ML14176A876
| ML14176A876 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/06/1990 |
| From: | Dance H, Garner L, Jury K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A874 | List: |
| References | |
| 50-261-90-11, NUDOCS 9006210522 | |
| Download: ML14176A876 (13) | |
See also: IR 05000261/1990011
Text
6R REG(
UNITED STATES
o
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report No.:
50-261/90-11
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: April 11 -
May 10, 1990
Inspectors:
.(.,
L. .Grrfer'Senior
Resi'dentfhspector
DAe Signed
K. R.
- ry,
R
dent Inspector
Da
Approved by:
L
H. C. Dance, Section Chief
Dat Si ned
Division of Reactor Projects
SUMMARY
Scope:
This routine, announced inspection was conducted in the areas of operational
safety verification; monthly surveillance observation; monthly maintenance
observation; onsite followup of written reports of nonroutine events; action
on previous inspection findings; and design, design changes, and modifications.
Results:
A similar violation was identified involving inadequate procedures for performing
Technical Specification required surveillance tests.
The procedure review
which identified this item was considered a strength (paragraph 5).
The Corporate Nuclear Safety/plant support of the pre-outage "focus on safety"
meeting was a reflection of the licensee's commitment to safety first
(paragraph 2).
A weakness was identified in operation's utilization of temporary procedure
changes (paragraph 3).
2
A weakness was identified in the Onsite Nuclear Safety evaluation process
for information notices and Part 21 reports.
Steps were not always taken to
ensure that all the previous vendor names associated with a component were
researched when determining if a specific vendor's component was installed in
a safety-related application (paragraph 5).
Discrepancies associated with the electrical distribution system design basis
document were processed in accordance with approved procedures and with the
proper emphasis on safety. A weakness was identified in that open items, those
with less significance than discrepancies, were not being prioritized or
tracked for resolution (paragraph 7).
REPORT DETAILS
1. Persons Contacted
R. Barnett, Manager, Outage Management
C. Baucom, Senior Specialist, Regulatory Compliance
C. Bethea, Manager, Training
R. Chambers, Engineering Supervisor, Plant Performance
D. Crook, Senior Specialist, Regulatory Compliance
J. Curley, Manager, Environmental and Radiation Control
C. Dietz, Manager, Robinson Nuclear Project
J. Eaddy, Supervisor, E & RC Support
R. Femal, Shift Foreman, Operations
S. Griggs, Technical Aide, Regulatory Compliance
- E. Harris, Manager, Onsite Nuclear Safety
- J. Kloosterman, Director, Regulatory Compliance
D. Knight, Shift Foreman, Operations
R. Moore, Shift Foreman, Operations
- R. Morgan, Plant General Manager
D. Nelson, Shift Outage Manager, Outage Management
- M. Page, Manager, Technical Support
D. Quick, Manager, Plant Support
0. Seagle, Shift Foreman, Operations
J. Sheppard, Manager, Operations
- R. Smith, Manager, Maintenance
R. Steele, 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 May 16, 1990.
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's records, data sheets, instrument traces,
and records of equipment malfunctions.
Through work observations and
discussions with operations staff members,
the inspectors verified the
staff was knowledgeable of plant conditions, responded properly to alarms,
adhered to procedures and applicable administrative controls, was cognizant
2
of in-process surveillance and maintenance activities, and was aware of
inoperable equipment status.. The inspectors performed channel verifica
tions and reviewed component status and safety-related parameters to
verify conformance with TS.
Shift changes were routinely observed,
verifying that system status continuity was maintained and that proper
control room staffing existed. Access to the control room was controlled
and operations personnel carried out their assigned duties in an effective
manner. Control room demeanor and communications continued to be informal
yet effective.
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.
Transformer Outage
The unit was removed from service on May 4, 1990, to upgrade the cooling
capacity of the main transformer banks.
The unit was scheduled to remain
in hot shutdown during the outage and be returned to service on May 14.
Major work on the main transformers included: replacement of the cooling
coils; installation of new fans, pumps, and conservator tanks; addition of
another bank of fans and pumps; drying of the windings; and replacement of
the transformer oil.
The work will lower the operating temperature and
reduce water content in the windings; thereby, potentially extending the
lifetime of the transformers.
In addition, the following work was
performed on the unit auxiliary transformer: the windings were dried, the
oil was replaced, and a new conservator tank was installed.
With. no capability to backfeed through the main transformer banks and
being aware of the Vogtle loss of.power event, steps were taken to ensure
that power remained available to safety-related equipment.: The area
around the startup auxiliary transformer (normal power source during a
shutdown) was roped off and all vehicular traffic in the switchyard was
being controlled by spotters.
Outage work around the offsite and onsite
power distribution system was limited, closely monitored, and controlled.
In addition, both the emergency diesel generators, the dedicated shutdown
deisel generator, both safety-related battery systems, and both loops of
motor driven AFW, SI, and RHR systems remained in service. Of the major
safety-related equipment, only the D SW pump was removed from service
(pump
replacement).
Work on secondary system components such as the
overhaul of the A main feedwater pump and the B heater drain pump
replacement did not have potential impact on safety-related systems.
On May 2, 1990, the inspectors attended a pre-outage "focus on safety"
meeting sponsored by ONS.
The purpose of the meeting was to review the
defined work scope and ensure that measures would be implemented to
3
control evolutions such that undesirable interactions between simultaneous
work activities would not result in unexpected safety system unavailability
or transients.
This concept was an extension of the pre-startup safety
review meeting at CP&L's BSEP facility.
The CNS/plant support of the
pre-outage focus on safety meeting was a reflection of the licensee's
commitment to safety first.
No violations or deviations were 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, 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:
EST-10 (revision 3)
Containment Personnel Airlock Leakage Test
MST-021 (revision 6)
Reactor Protection Logic Train B at Power
OST-202 (revision 21)
Steam Driven Auxiliary Feedwater System Component
Test
OST-615 (revision 9)
Low Voltage Fire Detection and Actuation
Systems, Zones 20, 21, and 22
OST-905 (revision 9)
Radiation Monitoring System
OST-910 (revision 11)
Dedicated Shutdown Diesel Generator
During the performance of OST-202, steps 7.2.7 and 7.2.8, the inspectors
noted that neither condensate or vapor was observed from the SDAFW pump
steam line drain to atmosphere when valve MS-159 was opened.
The
operators verified that the system was properly aligned. They then closed
MS-156 and MS-158 in an unsuccessful attempt to observe vapor from the
line.
The system was re-aligned and the lack of condensate in the line
was verified by observing proper operation of the steam trap and
verification that the line was hot.
Because the intent of the steps
(demonstration of no water in the line) was met, steps 7.2.7 and 7.2.8
4
were signed-off as complete.
The inspectors discussed with the cognizant
operating personnel the desirability of using a temporary procedure change
when a given methodology provided in a procedure does not provide the
expected results.
Not issuing a temporary procedure change under this
circumstance was identified as a-weakness in the operation's utilization
of temporary procedure changes.
No violations or deviations were identified.
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 and approved procedures.
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, and fire prevention controls were
adhered to. In particular, the inspectors observed/reviewed the following
maintenance activities:
CM-008 (revision 6)
Steam Driven Auxiliary Feedwater Pump Overhaul
CM-010 (revision .3)
Service Water Pump Overhaul
WR/JO 90-AASB1
Replacement of D SW Pump.
WR/JO 90-AFHR1
Repair of SDAFW Pump Oil Leak
On April 30, 1990, the SDAFW pump was removed from service to repair an
oil leak. Upon removal of the bearing cover on the pump end of the shaft,
it was observed that heat shrink tubing around the thermocouple wires to
the bearings was blocking the oil return port. A similar situation on the
turbine end of the pump had been corrected in January 1990 (see IR 90-02).
In January, it had been surmised that the piece of heat shrink on the pump
side was shorter and if it had not swollen and blocked the return oil port
at that time, then it would probably not do so.
The inspectors witnessed portions of the disassembly and re-assembly of
the SDAFW pump. A damaged area, approximately one and one-half inches by
three sixteenths of an inch, appeared to the inspectors to have changed
since last observed during the Fall 1989 pump overhaul.
The system
engineer indicated that the area appeared as before. The area is only 2
3 mils deep and therefore represents no structural concern. Neither the
licensee nor the pump vendor representative could definitely identify the
mechanism of degradation. Since the mechanism of degradation is unknown,
the inspectors discussed with plant management the feasibility of
periodically inspecting this area. During the exit, the licensee indicated
5
that they would reinspect this area for changes during the Fall 1990
refueling outage.
The licensee currently has on order a new impeller
which they plan to install during the next pump overhaul.
On May 9, 1990, in accordance with the PM program, the D SW pump was.
replaced with a factory rebuilt spare.
During testing, the rebuilt pump
experienced approximately 10 percent greater shutoff head than expected
and an acceptable yet higher than expected vibration.
The old pump and
motor was re-installed and successfully tested. The rebuilt pump will be
returned to the vendor for inspection and correction of the deficiency.
No violations or deviations were identified.
5. Onsite Followup of Written Reports of Nonroutine Events (92700)
(Closed)
P2189-01,
Brown Boveri K-line, K-225 through K-2000 Circuit
Breakers Delivered Prior to 1974 Need Rebound Spring Added to Slow Close
Pin.
The inspectors reviewed the Onsite Nuclear Safety OEF Evaluation
Sheet dated February 9, 1989.
The evaluation stated "HBR 2 does not use
Brown Boveri breakers in any safety or non-safety system by design and by
review of HBR 2's CMMS records and
EDBS listings."
The inspectors
observed that non-safety related 480 V switchgear bus no. 5 has Brown
Boveri breakers.
The ONS reviewer, indicated that this meant no Brown
Boveri K-line breakers.
The inspectors had also observed that the
breakers used for transfer of normal power to the dedicated shutdown
diesel power bus for MCC-5 and D SW pump are K-600 breakers. The reviewer
informed the inspectors that these breakers were no longer considered
breakers but manually operated transfer switches since the trip function
had been defeated.
Thus,
by walkdown of all safety-related switchgear,
and discussions with cognizant personnel, the inspectors confirmed that no
K-line breakers were installed in safety-related applications.
During the licensee's review of Brown Boveri supplied breakers, the K-line
transfer switches had not been identified by the record review.
This
occurred because the transfer switches were listed under the original
manufacturer's name, ITE Gould.
No search had been performed using that
name.
The reviewer indicated that, routinely, no precautions have been
taken to ensure all previous manufacturer's names were used when a
specific vender's component was being researched.
Since ONS performs
initial applicability screening for NRC Information. Notices, as well as
Part 21 reports , this is considered a programatic weakness.
This was
brought to the attention of the ONS manager.
Subsequently, the ONS
manager has indicated that this item has been discussed with all the ONS
reviewers.
The weakness is being reviewed by ONS for additional required
action.
(Closed)
LER 89-05, Reactor Trip Due To Inadvertent Closure Of Main Steam
Isolation Valve.
The inspectors reviewed the scram report.
All safety
systems performed as expected. Corrective actions identified in the LER
were the same as that provided in response to VIO 89-08-01, which is
discussed in paragraph 6 of this report.
6
(Open) LER 90-005, Failure To Test RPS Logic Channels In Accordance With
TS.
The subject report identified that the power range high flux -
low
setpoint reactor trip and two-out-of-three loop low flow reactor trip
logic channels were not completely tested monthly during power operations
as required by TS Table 4.1-1 item 27.
Test procedures were revised and
these features were successfully tested on March 14 and 15,
1990.
These
items were identified by the licensee during procedure reviews.
The
licensee also identified that the source range high flux - low setpoint
reactor trip and the intermediate range high flux reactor trips were not
tested monthly.
Neither the source range trip nor the intermediate range
trip is assumed to mitigate any UFSAR Chapter 15 accident. The licensee
developed a position that these were not required by TS, but determined it
was prudent to implement procedures to test the source range trip prior to
startup if not tested in the previous 7 days, and to test the intermediate
range high flux trip monthly. Subsequent to the report period the licensee
successfully performed testing on the trip functions prior to a restart on
May 14, 1990.
During a May 16, 1990 conference call with NRC Management,
the licensee was informed that, as written, TS item 27 required monthly
logic testing of the source and immediate range reactor trips.
Though
disagreeing that this testing is required by TS, the licensee committed to
submit a waiver of compliance or exigent TS change request concerning the
monthly source range high flux test prior to the end of the next monthly
surveillance test interval.
The TS surveillance problem addressed above is repetitive, in that, on
June 23,
1988,
an NOV was issued regarding an inadequate procedure. for
testing TROTS as required by TS Table 4.1-1 item 28 (see IR 88-10 and
LER 88-11).
Accordingly, this is identified as a VIO: Failure To Take
Adequate Corrective Action
To Preclude Repetition Of Inadequate
Procedures Involving TS Required Tests, 90-11-01.
A review for previous occurrences revealed the following:
0
On March 7, 1986, the licensee identified that test procedures did
not perform channel functional testing of the AFW automatic initiation
during a station blackout as required by TS Table 4.8-1 (see
LER 86-008).
On November 18, 1985, the licensee identified that the steam/feedwater
flow mismatch with a low steam generator level reactor trip was not
being tested as required by TS Table 4-1-1, Item 39.
An NOV was issued June 19, 1984, concerning an inadequate procedure
to test SI initiation due to high steam line flow coincident with low
steam line pressure or low RCS average temperature as required by TS
Table 4.1-1 Item 27 (see IR 84-19).
Corrective actions to the 1984 violation discussed above determined
that procedures were not adequate for steam line isolation testing,
and SI initiation on CV pressure (see LER 84-05).
in response to NRC generic letter 83-20, the licensee discovered
that the manual reactor trip function was not routinely tested.
7
In 1982,
the licensee had conducted an independent review of TS
surveillances as a result of the surveillance problems identified at
As indicated above, there has been a weakness in
being able to properly- implement surveillance testing of TS required
instrumentation.
One violation was identified.
6. Action on Previous Inspection Findings (92701, 92702)
(Closed) VIO 88-07-01, Failure To Declare An Unusual Event After Exceeding
An RCS Leak Rate Of 10 GPM. The inspectors reviewed the August 12, 1988
supplemental repsonse to the NOV.
The following corrective actions
contained in the supplemental response were verified to have been completed
as committed:
Directed transitions from AOPs to PEPs were incorporated in AOPs.
Procedures reviewed included:
APP (revision 6) Radiation Monitoring System
AOP-006 (revision 2) Turbine Vibration
AOP-009 (revision 0) Accidental Release of Waste Gas
AOP-016 (revision 5) Excessive Primary Plant Leakage
AOP-019 (revision 1) Malfunction of RCS Pressure Control
AOP-020 (revision 6) Loss of Residual Heat Removal
AOP-021 (revision 3) Seismic Disturbances
AOP-023 (revision 3) Loss of Containment Integrity
Operator Aid No.
89-01, Off Normal Event Notification, was issued as a
single reference for determining required reports. This was subsequently
cancelled March 9, 1990.
NRC reporting requirements are now contained in
AP-030, NRC Reporting Requirements.
Flowpath procedures EAL-1 and EAL-2 were issued to assist in emergency
classification determinations.
Per Collins to Eury letter dated
December 1, 1989, the NRC has reviewed revision 22 to the emergency plan
which contains these flowpaths.
Emergency Action Level Procedure User's Guide,
OMM-031,
was issued to
prescribe rules of usage for the EAL flowpaths and PEPs.
Training procedure, TI-909, Simulator Conduct Of Operations And Instructor
Qualifications, was rev-ised to ensure that the instructors verify that
PEP's are reviewed by operators to determine if they are applicable during
any off-normal event.
The above actions provided additional measures and aids to assist personnel
in the proper classification of an abnormal event. These actions should
prevent future occurrences of the violation.
(Closed)
VIO 88-28-02, Failure To Have A Program To Use Calibrated Stop
Watches For Required TS And ASME Section XI Testing.
The inspectors
reviewed the December 9, 1988 response to the NOV.
Procedure OMM-017,
Calibration Control/Repair Program For Portable Test Equipment,
was
revised to require that calibration of stop watches shall not exceed
twelve months.
The inspectors reviewed a sample of OSTs to verify that
calibrated stopwatches are
required to be used when timing
equipment associated with TS surveillances and ASME Section XI tests. The
inspectors have routinely observed the use of calibrated stopwatches
during OST performances.
(Closed) VIO 89-07-01, Initialing Procedure Step.Prior To Performing Work.
An improperly numbered sign-off step on the data sheet associated with
CM-111, Limitorque Limit Switch and Torque Switch Maintenance, contributed
to the event.
The inspectors verified that CM-111 has been revised to
correct the deficiency. The inspector discussed the lack of attention to
detail with the Maintenance Manager.
The Maintenance Manager indicated
that maintenance personnel have been cautioned on attention to detail
while-using procedures.
(Closed)
VIO 89-08-01,
Failure To Follow.OST-202 Results In A Reactor
The inspectors reviewed the June 16,
1988 response to the NOV.
The inspectors verified that EST-013,
Auxiliary Feedwater Bearing
Temperature Test, revision 8, and OST-202, Steam Driven System Component
Test, revision 21,
contain instructions on how to properly perform these
tests simultaneously.
- As committed in the response, the A MSIV was
inspected for damage. The evaluation of the inspection, attached to WR/JO
89-AEEF1,
dated October 9, 1989,
concluded that there was no physical
damage to the valve internals which would preclude the valve from seating.
The human factors review of the control board is being conducted as part
of the control room upgrade project.
The NRC is reviewing this latter
item as a separate issue.
9
(Closed)
VIO 89-09-01,
Procedure Inadequately Addresses Potential Pump
Runout With Only One SI Pump Injecting Into Two Hot Legs.
The subject
procedure was revised to incorporate the appropriate precaution.
The
inspectors verified that OMM-013,
Emergency Operating Procedure Writer's
Guide,
revision 2, was issued to require that a system engineer
participate in the verification of EOP changes.
This corrective action,
along with the EOP reviews being conducted as corrective action for
deficiencies identified in IR 89-16, should ensure required precautions and
limitations are contained in the EOPs.
(Closed) IFI 88-28-04,
Review Visual And Eddy Current Testing Of HVH 1-4
During November
1988 Refueling Outage.
The inspectors reviewed the
results of the HVH-4 eddy current examination presented in the Echoram
Technology,
Inc. final report dated November 1988.
Of the 108 tubes
inspected,
none were found with defects greater than 20 percent
through-wall.
(Closed)
IFI 88-03-02,
Review Finalized Transition Document And Step
Deviation Report.
The subject documents were reviewed by the NRC during
the EOP team inspection conducted September 18 -
September 29,
1989.
Results are documented in IR 89-16 and the associated licensee's response
of December 8, 1989.
No violations or deviations were identified.
7. Design, Design Changes, and Modifications (37700)
On April 11 and 12,
1990, an inspection was performed in the corporate
engineering office of the status and resolution of discrepancies
identified through the preparation and validation of the Electrical Power
Distribution System DBD (DBD/R 87038/SD16) revision 0, issued May 23, 1989.
The inspectors determined that discrepancies were being processed in
accordance with approved procedures and with the proper emphasis on safety. A
significant weakness in the electric system documentation is the
non-availability of supporting calculations. . A table, denoted as
CACL-MATRIX,
has been developed which shows what calculations are
available and unavailable for different plant operating conditions and
electrical system configurations.
At the time of the inspection, the
licensee was in the process of determining which unavailable calculations
would be generated.
Most major calculations such as offsite AC power
system response and
EDG transient loading during a LOCA have been
completed or should be completed this fall to support modifications
scheduled for the 1990 refueling outage.
During the preparation and validation phases of the DBD process, a number
of open items (less safety significant than a discrepancy) have been and
are continuing to be found.
The items may include errors or enhancement
recommendations associated with drawings or procedures. .Though open items
10
are captured and assigned a number, the task of determining how and if the
items are to be resolved was not assigned to any individual.
For those
open items deemed beneficial or necessary to be implemented, there was no
tracking system to ensure that they are properly resolved.
The lack of a
review and tracking systems for open items is considered a weakness. This
was discussed with engineering supervision. The Technical Support Manager
expects to have someone assigned the responsibility of overseeing the
resolution of the DBD open items by June 30, 1990.
8. Exit Interview (30703)
The inspection scope and findings were summarized on May 16,
1990 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. During the exit, and discussed in paragraph 4,
the licensee committed to reinspect the SDAFW pump's impeller during the
Fall 1990 refueling outage.
Dissenting comments were not received from
the licensee. Proprietary information is not contained in this report.
Item Number
Description/Reference Paragraph
90-11-01
VIO - Failure To Take Adequate Corrective Action
To Preclude Repetition of Inadequate Procedures
Involving TS Required Tests (paragraph 5).
10. List of Acronyms and Initialisms
Alternating Current
Administrative Procedure
Abnormal Operating Procedure
American Society of Mechanical Engineers
Brunswick Steam Electric Plant
Corrective Maintenance
CMMS
Corporate Material Management System
Corporate Nuclear Safety
Carolina Power & Light
Design Basis Document
E&RC
Environmental and Radiation Control
Emergency Action Level
EDBS
Equipment Data Base System
Emergency Operation Procedures
EST
Engineering Surveillance Test
GPM
Gallons Per Minute
HBR
H. B. Robinson
HVH
Heating Ventilation Handling
Instrumentation & Control
IFI
Inspector Followup Item
IR.
Inspection Report
LCO
Limiting Condition for Operation
LER
Licensee Event Report
Loss of Coolant Accident
MS
Main Stream
Maintenance Surveillance Test
NRC
Nuclear Regulatory Commission
OEF
Operating Experience Feedback
OMM
Operations Management Manual
Onsite Nuclear Safety
OST
Operations Surveillance Test
PEP
Plant Emergency Procedure
Preventative Maintenance
System Driven Auxiliary Feedwater
Safety Injection
TI
Training Instruction
TROTS
Turbine Redundant Overspeed Trip System
TS
Technical Specification
Updated Final Safety Analysis Report
V
Volt
Violation
WR/JO
Work Request/Job Order