ML14175B285
| ML14175B285 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/22/1985 |
| From: | Debs B, Julian C, Julian C, Mccoy F, Modenos L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B283 | List: |
| References | |
| 50-261-85-05, 50-261-85-5, NUDOCS 8507010074 | |
| Download: ML14175B285 (9) | |
See also: IR 05000261/1985005
Text
pR REGI
UNITED STATES
05
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30303
Report No.:
50-261/85-05
Licensee:
Carolina Power and Light Company
411 Fayetteville Street
Raleigh, NC 27602
Docket No.:
50-261
License No.:
Facility Name:
H. B. Robinson
Inspection Conducted: January 14 -
18, 1985
Inspectors:
A -------
d
B. T. Debs
Date S'igned
L. P. Modenos
D e Si _ed
F. R. McCoy
W
Da
Sig ed
Approved by:
oLt
C. Julian, Section Chief
D-e Signed
Division of Reactor Safety
SUMMARY
Scope:
This routine, unannounced inspection involved 105 inspector-hours on site
in the areas of maintenance activities, non-licensed employee training, and
licensed operator requalification training.
Results:
Of the 3 areas inspected, no violations or deviations were identified
in 1 area and 2 apparent violations were found in 2 areas.
(Failure to follow
written procedures in that dye penetrant was not removed from service water
piping; see paragraph 5.a and failure to adequately implement the licensed
operator requalification program in accordance with 10 CFR 50 Appendix A in that
licensed training staff personnel were exempted from annual requalification
written examinations contrary to Training Instruction requirements which define
the requalification program
and contrary to 10
CFR
55 Appendix A; see
paragraph 7.d).
8507010074 850308
PDR ADOCK 05000261
G
REPORT DETAILS
1.
Licensee Employees Contacted
- J. M. Curley, Manager, Technical Support
- W. J. Flanagan, Manager, Design Engineering
- F. L. Lowery, Manager, Operations
- A. R. Wallace, Director, Onsite Nuclear Safety
- H. S. Young, Director, QA/QC
- D. C. Stadler, Director, Regulatory Compliance
- E. Paine, Technical Support
- R. Chambers, Maintenance Supervisor
- S. W. Farmer, Senior Engineer
- R. Allen, Senior Specialist, Training
- V. L. Smith, Senior Specialist, Training
C. Bethea, Director, Training
NRC Resident Inspectors
- H. E. P. Krug, Senior Resident Inspector
- H. Whitcomb, Resident Inspector
- Attended exit interview
2. Exit Interview
The inspection scope and findings were summarized on January 18, 1985, with
those persons indicated in paragraph 1 above and by telecon (Fredrickson,
Region II NRC/Curley, H.B. Robinson,
Manager Technical
Support) on
January 24, 1985.
3. Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or devia
tions.
One unresolved item was identified in the area of licensed operator
requalification training and is discussed in paragraph 7.
5.
Inspection of Maintenance Activities
.
(a) Service Water System Piping
An
inspector entered the licensee's Unit No. 2 Containment and
inspected selected sections of Service Water piping. A majority of the
system within containment had recently been insulated.
The inspector
observed wetted insulation on one run of Service Water piping.
At the
inspector's request, the licensee removed approximately two feet of
2
wetted insulation.
An inspection of this section of pipe indicated
that the wetting was due to condensation and not pipe leakage.
On
January 16,
1985,
while in containment, the inspector observed a
vertical run of uninsulated Service Water piping associated with
HVH-2 (Containment Ventilation Cooler) with apparent dye penetrant
over an approximate two foot section of the pipe.
A member of the
licensee's engineering staff acknowledged the inspector's observations.
On January 17,
1985, the inspector was informed by the licensee that
this section of piping had subsequently been insulated; however, the
licensee was making preparations to remove the insulation to clean the
pipe. The inspector informed licensee management that the aforemen
tioned situation was contrary to licensee procedure NDEP-201, revision
No 6, Liquid Penetrant Examination (visible dye, solvent removable)
which states, in part, that penetrant examination materials shall be
removed from the subject surface(s) after completion of the examina
tion.
Licensee management was also informed that the aforementioned
procedural violation is contrary to 10 CFR 50, Appendix B, Criteria V,
which states that activities affecting quality shall be prescribed by
documented instructions, procedures, or drawings, of a type appropriate
to the circumstances and shall be accomplished in accordance with these
instruction, procedures, or drawings. (Violation 261/85-05-01).
(b) Component Cooling Water System Corrosion Inside Containment
The inspector requested that the lagging be removed from Component
Cooling Water valve 728C for inspection of external surface corrosion.
This valve and associated piping is designed to contain Reactor Coolant
System pressure should a leak develop in a reactor coolant pump thermal
barrier heat exchanger (2503 psi).
Upon inspection of the carbon steel
valve and visible sections of associated piping,
the inspector
expressed concern regarding the apparent deteriorative external condi
tion of the valve and piping.
On January 21, 1985, the inspector was telephonically informed that the
subject valve and piping had been evaluated by a Carolina Power and
Light corporate metallurgist who found that the corrosion was
acceptable in that no pitting or cracking was observed and the
corrosion that was evident is expected for a cold water carbon steel
system which is subject to sweating (condensation).
(c) Cold leg Accumulator Injection Line Corrosion
While inside containment on January 15,
1985,
an inspector observed
corrosion on a 10 inch diameter elbow located in the injection line
associated with Cold Leg Accumulator "B".
This corrosion gave a
freckled appearance to the external surface of this stainless steel
section of pipe.
The inspector expressed concern to licensee manage
ment that this corrosion should be evaluated to determine whether it
was a result of metal or chemical contamination and whether this
corrosion was detrimental to the pipe. The inspector was telephonically
informed by licensee management that a corporate metallurgist had
inspected this area of concern and tentatively identified the subject
corrosion as being resultant from chemical attack. Licensee management
3
further indicated that a chemical analysis was to be performed to
determine the causal agent.
The
inspector was
telephonically informed by the licensee on
January 24, 1985, that the chemical smears of the suspect area and dye
penetrant tests were acceptable.
(d) Corrosion of Seismic Supports
The inspector observed apparent corrosion of a seismic support
associated with the Service Water piping identified in subparagraph 5a
of this report.
This support was identified by the inspector to
licensee management.
The inspector expressed concern regarding
apparent galvanic corrosion of the hanger as a result of metal to metal
contact between the stainless steel Service Water piping and the carbon
steel support (sacrificial anode)
resulting in consumption of the
carbon steel and weakening of the support.
A review of the last in
service inspection of the support in 1982 performed under procedure
ISI-8-Rev. 8 indicated no remarkable corrosion.
A licensee certified visual inspector was sent to inspect the suspect
support.
The licensee inspector indicated that although there was
discoloration of the support, it was apparently due to past evaporation
(possibly of condensation) and that there was small indication of
corrosion on the hanger.
None was observed at the suspect area
identified by the inspector.
Furthermore,
it
was reported by the
licensee that the Service Water pipe did not make contact with the
support. The inspector had no further comments.
(e) The inspector reviewed selected inservice inspection pressure testing
procedures.
The inspector noted that the licensee categorizes leakage
as a deficiency or exception.
Leakage, or evidence of leakage, from
valve and pump packing glands without leakage collection systems, and
component mechanical connections within the area to be inspected are
identified as exceptions.
Deficiencies are flow impairments and
leakage, or evidence of leakage except as previously described as an
exception. The licensee routinely repairs deficiencies; however, the
determination to repair exceptions is left to the engineering judge
ment of the test coordinator. The inspector observed several instances
where mechanical fitting leakage had been categorized as an exception
without apparent corrective maintenance followup. The inspector stated
to licensee management that a good engineering practice would be to
followup all leakage identification with repair. The inspector did not
identify any violations or deviations in this area.
Violations and deviations were not noted in this area.
4
6. Non-Licensed Employee Training
The inspector reviewed the overall training and retraining activities for
non-licensed employees and general training for licensed employees to assure
conformance with the licensee commitments.
The following procedures from
the Training Instruction Manual were reviewed:
(a) "Retraining
and
Replacement Training for Non-licensed Operating
Personnel" Rev. 8 dated November 20, 1984.
The purpose of this procedure is to establish a retraining and replace
ment training program for the following personnel:
1.
Instrumentation and Control Technicians
2. Electricians
3. Mechanics
4.
E&RC Group
5. Auxiliary Operators
6. Stockroom personnel
This procedure met the requirement of ANSI-N18.1-1971.
(b) "Replacement Training for Instrumentation and Control Technicians and
Electricians" Rev. 8 dated August 29, 1984.
The purpose of this procedure is to provide for the qualification and
requalification training of plant I&C personnel and Electricians to
meet the minimum qualification requirements of ANSI-N18.1-1971 and any
additional requirements listed under NUREG-0737 Item II.B.4.
(c) "Replacement Training for Mechanics" Rev. 5 dated November 24, 1981.
The purpose of this procedure is to provide for the qualification and
requalification of the plant mechanics to meet the requirements of ANSI
Standard N18.1-1971.
(d) "Qualification
program for Auxiliary Operators"
Rev. 18 dated
October 5, 1984.
The purpose of this procedure is to provide a qualification program for
plant Auxiliary Operator as described in ANSI Standard N18.1-1971.
(e) "Qualification Program for Shift Engineer" Rev. 3 dated October 24,
1983.
The purpose of this procedure is to ensure the Shift Engineers are
provided with sufficient formal and on-the-job training to meet or
exceed the recommendations of NUREG-0578.
The review of these procedures revealed that an adequate program exists for
non-licensed personnel.
5
The inspector interviewed and reviewed the training records of several I&C,
Mechanics and Auxiliary Operator personnel.
The inspector confirmed that
the formal technical and on-the-job training was provided to the employees
as required by the licensee's committed program.
The inspector reviewed the Nuclear Safety Reviewers training course and
their training records to verify the qualifications of the reviewers.
A
letter from Guy P. Beatty, Jr., to Site Manager (Robinson File No. 13510H)
on January 10, 1985 identified a list of Qualified Nuclear Safety Reviewers.
These reviewers are authorized in accordance with Technical Specifications 6.5.1.1.4 to perform nuclear safety reviews of procedures, tests, experi
ments and modifications.
On the basis of the inspector's review of Modification packages 748 and 655
and a letter written by Guy P. Beatty, Jr. , on January 2, 1985 (Robinson
File No.
13510H)
where the Onsite Nuclear Safety (ONS)
Unit identified
deficiencies with some initial reviews, the ONS group has recommended to the
site management that all qualified safety reviewers be retrained beginning
the first quarter of 1985. The inspector could not determine the manner in
which qualified personnel are selected.
No written criteria was found to
identify the selection process and the required training for the qualified
personnel.
This item will be identified as Inspector Followup Item
(261/85-05-03).
7.
Licensed Operator Requalification Training
An inspection was performed in the area of Licensed Operator Requalification
Training in order to verify that the program is in conformance with NRC
requirements, that the program is properly implemented, and that the program
is technically adequate. With the exception of those specific deficiencies
noted herein, it was determined that in general the program was satisfactory
and that significant improvements had been made in this program over the
past five years. Training Instruction (TI) 200 defines and implements the
Licensed Operator Requalification Training Program which is divided into
four major sections:
preplanned lecture series, simulator retraining,
on-the-job training, and evaluation.
(a) The preplanned lecture series consists of 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of classroom
lectures which are repeated 4 to 6 times (as circumstances warrant)
annually. The lectures are conducted in accordance with a preplanned
schedule and formal detailed lesson plans and outlines. Provisions are
in place for ensuring that generic weaknesses noted in the previous
year's annual written requalification examination are factored into the
upcoming year's lectures.
The inspector was unable to attend lectures
since none were scheduled to be conducted during the inspection period.
A review of TI-200, a 1984 plant readiness summary which delineated the
1984 operator requalification program, selected lesson plans, exami
nations,
and records,
and interviews with selected operators and
training individuals indicated that the program is adequate and
complies with NRC regulations.
(b) The
simulator retraining consists of each licensed individual
participating in 2 sessions annually; each session being approximately
32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in length.
This training is conducted at the Harris E&E
6
Center on the Shearon Harris simulator and consequently could not be
observed by the inspector.
A review of TI-200, selected simulator
training evaluation records, and selected simulator control manipula
tion charts indicate that this training is in accordance with 10 CFR 55
Appendix A and the "Qualification of Reactor Operators" letter issued
by Harold R. Denton on March 28,
1980,
and is properly implemented.
One concern was addressed to training department management with
respect to simulator retraining.
This concern was that copies of the
control manipulation charts which specify the control manipulations
performed each year on the simulator by each licensed individuals and
which are maintained as records at the site by the Robinson training
department,
are not signed to certify correctness.
The inspector
considers that certification of these documents would be desirable for
record maintenance purposes.
(c) The on-the-job training consists of (1) a quarterly review of selected
Administrative Procedures,
Abnormal Operating Procedures,
Emergency
Operating Procedures,
Technical Specifications,
Environmental
and
Radiation Control Procedures,
Plant Emergency Procedures,
and Fuel
Maintenance Procedures,
(2) An annual walkthrough of control room
inaccessibility and loss of emergency
buses/station batteries,
(3) Required reading of appropriate design changes, facility license
changes, significant plant modifications,
procedure changes and
significant operating experiences and (4) for licensed staff personnel,
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> watch in the control room each month as an extra man on shift
(75% of which can be satisfied on the simulator).
A review of TI-200 and selected records yielded one concern in this
area regarding a licensed individual standing control room watches
subsequent to not actively performing the functions of an operator or
senior operator for a period in excess of four months.
states that if
a licensee has not been actively performing the
functions of an operator or senior operator for a period of 4 months or
longer,
he shall, prior to resuming activities licensed pursuant to
this part,
demonstrate to the commission that his knowledge and
understanding of facility operation and administration are satis
factory.
The Commission may accept as evidence, a certification by an
authorized representative of the facility licensee by which the
licensee has been employed.
The inspector noted one case where a licensed training instructor had
not stood watch as a shift complement member for approximately sixteen
months and then subsequently stood four 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> watches
(November 27 -
30,
1984)
as both the Shift Operator and Senior
Operator. There was no evidence of demonstration to the NRC that the
individual's knowledge and understanding of facility operation and
administration was satisfactory as specified in 10 CFR 55.31e.
The
licensee interprets the phrase actively performing the function of an
operator or senior operator in this application to mean that active
status will be maintained by participating in the annual requalifi
cation program (paragraph 3.1.7, TI-200).
Although for staff
personnel,
this includes an average of four hours per month in the
control room as an extra man on shift (75% of which can be satisfied on
7
the simulator), the inspector does not consider that the licensee's
interpretation of "actively performing functions of an operator or
senior operator" is a valid or adequate interpretation.
Consequently,
it
is considered in this case, that the licensee should
have demonstrated to the NRC that the individual's knowledge and
understanding of facility operation and administration was satisfactory
prior to his standing watch as a shift complement member in order to
meet the requirements of 10 CFR 55.31e.
This is classified as an
unresolved item (261/85-05-04)
pending
NRC evaluation and inter
pretation of what constitutes "actively performing the functions of an
operator or senior operator".
(d) The evaluation phase consists of an annual written qualification
examination,
oral examination (once every five years)
and,
where
necessary, accelerated training. In this area the inspector reviewed
annual written requalification examinations and accelerated training.
During the course of this review it
was noted that the four licensed
training staff personnel are routinely exempted from taking the annual
written
requalification examination since they participate in .
preparation and/or review of the annual requalification examination.
Specifically one of these individuals was exempted from the written
examination for the past 6 years, two for the past 3 years, and one for
the last year since becoming licensed as Senior Reactor Operator.
TI-200 requires that an annual written examination shall be admin
istered to all licensed personnel each calendar year and does not
contain any provision for exemptions unless an individual successfully
completes an NRC exam in less than 6 months prior to the requalifica
tion exam.
This condition was not met in the cases cited above.
Additionally, prior to 1983, Administrative Procedure 10.2 required
that a comprehensive written examination be given annually to each
licensed operator without any provisions for exemption.
This is contrary to 10 CFR 55 Appendix A and 10 CFR 50 Appendix B
Criterion V and is a violation (261/85-05-02).
A review of selected examinations and answers key reflected that for
those examinations reviewed, the questions were comprehensive.
It was
noted that a minimum of two examinations are made up and used during a
given requalification period.
A review of accelerated training for three individuals who failed the
1984 annual written requalification examination reflected that the
training was self study with a unique individual study plan directing
the study. This was considered adequate for the weaknesses noted in
the 1984 examinations for these individuals.
In all cases reviewed,
the involved individuals were removed from licensed duties, pending
completion of training and reexamination. A review of the new examina
tions indicated that they were adequate.
(e) At the exit interview, a concern was expressed with the fact that the
licensee was unable to demonstrate during the inspection that the NRC
had ever formally approved the Robinson licensed operator
8
requalification program.
Subsequently on January 22,
1985,
the
licensee produced documentation that the program was NRC approved by
letter dated January 30, 1974. This item is satisfactorily resolved.