ML14176A870
| ML14176A870 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 05/08/1990 |
| From: | Conlon T, Merriweather N, Mark Miller NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A869 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 50-261-90-08, 50-261-90-8, NUDOCS 9005230328 | |
| Download: ML14176A870 (14) | |
See also: IR 05000261/1990008
Text
tNF4 REGb4
UNITED STATES
NUCLEAR REGULATORY COMMISSION
o
AREGION
II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report No.: 50-261/90-08
Licensee: Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC 27602
Docket No.:
50-261
License No.:
Facility Name: H. B. Robinson
Inspection Conducted: April 16-20, 1990
N. Merriweather
Date Signed
M.C . Miller
Date Signed
Approved by(CiY
e&-
-
-
91 '
T. E. Conlon,-Chief
Date Signed
Plant Systems Section
Engineering Branch
Division of Reactor Safety
SUMMARY
Scope:
This special, announced inspection was conducted in the areas of the licensee's
conformance to Regulatory Guide (RG)
1.97,
Instrumentation for Light-Water
cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and
Following an Accident and previously identified open items.
Results:
In the areas inspected, violations or deviations were not identified.
The licensee has performed the necessary installation or modification of plant
instruments to comply with Regulatory Guide 1.97, Revision 3 and/or the SER and
their submittals to NRC.
The program was considered adequate with the
exception of a few minor weaknesses as described below.
Management
acknowledged the concerns and committed to provide both short term and long
term corrective action which was considered acceptable by the inspectors. In
addition, the licensee was extremely cooperative in resolving these technical
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2
RG 1.97 Master Equipment List an excellent reference document to assess the
requirement for RG 1.97 equipment. Although the inspectors considered some of
the licensee's activities in this area to be weak, overall the program was
considered to be average. Weaknesses considered in the licensee's program are
as follows:
Weaknesses:
The electrical drawings are inconsistent.
The calibration program does not require verifying signals from
loops to ERFIS computer output.
Q-list does not identify by tag number all RG 1.97 instruments.
Not all
RG 1.97 instruments and indicators are uniquely
identified and labeled.
Containment water level and pressure recorder is not tagged and
has been out of service for over a year.
The strengths and weaknesses are discussed further in paragraph 2.b.
REPORT DETAILS
1. Persons Contacted
Licensee Employees
- C. W. Coffman, Project Engineer - Onsite Nuclear Safety
- T. P. Kinnamn, Engineer Supervisor - Technical Support
- J. D. Kloosterman, Director - Regulatory Compliance
- L. Lynch, QC Supervisor
- R. E. Morgan, Plant General Manager
- M. F. Page, Manager - Technical Support
- F. Roy, Engineer - Technical Support
- J. J. Sheppard, Manager - Operations
R. Shoemaker, Project Engineer - Operations
- R. M. Smith, Manager - Maintenance
- D. C. Stadler, Onsite Licensing Engineer
- K. Williams, Senior Engineer - Technical Support
Other licensee employees contacted during this inspection included
engineers, operators, technicians, and administrative personnel.
NRC Resident Inspectors
- L. Garner, Senior Resident Inspector
K. Jury, Resident Inspector
- Attended exit interview
2. Inspection of Licensee's Implementation of Multiplant Action A-17:
Instrumentation for Nuclear Power Plants to Assess Plant and Environs
Conditions During and Following an Accident (Regulatory Guide 1.97)
(25587).
Criterion 13,
"Instrumentation and Control," of Appendix A to 10 CFR
Part 50 includes a requirement that instrumentation be provided to monitor
variables and systems over their anticipated ranges for accident
conditions as appropriate to ensure adequate safety.
Regulatory
Guide 1.97 (RG 1.97) describes a method acceptable to the NRC staff for
complying with the Commission's regulations to provide instrumentation to
monitor plant variables and systems during and following an accident.
The licensee responded to Reg Guide 1.97 (NUREG 0737, Supplement 1) in
letters dated December 31,
1984, July 18,
1985, July 28,
1986,
and
October 20, 1986. A Safety Evaluation Report covering the above responses
was issued to the licensee on March 5, 1987.
The SER concluded that the
licensee's instrumentation for RG 1.97 either conforms to, or an
acceptable justification exists, for deviating from the guidance of
Regulatory Guide 1.97, Revision 3 with
the exception of the
2
instrumentation for containment sump water temperature,
which will be
evaluated by NRC on a generic basis.
This inspection assessed the
licensee's
RG 1.97 instrumentation system using (1) the design and
qualification criteria described in Table 1 of RG 1.97,
Revision 3;
(2)
Technical
Evaluation Report No. EGG-NTA-7113, conformance to
Regulatory Guide 1.97 H. B. Robinson Steam Electric Plant, Unit 2; and
(3) licensees' submittals as described above; and (4) 10 CFR 50. A random
sample of 22 variables from the licensee's submittal were selected to
evaluate the licensee's program. The variables selected were classified
as Category 1 and 2 which require the most stringent design requirements
of all Reg Guide 1.97 instruments.
The instruments reviewed and the
results achieved are discussed in the paragraphs and tables below.
a. Category 1 and 2 Instruments
The instrumentation listed in the following Tables were examined to
verify that the design and qualification criteria of RG 1.97 or the
SER and licensee commitments had been satisfied. The instrumenta
tion was inspected by reviewing drawings, procedures, data sheets,
and other documentation; and performing walkdowns for visual observa
tion of selected installed equipment including CR indicators and
recorders. The following areas were inspected:
(1) Equipment Qualification - The EQ Master Equipment List and the
Q-list were reviewed for confirmation that the licensee had
addressed environmental qualification requirements and seismic
qualification.
A concern was identified in this area as
discussed in paragraph 2.b.
(2) Redundancy -
Walkdowns were performed to verify by visual
observation that selected instruments were installed as
specified and that separation requirements were met.
In
addition, loop drawings for all listed Category 1 instrumenta
tion were reviewed to verify redundancy and channel separation.
(3) Power Sources -
Loop drawings were reviewed to verify the
instrumentation is energized from a safety-related power source.
(4) Display and Recording - Walkdowns were performed to verify by
visual observation that the specified display and recording
instruments were installed.
Loop drawings were reviewed to
verify there was at least one recorder in a redundant channel
and two indicators, one per division (channel).for each measured
variable. A concern was identified in this area as discussed in
paragraph 2.b.
(5) Range - Walkdowns were performed to verify the actual range of
the indicator/recorders was as specified in RG 1.97 or as stated
in the licensee's submittal.
Review of calibration procedures
verified sensitivity and overlapping requirements of RG 1.97 for
instruments measuring the same variable.
3
(6)
Interfaces
-
The loop drawings and Q-list were reviewed to
verify that safety-related isolation devices were used when
required to isolate the circuits--from non-safety systems.
(7) Direct Measurement -
Loop drawings were reviewed to verify that
the parameters are directly measured by the senors.
(8) Service, Testing, and Calibration - The maintenance program for
performing calibrations and surveillances was reviewed and
discussed with the licensee.
Calibration and surveillance
procedures and the latest data sheets for each instrument were
reviewed to verify the instruments have a valid calibration.
A
concern
was identified in this area
as discussed in
paragraph 2.b.
(9) Equipment Identification - Walkdowns were performed to verify
that types A, B and C instruments designated as Categories 1 and
2 were specifically identified with a common designation on the
control panels.
A concern was identified in this area and is
discussed in paragraph 2.b.
CATEGORY 1 INSTRUMENTS
Variable
Instrument Number, Channel or Train
Neutron Flux
RE-582
RI-590 & 592
RR-594
RE-583
RI-591 & 593
RR-594
Reactor Coolant Pressure (Wide Range)
PT-402
PI-402
PR-444
PT-501
PI-501
4
Variable
Instrument Number, Channel or Train
(cont'd)
Core Exit Temperature
TE-472-496
TE-523-528
TM-578
TM-579
TR-581
TI-579(A)
TI-580(B)
Refueling Water Storage Tank Level
LT-948
LI-948
LT-969
LI-969
ERFIS
Containment Hydrogen Concentration
AET-8100-1
(PAM Panel)
AI-8100-1
AR-(Not Tagged)
PT-8100-1
AET-8110-2
)AI-8110-2
AR-(Not Tagged)
PT-8110-2
Steam Generator Level (Narror Range)
LT-474
LI-474
LT-475
LI-475
LT-476
LI-476
FR-478
LT-484
LI-484
LT-485
LI-485
LT-486
LI-486
FR-478
LT-494
LI-494
LT-495
LI-495
LT-496
LI-496
FR-478
5
Variable
Instrument Number, Channel or Train
(cont'd)
Steam Generator Pressure
PT-474
PI-474
PT-475
PI-475
PT-476
PI-476
PT-484
PI-484
PT-485
PI-485
PT-486
PI-486
PT-494
PI-494
PT-495
PI-495
PT-496
PI-496
ERFIS
Reactor Coolant System Hot Leg
TE-413
Temperature
TI-413C
TR-413
TE-423
TI-423
TR-413
TE-433
TI-433
TR-413
Reactor Coolant Cold Leg
TE-410
Temperature
TI-410
TR-410
TE-420
TI-420
TR-410
TE-430
TI-430
TR-410
Pressurizer Level
LT-459
LI-459
LR-459
LT-460
LI-460
LR-459
LT-461
LI-461
LR-459
6
Variable
Instrument Number, Channel or Train
(cont'd)
Containment Pressure
PT-956
(PAM Panel)
PI-956
PR-(Not Tagged)
PT-957
PI-957
PR-(Not Tagged)
Containment Water Level
LT-801(A-E)
LI-801
LR-(Not Tagged)
LT-802(A-E)
LI-802
LR-(Not Tagged)
CATEGORY 2 INSTRUMENTS
Variable
Instrument Number, Channel or Train
Primary Safety Relief Valves
RC-551A
Position (Accoustical Flow Switches)
RC-551B
RC-551C
Primary Power
PCV-455C
Operate Relief
PCV-456
Valves (PORV) Position
Limit Switches
Residual Heal Removal (RHR)
TE-606
Heat Exchanger Outlet
TR-604
Temperature
FT-605
Flow
FI-605
Heat Removal by the
HVH-1
Containment Fan Heat
HVH-2
Removal System
HVH-3
Fan Motor Status
HVH-4
(Switches & Indicating Lights)
FT-958A
Flow
FI-958A
FT-958B
FI-958B
7
Containment Cooling
DPS-1698A
Service Water Low Flow
ANN-A2-8
(Annunciator - ANN)
DPS-1698B
ANN-A2-1
DPS-1698C
ANN-A2-24
DPS-1698D
ANN-A2-32
Charging Flow
FT-122
FI-122A
Containment Isolation
All Valves
Valves Position
Limit Switches
b. Discussion and Conclusion
The inspectors concluded that the licensee has made the necessary
installation and/or modifications of plant instruments to comply with
Regulatory Guide 1.97, Revision 3 as described in their responses to
NRC and as discussed in the SER. The implementation of their RG 1.97
program was considered adequate in most areas, with the exception of
a few minor weaknesses in the areas of Q-list identification, ERFIS
calibration, equipment identification, drawings, and maintenance. To
resolve these weaknesses the licensee management committed to certain
short term and long term corrective actions.
The inspectors
considered these commitments acceptable to resolve all concerns. A
brief discussion of the areas reviewed and the results achieved
including any licensee commitments are summarized below:
(1) Q-1ist
The inspectors reviewed the Q-list for those Reg Guide 1.97
instruments identified in the tables above. In many instances,
the Q-list did not specifically list Category 1 and 2
instruments by "Tag Number".
Instead the Q-list specified
equipment on the process flow drawings as being classified Q.
The inspectors determined this method was not satisfactory and
the licensee agreed to correct the Q-list.
The licensee agreed
to specifically list all RG 1.97 Category 1 and 2 instruments by
tag numbers.
This corrective action will be completed in two phases.
The
short term phase is to add within three months all Category 1
and Category 2 safety-related variables to the Q-list. The long
term phase is to add all non-safety related Category 2 variables
to the Q-list within 18 months.
8
(2) Calibration Program for RG 1.97 Instruments
The inspectors reviewed the instrument calibration program,
calibration procedures, and data sheets for RG 1.97 instruments.
These documents were found to be satisfactory except for the
calibration method used for the ERFIS computer.
The licensee's
method is to calibrate the ERFIS computer inputs and the
instruments loops independently of each other.
This does not
require the technicians to verify the computer reading during
the loop calibration.
The inspectors did not consider this
practice to be acceptable for the following instrument channels
described in their submittal:
o
Containment Spray Addition Tank Level (Al)
o
Steam Generator Pressure (Al)
o
Condensate Storage Tank (CST) Level (Al)
O
Refueling Water Storage Tank Level (Al).
o
Containment Isolation Valve Position (Bl)
o
RCDT Temperature or Pressure (C3)
o
En ineered Safety Features (ESF) Actuated Valve Position
(D3)
O
Liquid Hold-up Tank Level (D3)
O
Gas Decay Tank Pressure (D3)
o
Emergency Ventilation Damper Position (D2)
o
DC Bus Voltage and Current (MCC A/B) (D2)
O
Plant Vent Flow Rate (E3)
For those instruments identified above the licensee specifically
states in their submittal that trend information or indication
on demand will be provided by the ERFIS computer. Based on the
above statements it appears that the licensee has taken credit
for ERFIS providing recording or indication for RG 1.97
instrument loops.
Based on this assessment the inspectors
concluded that the output of the loops to the ERFIS computer
should be calibrated to verify accuracy of the computer output
the same as the other recorders or indicators in the instrument
loop.
Subsequent to the inspection, during a conference call
with NRC staff on May 3, 1990,
the licensee made verbal
commitments to validate the ERFIS outputs for the containment
water level and containment pressure channels prior to the end
of the next refueling outage and to revise procedures by
December 31,
1991,
to validate 132 limit switches of 66
containment isolation valves and .25 various other instruments
including the containment water level and containment pressure
channels. The NRC staff considered this to be acceptable based
on the licensee's current plans to upgrade procedures.
(3)
Drawings
The controlled wiring drawings
(CWD)
and the Hagan instrument
loop drawings were reviewed by the inspectors to verify adequacy
and determine power requirements. The inspectors noted that the
licensee did not have a CWD for the Post Accident Monitoring
(PAM) panel detailing 120 VAC power. However, the licensee did
have a sketch (no.
M872-E-3640)
from the plant modification
package detailing the power to and within the PAM panel.
The
inspectors did not consider this as an acceptable way to control
drawings.
The inspectors verified the power requirements by
walking down the PAM panel and reviewing other documentation.
The licensee acknowledged the inspectors concerns and agreed to
review and revise the CWDs as appropriate for the PAM panel by
July 27, 1990.
In addition, the licensee agreed to review and
revise as appropriate all other Hagan drawings within a year.
This will entail reviewing approximately 30 to 50 drawings.
(4) Equipment Identification and Labeling
The inspectors toured the control room and examined the selected
RG 1.97 instruments for proper range and identification. During
the inspection the inspectors noted: (a) that not all type A, B
and C variables designated as Category 1 and 2 were uniquely
identified on the control boards as RG 1.97; and (b) that not
all instruments located on the PAM panel were always identified
with equipment ID numbers.
The Reg Guide requires that type A, B and C, Category 1 and 2
variables be marked with a common designation.
The only
instruments that were marked were the indicators and recorders
with a blue border.
Other components such as switches,
annunciators and valve position indicators for containment
isolation valves were not marked for type A, B and C, Category 1
and 2 variables on the control boards.
The inspectors
questioned the licensee regarding their position on the
designation of instruments for RG 1.97. The licensee indicated
that because of the size of the control boards and considering
the fact that the switches are specifically addressed in EOP's,
that it was not desirable or necessary to color designate with a
blue border those specific components on the control boards. The
licensee also considered it would clutter the control board and
could lead to operator confusion.
The inspectors requested
that if this position was not already documented that the
licensee should document their justification or reasons for not
marking all type A, B, and C category 1 and 2 variables on the
control boards.
The licensee agreed to document their
justification for not marking these variables and include this
information in their plant files within three months. The
10
inspectors noted that the recorder for both containment water
level and containment pressure did not have an equipment ID
number.
This was found to be inconsistent with other Reg
Guide 1.97 instruments located in the control room.
The
licensee was made aware of the concern and committed to identify
all instruments on the
PAM panel with equipment numbers
consistent with the plant equipment ID numbering system.
The
licensee indicated that the labeling of these instruments would
be completed within three months.
(5) Maintenance of Req Guide 1.97 Equipment
During the control room walkdown, the inspectors noted that the
recorder for both containment water level and pressure on the
PAM panel was tagged out of service. Further investigation of
this matter revealed that the recorder has been out of service
since March 1989. The licensee provided the inspectors a copy
of a project improvement report (PIR)
which proposes that the
recorder should be replaced in 1991 due to lack of replacement
parts and obsolescence. However, it does not make reference to
the work request or the fact that the recorder is out of
service.
The licensee informed the inspectors that they have
redundant indicators in the control room for both variables and
that all channels are inputted into the ERFIS computer. Thus,
adequate information has always been available in the control.
However, to resolve the concern the inspectors have about the
ERFIS computer calibration, the licensee committed to have both
the containment water level and containment pressure channel
calibrated with the ERFIS computer outputs verified prior to
startups from the next refueling outage.
The expected
completion date for implementation of the modification to
replace the PAM recorder will be in 1991.
3. Action on Previous Inspection Findings (92701)
(Closed) Inspector Followup Item 50-261/90-18-01,
Periodic Testing/
Surveillance of Appendix R Protective Devices Associated with Appendix R
Coordination Study
The licensee had initiated Plant Change Notice (PCN) 87-026/00, approved
on December 27, 1988, which evaluated the need for additional maintenance
surveillance testing,
and administrative controls for Appendix R
protective devices in associated circuits of concern (ACC).
The PCN
recommended testing every refueling outage 10 percent of all 480V
switchgear power circuit breakers and 480/208/120V Molded Case Circuit
Breakers that are required to function in the licensee's Appendix R
associated circuit analysis. For each breaker not meeting the acceptance
criteria, an additional 10 percent of that breaker type would be tested
until either no failures occur or until all ACC breakers of that type have
been tested. The PCN also recommended that procedures be developed to
control the replacement of fuses in Appendix R circuits.
To accomplish
all of the above recommendations,
the PCN suggested that two new
procedures should be developed for fuse control and molded case circuit
breaker testing.
In addition, an existing plant procedure should be
revised to ensure that 10 percent of all types of Appendix R 480V
switchgear breakers are tested each outage.
The proposed testing of
molded case circuit breakers would include testing the thermal element at
300 percent of the trip rating for appropriate time delay and testing the
instantaneous element for appropriate pickup current. The recommendations
of PCN-87-026/00 have not been completed due to lack of funding for
calendar years 1989 and 1990.
However, during this inspection the
licensee committed to incorporate this item on the work management
prioritization system as an NRC commitment.
This will ensure that this
item receives proper management attention for scheduling the completion of
this item.
4. Exit Interview
The inspection scope and results were summarized on April 20, 1990, with
those persons indicated in paragraph 1.
The inspectors described the
areas inspected and discussed in detail the inspection results discussed
above.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Subsequent to the inspection, the licensee made certain verbal commitments
to the NRC in telephone conferences on April 26 and May 3, 1990.
These
commitments specifically relate to the licensee's proposed corrective
actions and expected completion dates for the weakness identified during
the inspection.
These commitments are also described in the report
details.
5. Acronyms and Initialisms
AET
Analyzer Element (H2)
AI
Analyzer Indicator
Analyzer Recorder
ANN
Differential Pressure Switch
ERFIS
Emergency Response Facilities Information System
FI
Flow Indicator
FR
Flow Recorder
FT
Flow Transmitter
HVH
Heating Ventilation Handling
Level Indicator
LR
Level Recorder
LT
Level Transmitter
Pressure Control Valve
Pressure Indicator
PR
Pressure Recorder
12
Pressure Transmitter
RC
Reactor Coolant (Accoustical Flow Switches)
Regulatory Guide
RE
Reactivity Element (Neutron)
RI
Reactivity Indicator
Reactivity Recorder
Temperature Element
TI
Temperature Indicator
TM
Temperature Monitor
Temperature Recorder