ML14178A143
| ML14178A143 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/22/1991 |
| From: | Christensen H, Garner L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A140 | List: |
| References | |
| 50-261-91-17, NUDOCS 9109100072 | |
| Download: ML14178A143 (10) | |
See also: IR 05000261/1991017
Text
pVjF REG&,
UNITED STATES
0
'NUCLEAR
REGULATORY COMMISSION
REGION 1I
C 0101
MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report No.:
50-261/91-17
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:
July 13 -
August 9, 1991
Lead Inspector:
B4
o
.
, e4
. or
LI. W. Gar~er, nior R;W~den ,Anspector
D~te Si~ned
Other Inspectors: K. R. Jury, Resident Inspector
. E. Carroll, Project Engineer
Approved b
e.
d9/=
. 0.ChClstensen, Section Chief
Dat
Si
ed
Division of Reactor Projects
SUMMARY
Scope:
This routine, announced inspection was conducted in the areas of operational
safety verification,
maintenance observation,
onsite review committee
activities, and followup.
Results:
A violation with two examples was identified for failing to adequately
establish procedures (paragraph 2).
A violation was identified for failing to utilize a maintenance work request to
perform maintenance activities (paragraph 3).
A non-cited violation was identified for failing to complete a procedure usage
cover sheet prior to initiating work (paragraph 3).
0
9109100072 910823
ADOCK 05000261
REPORT DETAILS
1. Persons Contacted
R. Barnett, Manager, Outages and Modifications
- C. Baucom, Senior Specialist, Regulatory Compliance
D. Bauer, Regulatory Compliance Coordinator, Regulatory Compliance
- S. Billings, Technical Aide, Regulatory Compliance
- R. Chambers, Manager, Operations
T. Cleary, Manager -
Balance of Plant Systems and Reactor Engineering,
Technical Support
D. Crook, Senior Specialist, Regulatory Compliance
C. Dietz, Manager, Robinson Nuclear Project
- W. Dorman, Acting Manager, Nuclear Assessment Department Site Unit
J. Eaddy, Manager, Environmental and Radiation Support
S. Farmer, Manager - Engineering Programs, Technical Support
R. Femal, Shift Supervisor, Operations
- W. Gainey, Manager, Plant Support Unit
- P. Jenney, Project Specialist, Regulatory Compliance
J. Kloosterman, Manager, Regulatory Compliance
D. Knight, Shift Supervisor, Operations
- A. McCauley, Manager - Electrical Systems, Technical Support
R. Moore, Shift Supervisor, Operations
- A. Padgett, Manager, Environmental and Radiation Control
M. Page, Manager, Technical Support
D. Seagle, Shift Supervisor, Operations
- J. Sheppard, Plant General Manager, H. B. Robinson
- R. Smith, Manager, Maintenance
- D. Stadler, Onsite Licensing Engineer, Nuclear Licensing
W. Stover, Shift Supervisor, Operations
D. Winters, Shift Supervisor, Operations
- H. Young, Manager, Quality Control
Other licensee employees contacted included technicians,
operators,
mechanics, security force members, and office personnel.
- Attended exit interview on August 13, 1991.
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.
2
To verify equipment operability and compliance with TS,
the inspectors
reviewed shift logs, Operations' 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, cognizant of
in-progress 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 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 were appropriate.
Plant tours 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.
Inadequate EPP-10 Procedure
On July 22,
1991,
the inspectors observed that the alternate hot leg
recirculation flow path specified in EPP-10,
Transfer To Hot Leg
Recirculation, revision 4, did not open all the valves required for the
flow path.
The alternate flow path is from the RHR pump discharge header
via the CVCS system to the B RCS hot leg.
The pathway utilizes the normal
charging line which enters containment at penetration 24.
On March 1,
1991,
EPP-9,
Transfer To Cold Leg Recirculation, was revised to close
manual valves CVC-202A,
282,
and 309A, and to seal this penetration with
IVSW.
A combination of valves 282 and either 202A or 309A, are required
to be open for alternate hot leg recirculation to be established via
penetration 24.
Prior to the EPP-9 revision which closes these valves, it
was not necessary to verify that these valves were open during EPP-10
performance as a flow path through this penetration exists during normal
operation.
However,
performance of the revised EPP-9 not only closes
these valves within the first hour of a design basis LOCA, but would most
likely result in radiation fields which would preclude subsequent
reopening of these valves. . Thus,
when EPP-10 would be performed under
accident conditions, i.e. approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> after initiation of a
LOCA,
the alternate hot leg recirculation flow pathway could not be
established. The safety significance of the flow path's unavailability is
minor, in that, multiple failures must occur for the normal hot leg
recirculation flowpath to be unavailable. However, if the plant design is
such that an alternate hot leg recirculation flow path can be established,
the inclusion of this flow path into EOPs is expected.
The licensee is
presently reviewing the availability of an alternate hot leg recirculation
flow path via the RHR shutdown cooling suction line or re-establishment of
the previously specified RHR/CVCS flowpath.
Incorporation of a viable
alternate hot leg recirculation flowpath into EPP-10 is anticipated to be
completed by the end of August 1991.
3
The failure to identify that EPP-10 was adversely impacted by a revision
to EPP-9 is of special concern, since the V & V process for EOPs was
identified as a weakness in IR 89-16. In response to that weakness, a new
V & V process was developed in 1990 to be utilized during and subsequent
to, the EOP upgrade project which is scheduled for completion at the end
of 1991.
EOPs which had not been upgraded were not being verified and
validated by this new V & V process. The individual responsible for the
EOP upgrade project indicated that all future EOP revisions would now use
the new V & V process.
Because of the similarities between the past EOP
review process and that used for other types of operating procedures, the
weakness which allowed the EPP-9/EPP-10 problem to occur could exist for
other procedure revision processes.
The failure to adequately establish
EPP-10 constitutes one example of a violation: ' Failure To Adequately
Establish Procedures, 91-17-01.
Inadequate Review Of SP-1023
As documented in IR 91-15, SP-1023, IVSW Leak Test of Penetration 6, was
performed on July 11,
1991,
to return the RCDT pump discharge outboard
containment isolation valve,
WD-1722,
to service.
The inspectors
completed their test review and determined that the SP was adequately
performed on the established configuration, and as such,
successfully
demonstrated valve integrity.
Prior to performing the test, the licensee identified that the SP provided
a precaution and limitation which incorrectly referenced the applicable
TS.
The SP stated that the performance of the test would place the plant
in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LCO to hot shutdown per TS 3.3.6.1 and 3.3.6.2.
However, TS 3.0 was applicable, which is an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to hot shutdown LCO. Subsequent to
the issuance of the SP, and preparation for its performance, the operating
shift reviewed the procedure and detected the LCO discrepancy.
A
temporary procedure change was implemented to correct this error prior to
test initiation.
Evidently during the preparation of SP-1023,
the procedure preparer had
identified TS 3.0 as being applicable during the test; however, during the
review process,
discussions among
operations and technical support
personnel resulted in the incorrect determination that TS 3.3.6.1 and TS 3.3.6.2 were applicable, not TS 3.0. The failure to properly identify the
applicable TS in SP-1023 constitutes a second example of violation:
91-17-01, Failure To Adequately Establish Procedures.
One violation with two examples was identified.
3. 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.
4
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
particular, the inspectors observed/reviewed the following maintenance
activities:
WR/JO 91-AJJA1
Perform Current Traces on SI-876A, SI-867B,
and SI-869 Using VOTES
WR/JO 90-AEUY1
Replace PT-121, CVCS Charging Pump
Discharge Pressure Transmitter
Valve SI-867A Breaker Tripping
On July 29,
1991,
while taking current traces and voltage readings on
valve SI-867A,
BIT inlet bypass valve,
the valve's power supply
breaker tripped instantaneously to the valve's switch manipulation on the
RTGB.
Concurrent with this action was a loss of indication on a voltmeter
(multimeter) being used for voltage readings. The valve was declared out
of service and TS 3.3.1.2.e (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to hot shutdown LCO) was entered at
10:45 a.m.
as one flow path was determined to be inoperable.
The
redundant flow path (valve SI-867B) was demonstrated to be operable by
performing a stroke test per OST-152, SI system.
The voltage readings and current traces were being taken in support of AC
MOV motor torque calculation RNP-E-7013, to better estimate rated locked
rotor current, as neither actual field nor vendor data was available for
the calculation. The 600 VAC rated power supply breaker evidently tripped
when a 300 VAC multimeter (connected across B & C motor phases) shorted
out. The multimeter is designed to measure a maximum of 300 VAC; however,
it
was being utilized on a 480 VAC system.
Apparently, the impressed
voltage (which is above the meter range) shorted the spark gap circuitry
in the voltmeter, thus shorting the spike suppressor and tripping the
breaker. Subsequent to the breaker tripping, the breaker was reset and WR
91-AKND1 was initiated to perform a current trace and stroke time test for
the valve. Applicable portions of OST-152 were performed to verify proper
operation of remote position indicators, measure stroke time,
and to
verify that the valve assumed proper position on loss of operating power.
The current traces and OST-152 were both successfully performed and the
valve (and flow path) was declared back-in-service at 2:00 p.m..
Upon
reviewing
the circumstances surrounding this situation,
the
inspectors concluded there were several work control breakdowns which
occurred.
The first involved the communications between NED,
Technical
Support,
Maintenance,
and Operations.
There appeared to be a non
formalized communication process being utilized in accomplishing the
valve's voltage readings.
The apparent sequence occurred as follows:
(1) NED requested the current and voltage readings be taken per a
memorandum;
(2) Technical Support subsequently requested a WR
be
generated,
however,
the generated WR (91-AJJA1)
only required current
traces be taken, not voltage readings; and (3) the maintenance technicians
5
were verbally requested to also take voltage readings, however, Operations
was not informed nor aware voltage reading were going to be taken. While
this non-formalized "communication"
may not have been the root cause of
the event, it appeared to be a contributor. The second breakdown involved
the technicians performing the test being unaware that the multimeters
being utilized were unacceptably rated to measure the power supply's
voltage.
However, labels were on the meters indicating they were only to
be utilized up to a maximum of 300 VAC.
These labels were placed on the
meters due to a similar misapplication in early 1989 which resulted in a
Maintenance
Manual
Procedure
MMM-001,
Maintenance
Administration Program, revision 12,
requires a proper work request be
utilized in performing all maintenance activities and labor by craft
personnel.
If
the voltage readings were specified to be taken and
correctly ranged multimeters were identified to be used on the WR, this
situation may have been precluded.
Failure to adequately perform
maintenance activities is a violation:
Maintenance Activities Were
Performed Without Utilizing A Work Request, 91-17-02.
CVCS Charging Pump Pressure Transmitter, PT-121, Replacement
During the replacement of PT-121 per WR 90-AEUY1,
the inspectors noted
that after the technicians began implementing Process Instrumentation
Calibration Procedure PIC-006,
Pressure Transmitter, revision 1, the
Procedure Usage Cover Sheet had not been filled out.
Maintenance
Management Manual Procedure MMM-001,
Maintenance Administration Program,
Revision 12,
Section 5.1.8,
requires that procedures
issued for
performance of maintenance shall be provided with a Procedure Usage Cover
Sheet. The inspectors discussed this concern with a technician performing
the test and a NAD representative. The technician subsequently left the
work site and had the cover sheet completed as required.
Apparently, the
fact that the maintenance supervisor failed to complete the cover sheet
was overlooked by the technicians performing the work.
Upon cover sheet
completion, it
was determined that PIC-006 was to be used as "reference",
and that each segment is required to be verified after completion. As the
technicians were just in the process of setting up their testing apparatus
and the procedure was to be used as a reference, the failure to have this
cover sheet completed was not considered to be of significant concern and
appears to be an isolated event. Not completing the Procedure Usage Cover
prior to work initiation is considered a violation; however,
this
violation meets the criteria specified in Section V.A.
of the NRC
Enforcement Policy for not issuing a Notice of Violation and is not cited.
This violation is identified as a NC'V:
Failure to Complete Procedure
Usage Cover Sheet as Required, 91-17-03.
Two violations (one being non-cited) were identified.
4. Onsite Review Committee (40500)
The inspectors evaluated certain activities of the PNSC to determine
whether the onsite review functions were conducted in accordance with TS
and other regulatory requirements. In particular, the inspectors attended
6
the July 19,
1991
special
PNSC which reviewed the MFRVs'
fuse
installation procedure, SP-1026,
and proposed
FW line leak repair.
All
potential concerns with the SP were thoroughly discussed and resolved. It
was ascertained that provisions of the TS dealing with membership, review
process, frequency, and qualifications were satisfied.
No violations or deviations were identified.
5.
Followup (92700, 92701, 92702)
(Closed)
Part 21 89-12 and 89-18, Potential Failures Of Limitorque SMB-00
And SMB-000 Torque Switches.
On November 3, 1988, Limitorque issued a 10
CFR 21 Notification (89-18)
regarding post mold shrinkage on Melamine
torque switches used in their old style SMB-00 and SMB-000 actuators. On
September 29, 1989, Limitorque issued a second 10 CFR Notification (89-12)
regarding the loosening of stationary contact screws on the side of SMB-00
and SMB-000 cam-type torque switches with fiber spacers under their
contact bridge.
In response to these notifications, the licensee
identified 83 potentially affected valves (63 of which were safety
related).
Through a discussion with the licensee's MOV Technical Support
Coordinator and a review of associated work documents,
the inspector
confirmed
that
the
recommended verifications/replacements were
appropriately accomplished. This item is closed.
(Closed)
IFI 89-07-02,
Review Permanent Solution To RTD Thermowell
Cracking Phenomena.
During RO 12,
the RCS bypass temperature manifolds
were removed and fast response RTD thermowells were installed in their
place.
Unlike loops B and C, physical interferences prevented
installation of the A loop hot leg thermowells inside the existing RTD
bypass piping scoops.
Instead, the three A loop hot leg thermowells were
modified to facilitate installation in an elbow of thicker wall pipe
further downstream.
As discussed in IR 89-07,
the A loop hot leg
thermowells were subsequently redesigned when vibration induced fatigue
failure resulted in through-wall leakage.
Since conservative analysis
demonstrated that the redesigned thermowells would last at least 0.8
years, the licensee authorized unit operation for up to 9 months while
working on a final resolution.
Based on subsequent analysis, the
redesigned thermowells are now expected to last for the life of the plant.
The inspector reviewed associated engineering evaluations 89-52 (which
utilized a forcing function that reflects the redesigned thermowell
insertion length of 3.5 inches versus the earlier 4.5 inches) and 90-101
(which is based on vibration data taken at the start of RO 13), and had no
further concerns regarding this matter.
Closed IFI 89-23-02, Review Planned PM Schedule For AFW Components.
This
item addressed the concern that AFW pump cavitation damage and motor rotor
bar cracking identified in 1989, could have been detected earlier through
a more comprehensive PM program. As discussed in IR 91-15 the motor rotor
bar cracking concern has evidently been resolved and monitoring of rotor
bar condition is routinely being performed. The licensee also developed a
comprehensive PM schedule for the
pumps, motors,
and system
7
components.
Included in the pump PM schedule are: overhaul/teardown,
vibration analysis, flow checks, bearing inspections, and SDAFWP overspeed
trip mechanism inspection.
The AFW pump motors are scheduled for a
rotating overhaul/teardown sequence which consists of the motor scheduled
for refurbishment being replaced with the motor most recently refurbished.
In addition, motor diagnostic analysis and vibration analysis will be
regularly performed.
Also scheduled for PMs are FCVs 1424,
1425,
and
6416,
and air operated valves.
System Check valves and MOVs will be
maintained in accordance with the MVMP.
Additionally, system flow
orifices will be replaced on a refueling intervals and SDAFWP steam traps
and strainers will be inspected on the same interval.
The inspectors
verified that WRs have been generated for selected PM activities that are
to be accomplished during the next RO. Based on the established schedule,
this item is closed.
(Closed)
VIO 89-23-04,
Failure To Adequately Establish Measures
For
Suitability of Processes Essential To Safety-Related Functions As Required
By 10 CFR 50 Appendix B Criterion III.
This violation addressed two
unrelated examples. The first example involved an incorrect application
of Bernoulli's Equation in an AFW modification acceptance test procedure.
The other example concerned a SW modification which did not adequately
take into account the affects of the welding process utilized on the coal
tar lined pipe.
In the first example, the AFW acceptance test procedure
was revised to account for elevation and velocity head losses, and the
modified piping was retested with satisfactory results.
With respect to
the second example,
subsequent coal tar fouling was detected in the SW
tubes of containment fan coolers HVH 1-4.
Immediate corrective actions,
which are discussed in detail in IR 89-23,
included such things as
cleaning the HVH units and flushing the loose coal tar pieces from all
affected piping (i.e., from the suction of the SW booster pumps to the
outlet piping of the HVH units).
The affected SW piping was subsequently
replaced in RO 13.
The inspector reviewed associated design deficiency
reports (89-45 and 90-06) which were generated as a result of these two
issues and considered the indicated post event reviews conducted with
design personnel to be appropriate. This item is closed.
No violations or deviations were identified.
6.
Exit Interview (30703)
The inspection scope and findings were summarized on August 13, 1991, 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.
The licensee did not identify as proprietary any of the
materials provided to,
or reviewed
by the inspectors during this
inspection.
8
Item Number
Description/Reference Paragraph
91-17-01
VIO - Failure to Adequately Establish
Procedures as Required (paragraph 2).
91-07-02
VIO - Failure to Utilize a Work
Request
to
Perform
Maintenance
Activities (paragraph 3).
91-17-03
NCV -
Failure to Complete Procedure
Usage Cover Sheet (paragraph 3).
7. List of Acronyms and Initialisms
a.m.
Ante Meridiem
Alternating Current
BIT
Boron Injection Tank
CFR
Code of Federal Regulations
Chemical Volume Control System
CVS
Chemical Volume System
Emergency Operation Procedures
End Path Procedures
Flow Control Valves
HVE
Heating Ventilation Exhaust
HVH
Heating Ventilation Handling
IFI
Inspector Followup Item
i.e.
That is
IR
Inspection Report
IVSW
Isolation Valve Seal Water
LCO
Limiting Condition for Operation
Loss of Coolant Accident
Main Feedwater Regulating Valve
MMM
Maintenance Management Manual
Modification and Design Control Procedure
Motor Operated Valve
MVMP
Managed Valve Maintenance Program
NAD
Nuclear Assessment Department
Non-cited Violation
NED
Nuclear Engineering Department
NRC
Nuclear Regulatory Commission
OST
Operations Surveillance Test
Process Instrument Calibration
p.m.
Post Meridiem
Preventive Maintenance
PNSC
Plant Nuclear Safety Committee
Reactor Coolant Drain Tank
9
Robinson Nuclear Project
Refueling Outage
RTB
Reactor Trip Breaker
Reactor Turbine
SDAFWP
System Driven Auxiliary FeedwaterPump
Safety Injection
Senior Operator
Special Procedure
TS
Technical Specification
V & V
Verification.& Validation
VAC
Volts Alternating Current
Violation
VOTES
Valve Operation Test And Evaluation System
W/R
Work Request
WR/JO
Work Request/Job Order