 11censee concludce tnatLthe.
failure was'an: isolated case as other' failures of this type-have not been ! identified. ' Maintenance trending programs-- and operational differenMal
E pressure testing should be adequate to identify further problems 1with the '
valve.
Based on these actions the item is closed.
No violations or deviations were identified.
7.
Information Meeting with Local Officials (94600) ! On March 14, 1990, an information. meeting with local officials was held at l.
the Catawba Nuclear Energy. Center.
Officials in attendance ~ represented I.
Mayors'and Councilmen of the surrounding-towns and cou'nties.
The mission and functional organization of. the NRC 'and its relationship to the.
. A community were freely. discussed.
The' meeting was informal in nature with ! attendees responding with questions of interest 'and --importance to. the-O , communities.
Plant operational safety, security,: emergency -plans, and , p operator qualifications were of high interest to the group: The response- .i l by local officials was very positive and provided a good opportunity for , i interface and followup.
Representatives from the USNRC headquarars and Region II were press.at.
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Exit Interview The' inspection scope and findings were -summarized on April 6, and April 20, 1990, 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 Number Description and Reference --}) VIO 413/90-09-01 Inadequate or failure to follow procedures-resulting in incorrect power supply being removed . during: VC/YC L functional test, inoperable, P-12 interlock channels,, excessive cooldown of pressurizer, and failure-to initiate engineering evaluation after: excessive cooldown.
(Para-graph-2.b. and Paragraph 5)' -{ Inadequate Containment'Pur
NCV 413/90-09-02 Procedure. (Paragraph'3.d)ge System Surveillance NCV 414/90-09-03 Failure to Isolate Inoperable Manual Containment Isolation Valve. (Paragraph-3.e) NCV 413/90-09-04 Defective'SSF Surveillance-Procedure.
(Paragraph 3.f) ' VIO 413/90-09-05 Failure to establish measures to accurately indicate. operating status resulting' in closed- . steam generator PORV block valves and RN valves to NW closed.
(Paragraph 2.b)
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