ML14176A745
| ML14176A745 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 07/07/1989 |
| From: | Dance H, Garner L, Jury K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A744 | List: |
| References | |
| 50-261-89-10, NUDOCS 8907180383 | |
| Download: ML14176A745 (8) | |
See also: IR 05000261/1989010
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION il
101 MARIETTA ST., N.W.
ATLANTA, GEORGIA 30323
Report No.:
50-261/89-10
Licensee:
Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC 27602
Docket No.:
50-261
License No.: DPR-23
Facility Name: H. B. Robinson
Inspection Conducted: May 11- June 13, 1989
Inspectors:71
/9
L. W. Garner, Senior R
enX4 nspector
Oatd Signed
K- R Jury
Resident I f0ectof
Da e Signed
Approved by:
__
4_____
7/I
H. C. Dance, Section Chief
te Signed
Division of Reactor Projects
SUMMARY
Scope:
This routine, announced inspection was conducted in the areas of operational
safety verification, surveillance observation, maintenance observation,
engineered safety feature system walkdown,
and emergency diesel generator fuel
oil quality.
Results:
Breakdowns in the licensee's corrective action program were identified.
A
violation was issued for failure to promptly identify and correct three
conditions adverse to quality, paragraph 2.a and b.
Repair activities of the B component cooling system heat exchanger were well
planned and coordinated, paragraph 2.a.
9O718038 890707
GDR ADOCK 05000261
PNU
REPORT DETAILS
1. Persons Contacted
- D. Crook, Senior Specialist, Regulatory Compliance
- J. Curley, Director, Regulatory Compliance
C. Dietz, Manager, Robinson Nuclear Project
J. Eaddy, Supervisor, Environmental and Chemistry
R. Femal , Shift Foreman, Operations
W. Flanagan, Manager, Design Engineering
W. Gainey, Supervisor, Operdtions Support
- E. Harris, Director, Onsite Nuclear Safety
D. Knight, Shift Foreman, Operations
D. McCaskill, Shift Foreman, Operations
R. Moore, Shift Foreman, Operations
R. Morgan, Plant General Manager
- C. Mosely, Corporate Manager, Operations Quality Assurance
D. Myers, Shift Foreman, Operations
D. Nelson, Maintenance Supervisor, Mechanical
R. Powell, Engineering Supervisor, Technical Support
- D. Quick, Manager, Maintenance
D. Seagle, Shift Foreman, Operations
- J. Sheppard, Manager, Operations
R. Steele, Operations Coordinator
D. Winters, Shift Foreman, Operations
- H. Young, Director, Quality Assurance/Quality Control
Other licensee employees contacted included technicians, operators,
mechanics, security force members, and office personnel.
- Attended exit interview on June 21, 1989.
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2. Operational Safety Verification (71707)
The inspectors evaluated licensee activities to confirm that the facility
was being operated safely and in conformance with regulatory requirements.
These activities were confirmed by direct observation, facility tours,
interviews and discussions with licensee personnel
and management,
verification of safety system status, and review of facility records.
To verify equipment operability and compliance with TS,
the inspectors
reviewed shift logs, operation records, data sheets, instrument traces,
and records of equipment malfunctions.
Through observations of work and
discussions with operations staff members,
the inspectors verified the
staff was knowledgeable of plant conditions, responded properly to alarms,
2
adhered to procedures and applicable administrative controls, cognizant of
in-process surveillance and maintenance activities, and aware of inoperable
equipment status.
The inspectors performed channel verifications and
reviewed component status and safety-related parameters
to verify
conformance with TS.
Shift changes were routinely observed.
Access to
the control room was controlled and operations personnel carried out
their assigned duties effectively.
Plant tours and perimeter walkdowns were conducted to verify equipment
operability, assess the general condition of plant equipment,
and to
verify that radiological controls, fire protection controls, physical
protection controls,
and equipment tagging procedures were properly
implemented.
a. CCS Leakage Into The SW System
On June 2, 1989, while conducting a survey on closed cooling systems,
the inspectors identified that the CCS surge tank was being made-up
on an abnormally frequent basis.
Water is normally only added to
the CCS after maintenance which requires partial system draining.
Operations personnel informed the inspectors that the surge tank was
being made-up (i.e., reaching 45% low level alarm set-point and being
filled to approximately 50% level) every two weeks. Upon questioning
the effect these additions had on CCS chemistry, the inspector
contacted the Chemistry Department; the Chemistry Department was
unaware of these additions.
The CCS chemistry was then analyzed and
found to be out of specification for both chromates (corrosion
inhibition) and ph.
These two parameters are monitored to prevent
corrosion and fouling of the CCS piping and components, which could
result in decreased CCS heat removal capability. Upon investigation,
it was determined that approximately 100 gallons were being added to
the CCS approximately every 2 1/2 days since April 30,
1989.
The
unusual number of additions indicated that there was leakage from the
CCS. The inspectors questioned Operations about possible CCS leakage
pathways. The inspector and an SRO walked down portions of the CCS
piping outside of Cv; however, the leakage source was not located.
Chromates were not identified in the waste hold-up tank, which would
have indicated a leak inside of Cv.
After returning chromate concentrations and ph to within specifica
tions, Chemistry monitored chromate concentrations in the CCS on a
daily basis for the next five days.
It was determined that the
chromate concentration was continually decreasing, verifying the
presence of a leak.
On June 6, Operations isolated the A and B CCS
heat exchangers and discovered that B heat exchanger was, in fact,
leaking into the SW system. On June 13, during repairs to the B CCS
heat exchanger, six tubes were found to be leaking and were
subsequently plugged.
This repair effort was well planned and
coordinated effectively between Operations, Maintenance and Chemistry.
3
The Chemistry Department was prompt in responding to the inspectors'
concerns and communicated effectively with Operations concerning this
matter.
Since the repair, there has been no further indications of
CCS leaks.
This situation resulted in several problems being identified.
The
first has to deal with operator recognition that there was a leak
from the CCS. The licensee's operation shift schedule is not conducive
to one particular shift recognizing the unusual number of times
additions were made to the CCS; all but two of the required log
entries were recorded into the CO's log book.
At the end of each
shift the shift foreman initials the log entries for that respective
shift, acknowledging cognizance of the evolutions performed.
Additionally, as part of shift turnover, the oncoming CO documents
that he/she has "reviewed previous shifts logs".
As a result, each
time a CCS addition was logged, at least three individuals were
acknowledging each respective make-up that was logged.
Between
April 30 - June 2, 1989, there were at least thirteen make-ups to the
CCW system; thus, there were thirty-nine instances (sometimes the same
operators) of implicit acknowledgement of CCS make-ups occurring.
Additionally, there is not evidence that these additions were verbally
communicated between shifts. There was not an investigation/corrective
action initiated until June 2, 1989, when the possibility of a CCS
leak was raised by the inspectors. The failure to promptly identify
and correct the CCS leak is a violation:
Failure to Promptly Identify
and Correct Conditions Adverse to Quality, 89-10-01.
The
fact
that
there
was
not a control
mechanism
triggering Operations to notify the Chemistry department when a CCS
addition was performed, resulted in CCS chemistry being driven out of
specification and delaying prompt leakage identification. Chemistry
samples the CCS on a monthly basis, and if not notified when the
system chemistry is diluted, has no control over maintaining chemistry
specifications.
Corrective action for this violation should address
this problem.
b. Inadequate and Untimely Corrective Action on Valves TCV-144 and
CC-832
As part of the CCS walkdown,
the non-regenerative heat exchanger
piping and valves were inspected to verify the absence of potential
leakage sources.
The inspector noted a deficiency tag written on
TCV-144, the non-regenerative heat exchanger outlet TCV, indicating
that the valve had a packing leak. Upon inspection (by the inspector,
4
an SRO,
and regulatory compliance) it was determined that the valve
was not leaking.
Review of the past year's WRs on this valve
revealed the following sequence of events:
WR/JO#
Date
Problem Identified
Corrective Action
Implemented (Date)
88-AJHC1
09/07/88 Valve failed stroke
New packin
test
installed (9/12/88)
88-AKHJ1
10/02/88 Valve has a packing
Adjusted packing to
leak
stop leak (10/17/88)
89-AEGC1
04/07/89 Valve failed stroke
Shaft lubricated and
test
packing glands
loosened (04/08/89)
89-AFCM1
05/13/89 Valve has a packing
Adjusted packing to
leak
stop leak (05/31/89)
89-AFMJ1
05/31/89 Valve failed stroke
Lubricated stem and
test
loosened packing
glands (06/13/89)
Based on the above sequence of events, it appears that the corrective
action implemented for each respective WR had an adverse effect on
the valve, resulting in the subsequent WR being initiated.
In
addition, after the packing was adjusted to stop the leak on
October 17, 1988, there was not a post-maintenance test performed to
verify the valve would stroke in the required time.
The failure to
take adequate corrective action to preclude this situation from
recurring (i.e., failing to stroke, packing leak, failing to stroke,
etc....) is considered an example of Violation 89-10-01, Failure to
Promptly Identify and Correct Conditions Adverse to Quality.
While reviewing the
CCS leak discussed in paragraph 2.a,
the
inspectors noted that Valve CC-832, the CCS surge tank make-up valve,
did not always fully close (with the PW pump running) after the CCS
was made-up; thus, allowing an excessive amount of PW to enter the
surge tank.
This condition could mask a leak out of the system,
exacerbated chromate concentration dilution of the system,
and
prevented an accurate leakage rate from being determined.
The
failure of this valve to fully close was first identified in February
1988. Subsequent to this identification, WR 88-AEKC1 was written on
April 9, 1988. On April 13, 1988, EWR 324 was written by maintenance
addressing the fact that no torque switch setting was provided in the
WR nor in procedure CM-111 Rev. 5, Limitorque Limit Switch and Torque
Switch Maintenance.
Maintenance. requested Engineering action by
eI
5
May 1, 1988, as the "leaking valve could possibly cause the CCS surge
tank to overfill."
As of June 8, 1989,
the Technical Support
Department had not dispositioned this EWR for resolution, as it was
not considered a priority work item. However, after discussions with
several operators, it became apparent that this valve had not fully
closed on several occasions, resulting in the CCS surge tank reaching
its high level alarm setpoint. The operators have had to perform the
abnormal evolution of closing this valve after stopping the PW pump
(versus closing the valve then stopping the pump) for the past
sixteen months. According to the operators, this evolution was not
always performed correctly or the valve would not fully close,
resulting in the overfills described above. The fact that Engineering
did not perform an evaluation of this valve's inability to close for
over sixteen months is considered another example of Violation
89-10-01, Failure to Promptly Identify and Correct Conditions Adverse
to Quality.
One violation, with three examples, was identified.
3. Monthly Surveillance Observation (61726)
The inspectors observed certain safety-related surveillance activities on
systems and components to ascertain that these activities were conducted
in accordance with license requirements.
For the surveillance test
procedures listed below, the inspectors determined that precautions and
LCOs were adhered to; the required administrative approvals and tagouts
were obtained prior to test initiation; testing was accomplished by
qualified personnel in accordance with an approved test procedure; test
instrumentation was properly calibrated; the tests were completed at the
required frequency; and that the tests conformed to TS requirements. Upon
test completion,
the inspectors verified the recorded test data was
complete, accurate, and met TS requirements; test discrepancies were
properly documented and rectified; and that the systems were properly
returned to service.
Specifically, the inspectors witnessed/reviewed
portions of the following test activities:
o
OST-10 (revision 9)
Power Ranger Calorimetric During Power
Operation
o
OST-051 (revision 10)
Reactor Coolant System Leakage Evaluation
o
OST-905 (revision 4)
Reactor Coolant Flow Protection Channel
Testing
No violations or deviations were identified.
6
4. Monthly Maintenance Observation (62703)
The inspectors observed safety-related maintenance activities on systems
and components to ascertain that these activities were conducted in
accordance with TS,
approved procedures,
and appropriate industry codes
and standards.
The inspectors determined that these activities did not
violate LCOs and that required redundant components were operable.
The
inspectors verified that required administrative, material,
testing,
radiological, and fire prevention controls were adhered to.
In addition
to those WRs discussed in paragraph 2, the inspectors also observed/reviewed
the following maintenance activities:
o
MST-006 (revision 4)
Reactor Coolant Flow Protection Channel
Testing
0
WR/JO 89-AETP1
Repair FT-436C Instrument Loop
No violations or deviations were identified, except as noted in
paragraph 2.
5. ESF System Walkdown (71710)
The inspectors performed a field walkdown of selected portions of the SW
system
shown
on drawings
G-190199
sheets 3,5,6,7,9,10, and
11.
Specifically, the inspectors examined selected components in the SI pump
room, CCS room, auxiliary building, and turbine building.
Items examined
included pumps,
valves, piping, pipe supports,
instrument tubing, and
component tagging.
The inspectors verified that major valves were in their
correct position, manual valves were locked as required, and instrumenta
tion was valved into service.
No-violations or deviations were identified.
6. Proper Receipt, Storage, and Handling of EDG Fuel Oil (255100)
In reviewing the EDG fuel oil controls, the inspectors reviewed the
licensee's Operations QA/QC Surveillance Report 89-019, Proper Receipt,
Storage,
and Handling of Emergency Diesel Generator Fuel Oil.
This
surveillance verified compliance to FSAR and TS requirements and commit
ments concerning EDG fuel oil.
The inspectors also reviewed the ONS OEF
Evaluation of IEN 87-04, Diesel Generator Fails Test Because of Degraded
Fuel.
The surveillance report adequately detailed how -the licensee
addressed the questions contained in TI 2515/100 Appendix A.
The QA/QC
surveillance appeared to be very thorough and all discrepancies identified
were documented and tracked within the licensee's corrective action
program.
No violations or deviations were identified.
________________________________I
7
7. Exit Interview (30703)
The inspection scope and findings were summarized on June 21, 1989, with
those persons indicated in paragraph 1.
The inspectors described the
areas inspected and discussed in detail the inspection findings listed
below and in the summary. Dissenting comments were not received from the
licensee. Proprietary information is not contained in this report.
Item Number
Description/Reference Paragraph
89-10-01
VIO - Failure to Promptly Identify and Correct
Conditions Adverse to Quality (paragraph 2.a
and b)
8. List of Acronyms and Initialisms
Component Cooling System
CFR
Code of Federal Regulations
Corrective Mainteance
CO
Control Operator
Cv
Containment
Engineered Safety Feature
Engineering Work Request
IEN
Inspection & Enforcement Information Notice
LCO
Limiting Condition for Operation
Maintenance Surveillance Test
NRC
Nuclear Regulatory Commission
OEF
Operational Experience Feedback
Onsite Nuclear Safety
OST
Operations Surveillance Test
PH
Hydrigen ion concentration
PW
Primary Water
Safety Injection
Senior Reactor Operator
Temperature Control Valve
TS
Technical Specification
Updated Final Safety Analysis Report
Unresolved Item
Violation
WR/JO
Work Request/Job Order