ML14176A585
| ML14176A585 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/05/1981 |
| From: | Kellogg P, Mcdonald J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A579 | List: |
| References | |
| 50-261-81-02, 50-261-81-2, NUDOCS 8103310654 | |
| Download: ML14176A585 (12) | |
See also: IR 05000261/1981002
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION lI
101 MARIETTA ST., N.W., SUITE 3100
ATLANTA, GEORGIA 30303
Report No. 50-261/81-02
Licnsee: Carolina Power and Light Company
411 Fayetteville Street
Raleigh, NC
27602
Facility Name:
Robinson
Docket No. 50-261
License No.
Inspection at Robinson Facility near nartsvIIle, South Carolina
Inspector:
J. A. Mc~onald
Dat Sicn
.Approved by:
P...
K.0goog
Section CTefRONS Branch
Date Signed
SUMMARY
Inspection on January 5-9,
1981
Areas Inspected
This routine, announced inspection involved 26 resident inspector-hours on site
in the areas of licensee action on previous inspection findings and plant tour.
Results
Of the two areas inspected, no violations or deviations were identified in one
area; two violations were found in
one area (Technical
Specification 6.8.1
failure to control nonconforming
items paragraph 5.a.; Technical Specification 6.8.1 -
failure to identify instrumentation to which quality standards apply
paragraph
5.b.); one deviation was
found
in one area (failure to keep core
subcooling monitor installed as committed - paragraph 5.c.).
08
10 a a 1 0-o57
DETAILS
1.
Persons Contacted
Licensee Employees
- R. B. Starkey, Jr., General Manager
- D. H. Baur, Senior QA Specialist
- J. F. Benjamin, Operations Engineer
- C. A. Bethea, Training Supervisor
- R. H. Connally, Director, Nuclear Safety and QA
- C. W. Crawford, Manager, Operations and Ma-ntenance
- H. S. Zimmerman, Manager, Technical and Administrative
Other Oranizations
R. Muth, Westinghouse Engineer
- Attended exit in-erview
2.
Exit Interview
The inspection scope and findings were summarized on January 9, 1981 with
those persons indicated in Paragraph 1 above. The licensee acknowledged the
insOection findings. The General Manager commented that with respect to the
deviation discussed in paragraph 5.c., it had been CP&L's intent to keep the
system operable to the degree required by CP&L's proposed yet unapproved
Technical Specifications. The General Manager acknowledged that application
of this philosophy did not assure compliance with the commitments upon which
this deviation was based.
3. Licensee Action on Previous Tnspection Findings
(Closed) Deficiency (50-261/80-21-04):
Failure of operator requalification
program to assure operator cognizance of procedural and design changes. A
review of outstanding required reading in the control room indicated the
licensee was currently in compliance with this aspect of continuous operator
requalification. Therefore, the item of noncompliance is closed. However,
the licen'sees commitment to review a monthly status report of all reactor
operator license retraining commitments was not being met.
Until the
licensee includes the retraining requirements of 10 CFR 55,
Appendix A,
Section 3.c in the monthly status report, the October 7, 1980 commitment in
response to item 50-261/80-21-04 is not met and this item is open (50-261/
81-02-01).
4.
Unresolved Items
Unresolved items are matters about which more information is required to
k
determine whether they are acceptable or may involve noncompliance or
deviations.
A new unresolved item identified during this inspection is
discussed in paragraph 5.d.
3
5.
Plant Tour
The inspector observed control room operations including a review of the
status of equipment associated with actuated annunciator lights and the
status of equipment for which work authorized had been initiated.
Findings
were acceptable except as follows:
a.
Containment Pressure indicator PI-951 was identified as reading too low
by Work Authorization OP-5 on January 2, 1981. The instrument is fed
from the engineered safeguards circuitry utilized for containment
isolation. Therefore, nonconservative performance of this element of
the containment isolation circuitry was a possibility, yet the channel
was
allowed to
remain in service.
Around January 4,
1981 Work
Authorization OP-114 was written indicating that PI-951 was indicating
3.75 psi low based upon +0.75 psid actual containment to atmosphere
differential and -3.0 psid on PI-951.
The channel remained in service
until NRC inspection on January 7, 1981. These examples of failure to
control nonconforming items constitutes a violation (50-261/81-02-02).
During the course of the inspection the licensee completed immediate
corrective actions of investigating the problem.
The condition was
isolated to the nonprotective function of the indication meter,
therefore the possibility of nonconservative safety circuit operation
was not confirmed.
it was noted that log keeping practices were the measures established
to keep operating personnel informed of the status of instrumentation
declared out of service. However, no measures existed to indicate the
operating status of instrumentation which was considered to be going
out of tolerance indication yet was a reliable trend indicator or was
in error by a known amount.
The licensee should also address this
aspect of control of nonconforming instrumentation in response to this
item.
b.
The inspector noted inconsistent determination of safety classification
of instrumentation on work authorizations initiated by Control Room
personnel.
Section 2 of ANSI N45.2-1971 requires the identification of
items and services to which quality standards apply.
Plant Operating
Procedure, Appendix II is designated to provide this identification.
However,
safety related instrumentation was not identified, with the
exception of Nuclear Instrumentation.
Section 11.4 .2 of the procedure
gave only a guide for making the identification.
This failure to
identify instrumentation to which quality standards apply constitutes a
violation (50-261/81-02-03).
It was also noted from Section 3.1.3 of ENG-2
that Electrical
Components Controls and spare parts have apparently not been adequately
identified.
From discussion with licensee personnel the previously
completed identification of mechanical components needs updating to
4
reflect revisions to plant design.
The licensee should also address
identification of safety related items other than instrumentation in
response to this finding.
c. The core subcooling monitor consists or two channels which were
operational prior to the last refueling outage which ended in November
1980.
Modifications to improve the qualifications of the equipment
were initiated, however, not completed during the refueling outage. At
the time of the inspection on January 7, 1981 both channels were
administratively under control of the Instrumentation
and Controls
personnel.
One channel was energized and providing indication of
coolant saturation condition to the operators.
However, this single
channel was recognized to have muptliple signal input problemi.
One of
three pressure inouts was disabled.
One of two hot leg temperature
inputs was disabled (the third loop
s only used in the dergcized
channel).
Seven of eight core exit
nermocoupl es were disabled.
The
minimum Lessons Learned Short Term reauirements i cluded temoerature
indication from each not leg or multiple core ext
thermocouples. The
CP&L commitment was in excess of these n'umbe'rs of instruments.
Since
preplanned modi fication work reduced the capabi lity of the system below
the CP&L commitment and the minimum Lessons Learned requirement this is
considered a deviaiton (50-261/81-02-04).
The licensee took. immediate corrective action of restoring the
deenergized channel to service from a temporary power supply and
eventually its vital power supply during the course of this inspection.
d.
The Boron Injection Tank
(BIT)
low level alarm
appears to be
annunicating approximately three times a day.
This is indicative of
low level in a relatively low volume pot at the top of the BIT.
The
source of the gas filling this space and resulting in annunication that
the BIT is not full is not known.
Positive means of removal of the gas
is not provided. Operators pressurize the BIT to compress the gas and
encourage its dissolution to clear the annunciation. These efforts to
clear annunciations or to prevent them require excessive operator
attention and equipment operation. Until the licensee evaulates the
system design and operational problems associated with keeping the BIT
full and indicating full and implements appropriate corrective action
this item is unresolved (50-261/81-02-05).
'I,
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
.101 MARIETTA ST., N.W., SUITE 3100
ATLANTA, GEORGIA 30303
FEB - 9 1981
Carolina Power and Light Company
ATTN:
J. A. Jones
Senior Executive Vice President and
Chief Operating Officer
411 Fayetteville Street
Raleigh, NC
27602
Gentlemen:
Subject: Report Nos. 50-261/81-01 50-325/81-01, 50-324/81-01, 50-400/81-01,
50-401/81-01,
-402/81-01 and 50-403/81-01
This refers to the routine safety inspection conducted by V. L. Brownlee of this
office on January 6-9,
1981,
of activities authorized by NRC Operating License
Nos.
DPR-71 and Construction Permit Nos.
CPPR-158,
CPPR-159,
CPPR-160 and CPPR-161 for the H. B. Robinson,
Brunswick and Shearon Harris
facilities and to the discussion of our findings held with Messrs. P. W. Howe
and R. M. Parsons at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the
enclosed inspection report.
Within these areas, the inspection. consisted of
selective examinations of procedures and representative records, interviews with
personnel, and. observations by the inspector.
Within the scope of this inspection, no violations or deviations were disclosed.
We have examined actions you have taken with regard to previously identified
enforcement matters and unresolved items. The status of these items is discussed
in the enclosed report.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title
10, Code of Federal Regulations, a copy of this letter and the enclosed inspection
report will be placed in the NRC's Public Document Room.
If this report contains
any information that you (or your contractor) believe to be proprietary, it
is.
necessary that you make- a written application within 20 days to this office to
withhold such information from public disclosure.
Any such application must
include a full statement of the reasons on the basis of which it is claimed that
the information is proprietary, and should be prepared so that proprietary
information identified in the application is contained in a separate part of the
document.
If we do not hear from you in this regard within the specified period,
the report will be placed in the Public Document Room.
Should you have any questions concerning this letter, we will be glad to discuss
them with you.
Sincerely,
C.E. Murph
e
Reactor Construction and Engineering
Support Branch
Enclosure:
(See Page 2)
Carolina Power and Light Company
-2-
FEB -
1981
Enclosure:
Inspection Report Nos. 50-261/81-01,
50-325/81-01, 50-324/81-01, 50-400/81-01,
50-401/81-01, 50-402/81-01 and 50-403/81-01
cc w/encl:
R. B. Starkey, Jr., Plant Manager
A. C. Tollison, Jr., Plant Manager
R. Parsons, Site Manager
SpkREG(Q
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100
ATLANTA, GEORGIA 30303
FEB - 9 1981
Report Nos. 50-261/81-01, 50-325/81-01, 50-324/81-01, 50-400/81-01,
50-401/81-01, 50-402/81-01, and 50-403/81-01
Licensee: Carolina Power & Light Company
411 Fayetteville Street
Raleigh, NC
27602
Facility Names:
H. B. Robinson, Brunswick, and Harris
Docket Nos. 50-261, 50-324, 50-325, 50-400, 50-401, 50-402, and 50-403
License Nos. DPR-23, DPR-62, DPR-71, CPPR-158, CPPR-159, CPPR-160 and
CPPR-161
Inspection at General Offices- in Raleigh, NC and at Harris site near
Raleigh, North Carolina
Inspector: _
_
_
_
_
___
V. L.
ownlee
Daie Signed
Approved bv j
A 1gJ
TE. Conlon, Section Chief,. RC&ES Branch
Dite'Signed
SUMMARY
Inspection on January 6-9, 1981
Areas Inspected
This routine, unannounced inspection involved 25 inspector-hours on site in the
areas of closeout of previously identified enforcement matters, unresolved items
and.. inspection followup items.
Results
Of the three areas inspected,
no
items of noncompliance or deviations were
identified.
DETAILS
1.
Persons Contacted
Licensee Employees
- P. W. Howe, Vice President, Technical Services Department
- R. M. Parsons, Site Manager, Harris
- N. J. Chiangi, Manager, Engineering-and Construction QA
W. J. Dorman, Project.QA Specialist, Operations
S. McManus, Corporate Nuclear Safety and QA Audit
- L. I. Loflin, Manager, Harris Plant Engineering Section
- A. M. Lucas, Senior REsident Engineer, Harris
- G. L. Forehand, Principal QA Specialist, Harris
Other licensee employees contacted included four office personnel.
NRC Resident Inspector.
- G. Maxwell
- Attended exit interview
2. Exit Interview
The inspection scope and findings were- summarized on January 9, 1981 with
those persons indicated in Paragraph 1.
above.
3.
Licensee Action on Previous Inspection Findings
a.
(Closed)
Infraction-, 50-261/79-19-03,
-
The violation was
that CP&L had not developed and implemented appropriate procedures to
assure that:
deviations are evaluated per (21.21(a)(1)); the Director
or responsible- officer is informed per (21.21(a)(2));
the written
report to- the. Commission contain
the
required
information- per
(21.21(b)(3)); the required records are maintained per (21.51).
CP&L's letter of response and associated supplements dated November 2,
1979, November 21, 1979 and February 26, 1980 regarding this matter was
reviewed by RII and-found.to be acceptable.
The
inspector
held discussions
with responsible general office
personnel and. reviewed: the, following documents:
I. Corporate Procedure For Evaluating and Reporting of Defects and
Noncompliances in Accordance With 10
CFR 21,
Rev.
4, August. 5,.
1980.
2.
Power Supply Group, Nuclear Operations Department Procedure No.
No.-711, Evaluating and Reporting of Defects and Noncompliances in
Accordance With 10 CFR 21, Rev.
1., April 1, 1980.
2
3.
H. B. Robinson Administrative Instruction, Section 13 Instructions
For Compliance to 10 CFR 21.
4.
Nuclear Power Plant Engineering Department Procedure No.
3.11,
Handling of Reportable Items Under 10 CFR 21, Rev. 1.
The inspector concludes that
has
implemented
the corrective
actions identified in their letter of response regarding the develop
ment and implementation of appropriate procedures to meet the posting,
evaluating,
informing,
notifying,
reporting
and
record
keeping
requirements of 10 CFR 21.
b.
(Closed)
Infraction, 50-400/80-12-01; 50-401,
402,
403/80-10 -01,
No
Comprehensive System or Planned and Periodic Audits For Non-ASME Areas
CP&L's letter of response dated June 26, 1980 regarding this matter was
reviewed by RII and found to be acceptable.
The
inspector held discussions with responsible Corporate
Nuclear
Safety and QA Audit personnel,
reviewed the Non-ASME Master-Audit List,
reviewed completed Audit Report QAA-160-8 and reviewed preparations for
QAA/81-15 audit.
The inspector concluded that CP&L has implemented the
corrective, actions identified. in their letter of response dated June
26, 1980.
c.
(Closed) Infraction 50-400/80-12-02;. 50-401, 402, 403/80-10-02; Fai.lure
to. Properly Identify and Handle Audit. Nonconformances
CP&L's letter of response dated June. 26,
1980 regarding: this matter was.
reviewed. by RII. and found to be acceptable-..
The
inspector held. discussions with responsible Corporate Nuclear
Safety and QA Audit personnel and reviewed procedure QAAP-1,
Rev.
10,
May 14,
1980.
The: inspector concluded that CP&L has implemented the
corrective actions identified in their letter of response dated June
26, 1980..
d.
(Closed)
Unresolved
Item 50-400/80-12-10;
50-401,
402 403/80-10-10,
Licensee Identified Variences with ANSI. N45.2.2
CP&L submitted. on November 10,
1980 a letter- to NRR QA Branch des
cribing CP&L's. activities at the Harris plant which are not. in-
complete
agreement with ANSI N45.2..2 as required by. Section 1.8 of the SHNPP
PSAR.
Discussions with NRR *QA- Branch personnel
indicate that the
letter of clarificationfia cceptable0
The.inspector reviewed the November 10, 1980 letter and concluded that
it represents those: activities which are being performed at, present.
3
4.
Unresolved Items
Unresolved items were not identified during this inspection.
5. Reporting of Defects and Noncompliances (10 CFR 21 and 10 CFR 50.55(e)) for
Robinson (Part 21), Brunswick (Part. 21) and Harris (Part 21 and 50.55(e))
a. General
The purpose of this inspection was. to ascertain whether
CP&L,
and
appropriate responsible officers, has established and implemented
procedures-and other instructions as required to ensure compliance with
10 CFR 21. and 10 CFR 50.55(e) requirements relative to the reporting of
defects and noncompliances. Inspector determinations are based on the.
requirements of
10
CFR 21
as clarified by
staff positions in
Revision 1 and. additional IE guidance relative to 10 CFR
50.55(e).
b.
Documents Examined
1..
Corporate Procedure for Evaluating and. Reporting of Defects and.
Noncompliances in Accordance With 10 CFR. 21,
Rev.
4, August. 5,
1980.
2..
Power Supp-ly Group, Nuclear Operations. Department Procedure No.
7.11.,. Evaluating and Reporting of Defects and Noncompliances in
Accordance With 10 CFR 21, Rev. 3, April 1, 1980.
3. Administrative Procedure.AI-39, BSEP Program for Compliance to 10
CFR 21, Rev. 3, June 16, 1980.
4. H. B..
Robinson
Administrative
Instructions,
Section
13
Instructions for Compliance to 10 CFR 21.
5.
CP&L Technical Services Department Engineering and Construction QA
Procedure AQAS-5,
Reportable Items Under 10 CFR 50.55(e) and. 10
CFR 21, Rev. 3, September 17, 1980.
6.
CP&L Procedure for Evaluating Deficiences in Accordance With 10
CFR 50.55(e)-, Rev.. 9', September 9, 1980.
7..
SHNPP Adminis trative- Procedure No.. AP-1X-16,, Rev.
2., November 26,
1980, -SHNNP Site Processing of Items in Accordance with 10 CFR
50.55(e)- and 10 CFR 21.
8. Nuclear Power Plant Engineering Department Procedure
No.
3.11
Handling of Reportable Items Under 10 CFR 21, Rev. 1.
9. Nuclear Power Plant Engineering Department
Procedure No.
3.9,
Handling of Reportable Items Under 10 CFR 50.55(e), Rev. 1.
4
c.
Program Review
The inspector. reviewed, the above controlling procedures and verified
that procedures
have been established to assure that the following
requirements of 10 CFR 21 will be met; the posting (21.6),
evaluating
deviations (21.21.(1)), informing the director (21.21(a)), assure that
the director will notify the Commission (21.21(b)), and to assure that
procurement documents specify that. provisions of 10 CFR Part 21 will
apply when applicable (21.31),
maintenance of records (21.51(a)),
and
disposition of records (21.51(b)).
The inspector also verified that
procedures have been established to assure that 10 CFR 50.55(e) identi
fication, evaluation and reporting requirements will be met..
d.
Program Implementation
The inspector held discussions with the above responsible managers,
engineers, QA and QC. personnel and examined the above noted areas for
posting, audits and audit findings, nonconformances and evaluations,
vendor and other sources of input, notification documentation,
and
reports to verify procedure implementation.
Based on the above program review and evaluation implementation the
inspector concludes:
1. Responsible personnel at the site and General Offices are quite
knowledgeable of Part 21 requirements..
2. Responsible personnel understand CP&LPart 21 procedures.
3. The procedures areradequate .
The inspector has no further questions regarding this matter.
6.
(Closed) Inspector- Followup Item 50-400/80-12-03;, 50-401, 402, 403/80-10-03,
Audit.Frequency rncorrently Specified in QAAP-1
QAAP-1 procedure has been revised to meet the ANSI Standard requirement for
annual audits of internal activities.
7.
(Closed) Inspector Followup Item 50-400/80-12-04; 50-401, 402, 403/80-10-04,
Modification of QA Monitoring Program- Procedures
Site QA- personnel- have- reviewed, applicable site procedures. and revised.
CQA-6,
CQA-10,
CQA-11,
CQA-12 and CQA-13 to define responsibility for
scheduling and documenting the monitoring of activities. Therdiscipline: QA
specialist has, been
assigned the
responsibility
for scheduling the
monitoring of the activities based on work in progress.
The inspector checked two area disciplines and found no discrepancies.
5
8.
(Closed)
In'spection
Follow-up
Item,
50-400/80-12-08;
50-401,
.402,
403/80-10-08, Laydown Storage
CP&L is performing a monthly surveillance of the laydown storage area
relative to proper- identification and equipment status.
The inspector
performed
an
inspection
of
the
laydown storage area and found no
discrepancies..
9.
(Closed) Inspector Followup Item 50-400/80-12-11; 50-401., 402, 403/80-10-11,
QA/QC Site Organizational/Functional Alignment
CP&L submitted on September 19,
1980 a letter to NRR QA Branch describing
the variances of CP&L's in place QA organization from that described in the
PSAR. Discussions with NRR QA Branch personnel indicate that the letter of
clarification is acceptable. The inspector reviewed the September 19, 1980
letter and concluded that it represents that organization which is presently
in place.