ML14178A387
| ML14178A387 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/04/1993 |
| From: | Christensen H, William Orders NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A385 | List: |
| References | |
| 50-261-93-19, IEIN-87-043, IEIN-87-070, IEIN-87-43, IEIN-87-70, NUDOCS 9310130066 | |
| Download: ML14178A387 (18) | |
See also: IR 05000261/1993019
Text
pV REGU
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
Report No.:
50-261/93-19
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 Unit 2
Inspection Conducted: August 15 - September 11, 1993
Lead Inspector:
(--
. T. Orders, Senior Re S nt
pector
Date igned
Other Inspectors: C. R. Ogle, Resident Inspector
J. E. Tedrow, Senior Resident Inspector - Shearon Harris
Approved by: 9
'n
WH.
1. Christensen, Chief
Date 'Signed
Reactor Projects Section 1A
Division of Reactor Projects
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the areas of operational
safety verification, surveillance observation, maintenance observation,
engineered safety feature system walkdown, and followup of previously
identified items.
Results:
One violation was identified involving an operator failing to follow the
applicable procedure during the performance of a surveillance test
(paragraph 3).
Another violation, with two examples, was identified concerning an inadequate
calibration program procedure (paragraph 6).
A non-cited violation was identified involving an area firewatch leaving his
post (paragraph 3).
9310130066 931005
PDR ADOCK 05000261
0
2
A second non-cited violation was identified involving a degraded diesel
generator ventilation system (paragraph 8).
An unresolved item was identified concerning the testing adequacy of component
cooling water pump start circuitry (paragraph 5).
A second unresolved item was identified concerning the manipulation of control
room ventilation dampers during performance of testing (paragraph 6).
A third unresolved item was identified pertaining to the adequacy of control
room ventilation system testing (paragraph 6).
The licensee's response to an ethylene glycol spill was poor; however, the
licensee met the reporting requirements of 50.72 (paragraph 3).
REPORT DETAILS
1. Persons Contacted
- R. Barnett, Manager, Project Management
C. Baucom, Senior Specialist, Regulatory Compliance
S. Billings, Technical Aide, Regulatory Compliance
- B. Clark, Manager, Maintenance
- T. Cleary, Manager, Technical Support
- D. Crook, Senior Specialist, Regulatory Compliance
C. Dietz, Vice President, Robinson Nuclear Project
R. Downey, Shift Supervisor, Operations
J. Eaddy, Manager, Environmental and Radiation Support
S. Farmer, Manager Engineering Programs, Technical Support
R. Femal, Shift Supervisor, Operations
- W.J
Flanagan Jr., Acting Plant General Manager
W. Gainey, Manager, Plant Support
P. Jenny, Manager, Emergency Preparedness
D. Knight, Shift Supervisor, Operations
J. Kozyra, Project Specialist, Licensing/Regulatory Programs
A. McCauley, Manager, Electrical Systems, Technical Support
R. Moore, Shift Supervisor, Operations
D. Morrison, Shift Supervisor, Operations
D. Nelson, Manager, Outage Management
- A. Padgett, Manager, Environmental and Radiation Control
D. Seagle, Shift Supervisor, Operations
- M. Scott, Manager, NSSS Technical Support
E. Shoemaker, Manager, Mechanical Systems, Technical Support
W. Stover, Shift Supervisor, Operations
- A. Wallace, Acting Operations Manager
D. Waters, Manager Regulatory Affairs
D. Winters, Shift Supervisor, Operations
Other licensee employees contacted included technicians, operators,
engineers, mechanics, security force members, and office personnel.
- Attended exit interview on September 15, 1993.
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2. Plant Status
Except for power reductions to perform required testing, the unit
operated at full power until initiating a shutdown at approximately
10:30 p.m., on September 10, 1993, to begin refueling outage 15.
The
unit-completed 351 days of continuous operation prior to the shutdown.
This was a record run for both Robinson and CP&L.
2
3. 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, 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 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
were appropriate.
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.
Boraflex Neutron Absorber
The resident inspectors performed a review of the licensee's use of
Boraflex in the spent fuel pool.
The inspectors determined that the
plant uses Boraflex as a neutron absorber in the high density fuel
racks. The licensee is aware of documented industry problems with
Boraflex and has evaluated IEN 87-43. At the close of this report
period, the licensee had not received IEN 93-70: Degradation Of Boraflex
Neutron Absorber Coupons. The licensee's operating staff is cognizant
of potential problems pertaining to spent fuel pool dilution and there
are procedural controls in place intended to prevent spent fuel pool
dilution.
The pool is maintained at a boron concentration of greater than 1950.
ppm.
The licensee has a chemistry sampling program in place to
routinely evaluate the boron concentration of the spent fuel pool.
The
results of the last three samples indicate a concentration in excess of
2100 ppm.
The licensee evaluates the integrity of the Boraflex absorber by
periodically analyzing coupon samples for signs of degradation.
3
According to the licensee's engineering staff, there has been no
evidence of the current, industry reported degradation in samples from
the Robinson SFP.
Turbine Runback During OST-005
At 11:28 a.m., on August 14, 1993, the unit experienced a runback during
the performance of OST-005, Nuclear Instrumentation Power Range (Bi
Weekly). The runback occurred when the SRO performing the OST
inadvertently mispositioned the dropped rod mode switch on power range
nuclear instrument N-41.
Following the SRO's recognition that a turbine runback was in progress,
the switch was restored to the correct position and the shift responded
to the transient. Following recovery from the transient, the unit was
restored to 100 percent power.
The inspectors interviewed the operator conducting OST-005; reviewed the
ACR and shift supervisor logs associated with the transient; and
analyzed the ERFIS printout for the runback. Additionally, the
inspectors reviewed the transient with the system engineer. Based on
this inspection effort, the inspectors determined that the operator
mispositioned the dropped rod mode switch when the OST was recommenced
following a brief interruption in the procedure. This interruption
occurred when the operator stopped the OST to obtain assistance in
monitoring an adjacent panel for an expected alarm. When the OST was
restarted, the operator manipulated the dropped rod mode switch instead
of the required operation selector switch.
Technical Specification 6.5.1.1, Procedures, Tests, and Experiments
requires, in part, that written procedures be established, implemented
and maintained, covering the activities recommended in Appendix A of
Regulatory Guide 1.33, Rev 2. 1978. Regulatory Guide 1.33 Paragraph
8.b. requires that procedures be written for technical specification
surveillances. Implicit in this is the requirement that these
procedures be followed while performing technical specification required
surveillances. Operations Surveillance Test Procedure, OST-005, Nuclear
Instrumentation Power Range (Bi-Weekly) is provided to satisfy a
Technical Specification required surveillance for the power range
nuclear instruments.
Contrary to the above, on August 14, 1993, an on-duty operator deviated
from OST-005 and repositioned the dropped rod mode switch to normal
position from the specified bypass position. This action resulted in a
turbine runback. This is identified as a potential violation, VIO
93-19-01:
Operator Deviation From OST-005 Results in Turbine Runback.
From the review of the ERFIS printout, the inspectors noted anomalies
associated with the runback. These observations included an unexpected
1.5 second interruption in the turbine load limit runback.
Additionally, the time delay relay actuation did not occur concurrently
with the turbine load limit runback as expected. These observations
4
were provided to the system engineer. Following his review of the
transient, and confirmation of these observations, the system engineer
indicated that the performance of the system would be examined during
the upcoming outage. This commitment was also reaffirmed by the
cognizant engineering supervisor.
As turbine power was decreased by the runback, an expected deviation in
the reactor coolant reference temperature (Tref) and the average reactor
coolant temperature (Tave) developed. In response to this deviation, an
automatic insertion .of control rods occurred. This insertion eventually
resulted in control rod bank D being inserted below the rod insertion
limit. This condition was cleared after a boric acid addition and
restoration of control rods to normal position in the subsequent
recovery. The control rod bank D rods were below the insertion limit
for approximately 5 minutes. During a subsequent review of the
transient the licensee recognized that the insertion limit had been
exceeded and generated an ACR and LER to address this situation.
TS 3.10.1.3 requires that the control rod insertion limits be satisfied.
However, no action statements or LCOs are provided for inability to
maintain the rod insertion limits.
During their review, the licensee concluded that the rod insertion
limits may be violated during transients. The licensee has indicated
their intention to revise TS 3.10.1.3 to incorporate this conclusion and
provide an action statement for restoring rod positions. The inspectors
have no further question on this item.
Area Fire Watch Vacates Post
On August 31, 1993, the licensee determined that an area fire watch had
vacated his assigned post prematurely. The watch had been stationed in
the Unit 2 cable spread room as required by Fire Protection Procedure
FP-012, Fire Protection Systems Minimum Equipment and Compensatory
Actions, when the halon suppression system for that area (zone 19) was
disabled. The system was disabled at 9:29 a.m., on August 31, 1993, to
support work on penetrations associated with an ongoing plant
modification. At 5:36 p.m. that same day, while restoring the zone 19
system to service, the on-shift fire technician determined that the area
fire watch had left the cable spread room prior to the restoration of
the system.
The inspectors interviewed the area fire watch and on-shift fire
technician. Additionally, the inspectors reviewed the security log
printout for the area; reviewed the shift supervisor and on-shift fire
technician logs; and discussed the event with the cognizant supervisors.
Based on this effort, the inspectors determined that the area fire watch
was unaware of his responsibility to remain at his assigned station
until the fire suppression system was restored to service.
Instead, the
area fire watch had left when the modification work being performed that
day had been completed.
5
The licensee has documented the event on a Condition Evaluation Report
and covered the event with a portion of the Craft Resources Unit. The
licensee also committed to reviewing this event with all members of the
Project Management Section who perform area fire watch duties.
The failure of the area fire watch to remain in the cable Spread Room
with the fire suppression system disabled is a violation of FP-012.
However, this violation will not be subject to enforcement action
because the licensee's efforts in identifying and correcting the
violation meet the criteria specified in Section VII.B of the
Enforcement Policy. This item is identified as a non-cited violation,
NCV 93-19-02:
Area Fire Watch Vacates Post.
Ethylene Glycol Spill
On Monday, August 30, 1993, the licensee management was informed by a
chemistry technician of a spill of approximately one gallon of ethylene
glycol (antifreeze) which occurred on Saturday, August 28, 1993. Since
this spill exceeded the reportable quantity specified in the licensee's
Best Management Plan, a notification was made to the South Carolina
Department of Health and Environmental Control at 9:50 a.m., on August
30. Additionally, a notification to the National Response Center was
made at 9:55 a.m. that same day. As a result of these notifications,
the licensee made a 4-hour non-emergency notification to the NRC in
accordance with the requirement of 10 CFR 50.72(b)(2)(VI), Offsite
Notification, at 11:05 a.m., on August 30, 1993.
Based on interviews of individuals involved, the inspectors determined
that the spill occurred when a 55-gallon drum of antifreeze was
accidently dropped and punctured during a routine movement. The spill
occurred at a site storage area and was limited to the ground in the
immediate vicinity of the drum. Immediately following the spill, the
on-shift chemistry technician was notified. Based upon his review of
the spill, the small quantity involved, and information provided on the
Material Safety Data Sheet, he concluded that the hazard presented by
the spill was minimal.
As a result, no further action was taken until
he notified his supervisor of the spill on Monday, August 30. Following
this, the dirt in the vicinity of the spill was removed and the
notifications discussed above were made. Based on their review of this
event, the inspectors concluded that while the licensee's initial
response to the spill was poor, the licensee met the requirements for
NRC notification specified in 10 CFR 50.72. The inspectors have no
further questions on this event.
4. 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, testing was accomplished by qualified
personnel in accordance with an approved test procedure, test
6
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:
OST-352
Containment Spray System Component Test
OST-401
Emergency Diesels (Slow Speed Start - EDG A Only)
No violations or deviations were identified. Based on the information
obtained during the inspection, the area/program was adequately
implemented.
5. 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
particular, the inspectors observed/reviewed the following maintenance
activities:
WR/JO 93BTQ371
Calibrate CS Pump Discharge Pressure Gauges In
Accordance With Procedure PIC-302, Process
Instrument Calibration Procedure Pressure and
Vacuum Gauges.
WR/JO 93BVY371
Calibrate The CCW Pumps Pressure Instrumentation
(PC-611 Only)
WR/JO 93AIGX1
Replace Misaligned Gasket On EDG A
WR/JO AILN2
Solenoid Valve EV 1727 Venting Continuously
Adequacy of Testing For CCW Pump Autostart Feature
During followup on the calibration of the CCW pump discharge pressure
switch PC-611, the inspectors noted that the calibration procedure did
not fully verify the logic associated with the switch. The switch
actuates on a low pressure condition in the CCW discharge header to
provide an automatic start of idle CCW pumps. The pressure switch (PC
611) operates to energize a relay, the contacts of which operate to
start the standby pumps. The calibration procedure only checked the
actuation of the contacts in PC-611.
No check was made of the
associated relay or its contacts.
7
The inspectors noted from a review of the "Preliminary Revision" of the
CCW Design Basis Document that the low pressure autostart capability was
a design feature of the system. Based on this, the inspectors requested
that the license address the adequacy of the existing calibration
procedure to verify this potential design feature. The licensee had not
completed this evaluation prior to the end of the inspection period.
Pending the resolution of this issue, this item will be tracked as an
unresolved item, URI 93-19-03: Adequacy Of Testing For CCW Pump
Autostart Feature.
No violations or deviations were identified. Except as noted above, the
area/program was adequately implemented.
6. ESF System Walkdown (71710)
Control Room Ventilation System Walkdown
The inspectors reviewed the control room habitability system with
primary emphasis on the ventilation portion of the system. This effort
included a walkdown of the ventilation equipment; a review of the
calibration of installed instrumentation; a review of testing
accomplished to satisfy TS requirements; and a verification of selected
portions of the control room envelope. The inspectors also witnessed the
operation of the system in the emergency pressurization mode. Based on
this review, the inspectors concluded that the system was properly
aligned and capable of performing its intended safety function.
However, deficiencies were identified in material storage, completeness
of testing, instrument calibration, and design control.
During a physical inspection of the interior of the Main Control Room
HVAC System Instrument Panel Safety Train A on August 25, 1993, the
inspectors noted foreign material stored in the panel. This panel
houses differential pressure instrumentation associated with the
operation of the control room ventilation system. The material
identified included 2 bottles of gas leak detector, 1 bottle of soap
solution for leak checks, and 1 bottle of refrigerant oil.
This
information was conveyed to the shift supervisor for resolution. The
storage of these items in a panel for Technical Specification required
equipment is considered a weakness. During a subsequent inspection of
the panel, the inspectors noted that the material had been removed.
During a review of instrument calibration, the inspectors noted that
temperature controllers TC-6559 A and TC-6559 B, used to verify control
room temperature within the limits of TS 4.15.a, were not included in
the plant instrument calibration program. These instruments not only
provide a display of the control room temperature, but are also used for
WCCU operation. Following the identification of this item, the licensee
began monitoring control room temperature using alternate calibrated
temperature instruments. The licensee also performed calibrations of
TC-6559 A and B. The inspectors reviewed the results of these
calibrations and noted that both instruments were found in calibration.
The licensee also indicated that the instruments would be added to the
8
calibration program. The inspectors reviewed documentation provided by
the licensee which demonstrated that TC-6559 A and TC-6559 B were
calibrated in December 1990 when installed as part of a modification to
upgrade the control room ventilation system.
Technical Specification 6.5.1.1, Procedures, Tests, and Experiments
requires, in part, that written procedures be established, implemented,
and maintained, covering the activities recommended in Appendix A of
Regulatory Guide 1.33, Rev. 2 1978, including procedures for ensuring
calibration of instruments. Maintenance Management Manual Procedure,
MMM-006, Calibration Program, is provided to ensure calibration of
installed plant instrumentation.
Contrary to the above, on August 31, 1993, MMM-006 was found to be
inadequate, in that, TC-6559 A and TC-6559 B (the instruments used to
verify compliance with Technical Specification limits on control room
temperature) were not included. This is one of two examples which in
the aggregate comprise a violation, VIO 93-19-04:
Failure To Properly
Maintain Instrument Calibration Program, Two Examples.
Based on the as-found data for the instrument being within tolerance and
observations of control room temperatures over the last operating cycle,
the inspectors concluded that this finding had minimal safety
significance.
The second item observed by the inspectors involved calibration of DPI
6520, Control Room Differential Pressure. The inspectors noted that
this instrument, which is used in surveillance testing to verify control
room pressurization capability, had not been calibrated within the
frequency specified in MMM-006. When queried by the inspectors on this
observation, the licensee stated that the instrument currently installed
as DPI-6520 is a manometer, which does not require calibration. The
calibration program had not been revised to reflect this change.
Technical Specification 6.5.1.1., Procedures, Tests, and Experiments
requires, in part, that written procedures be established, implemented,
and maintained, covering the activities recommended in Appendix A of
Regulatory Guide 1.33, Rev. 2, 1978, including procedures for ensuring
calibration of instruments. Maintenance Management Manual Procedure
MMM-006, Calibration Program, is provided to ensure calibration of
installed plant instrumentation.
Contrary to the above, on August 30, 1993, MMM-006 was found to be
inadequate, in that, DPI-6520, Control Room Differential Pressure
Instrument, was inappropriately included. This is the second of two
examples which in the aggregate comprise a violation, VIO 93-19-04:
Failure To Properly Maintain Instrument Calibration Program, Two
Examples.
The inspectors reviewed surveillance testing conducted on the control
room ventilation system and the surveillance requirements for the system
in Technical Specifications. Specifically, the following surveillances
9
were reviewed: EST-023, Control Room Ventilation System; OST-163, Safety
Injection Test and Emergency Diesel Generator Auto Start On Loss of
Power and Safety Injection and Emergency Diesels Trips Defeat; OST-924,
Radiation Monitoring System; and OST-750, Control Room Emergency
Ventilation System.
The inspectors noted that EST-023 performed on May 1, 1992, made
reference to backflow through the air cleaning unit while it was idle.
The EST noted that this was corrected by operating the dampers
associated with the unit several times. When questioned by the
inspectors on this issue, the system engineer indicated he was aware of
intermittent problems associated with the dampers on the ACU fans in-the
past. However, he stated that counterweights had been added to the
dampers to alleviate the problem. He was unsure if these additional
weights were added before or after the conduct of the EST. The
inspectors requested additional information on the sequence of these
events.
Pending resolution of this item it will be tracked as an
unresolved item, URI 93-19-05: Manipulation Of Air Cleaning Unit
Dampers During Performance Of Testing.
The inspectors also noted that the testing accomplished by OST-163 and
OST-924 does not fully comply with the requirements of TS 4.15.3. TS 4.15.3 requires verification that on an SI test signal or high radiation
test signal the system switches into the emergency pressurization mode
with flow through the air cleaning unit (ACU). Neither OST verifies
flow through the ACU. Instead, both merely check for proper alignment
of dampers and starting of fars. The inspectors requested clarification
from the licensee on the methodology used to satisfy the TS
surveillance. Pending the resolution of this issue, it will be tracked
as an unresolved item, URI 93-19-06: Adequacy Of Control Room
Ventilation System Surveillance Testing.
TMI Action Plan Requirement Item III.D.3.4, Control Room Habitability
Requirements, is considered closed. Closing this item is based on .
reviews and evaluations provided in NRC letters to CP&L dated May 17,
1991, and October 26, 1990, as well as the walkdown described above.
7.
Employee Concerns Program
The inspector reviewed the licensee's employee concern Quality Check
program which was created to provide employees an alternate path from
their supervisor and normal line management to express safety concerns
or allegations. As part of this inspection, the inspector reviewed the
program implementing procedure and discussed the program/process with
the site Quality Check Representative. Survey reports of Quality Check
activities were also reviewed. See attachment for questions addressed
during this inspection.
The licensee had established several methods for submission of employee
concerns which included employee interviews, telephone, or by submission
of Quality Check Report (QCR) forms in one of several Quality Check
Station lockboxes. The inspector was informed that confidentiality of
10
the submitter was maintained. The Manager - Quality Check was
responsible for reviewing the QCRs and identifying nuclear safety issues
or other matters requiring management attention. Employee concerns were
classified in one of three categories. Nuclear safety issues or
technical/quality issues received the classification of a "Case" which
required an investigation and some form of action. Other concerns, such
as personnel issues, resulted in classification of Management
Information Items (MIls) or Notices of Information. Only Cases and MIIs
required a formal response from line management. After review by the
Manager - Quality Check, the concern was then transferred to Quality
Check forms and routed to assigned evaluators/investigators. The
inspector found that consideration was provided for reportability
determination by reference in the Quality Check forms to the licensee's
Corrective Action Program. The surveys of Quality Check activities for
1991, 1992, and through July 1993, indicated that 111 employee concerns
had been expressed. Of these, only 1 remained open.
8. Followup (92700, 92701, 92702)
(Closed) Unresolved Item 93-11-04, Degraded Diesel Generator Ventilation
System.
As detailed in Inspection Report 93-11, during the June 10, 1993
performance of bi-weekly surveillance test OST-401 on the A EDG,
licensee personnel observed that the room ventilation air return damper
was partially open when it was to have been closed. The damper is
designed to automatically close when the ambient air temperature is
above 55 degrees F. With the damper partially open, the efficiency of
the ventilation system was degraded. The licensee found that the damper
had been manually blocked open by a wooden wedge which had apparently
been manufactured for that purpose. At the close of that report period,
the licensee was evaluating the impact of this unauthorized modification
on the system's ability to perform its intended safety function and in
turn, the operability of the EDG. Pending the completion of that
evaluation, the issue remained unresolved.
The resident inspectors reviewed the licensee's safety analysis of the
event which indicated that the event had minimal impact on plant safety,
in that, the operability of the diesel was not jeopardized.
Specifically, the analysis indicated that under accident conditions,
operators would investigate the source of an abnormal temperature in the
room, and would have been able to take corrective actions (i.e., remove
the block of wood) prior to conditions causing a threat to the diesel.
Although the unauthorized modification of the ventilation system did-not
result in a significant diesel generator operability challenge, it
represents a failure to maintain system design integrity.
10 CFR 50 Appendix B, Criterion III Design Control, requires in part,
that measures be established to ensure that the design basis for
structures systems and components be maintained. Contrary to these
requirements, the design integrity of the A Emergency Diesel Generator
11
Ventilation System was not maintained in that the system underwent an
unauthorized modification which decreased its ability to performs its
intended function. However, this violation will not be subject to
enforcement action because the licensee's efforts in identifying and
correcting the violation meet the criteria specified in Section VII.B of
the Enforcement Policy. This item is identified as a non-cited
violation, NCV 93-19-07: Degraded Diesel Generator Ventilation System.
9. Exit Interview (71701)
The inspection scope and findings were summarized on September 15, 1993,
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. The licensee did not identify as
proprietary any of the materials provided to or reviewed by the
inspectors during this inspection.
During the exit meeting, the licensee stated that the runback on
August 14, 1993, was the result of operator error. The licensee
questioned the appropriateness of a potential violation for a failure to
follow the applicable procedure in that the SRO did not willfully fail
to follow the procedural guidance. The inspectors acknowledged that the
violation did not appear to be willful, but informed the licensee that
the net result of the operator's error was a departure from the sequence
specified in the procedure, which in this case resulted in a turbine
runback. It was this deviation from the procedure which served as the
basis of the violation.
The licensee also questioned the characterization of the violation for
failing to calibrate TC-6559 A and B and maintaining DPI -6520 in the
calibration program as a failure to properly maintain MMM-006. The
licensee stated that these instruments had not been included in the
calibration program as a result of a failure in the modification process
(that being the failure of the modification which installed the
instrumentation) to provide appropriate documentation to revise MMM-006.
The licensee also stated that the inspectors had been informed of this
during the inspection period.
The inspectors acknowledged that they had been advised of this potential
inadequacy in the modification process during the inspection period.
However, the inspectors detected this problem during an ESF walkdown
while comparing the instruments installed in the control room
ventilation system against instruments listed in MMM-006. Since the
identification of the violation occurred while reviewing the
completeness of MMM-006, the inspectors concluded that it would be
appropriate to cite the violation against the inadequate procedure.
The following items were identified and reviewed during this inspection
period:
12
Item Number
Description/Reference Paragraph
93-19-01
VIO: Operator Deviation From OST-005 Results In
Turbine Runback (paragraph 3).
93-19-02
NCV: Area Firewatch Vacates Post (paragraph 3).
93-19-03
URI: Adequacy Of Testing For CW Pump Autostart
Feature (paragraph 5).
93-19-04
VIO: Failure To Properly Maintain Instrument
Calibration Program, Two Examples (paragraph 6).
93-19-05
URI: Manipulation Of Air Cleaning Unit Dampers
During Performance Of Testing (paragraph 6).
93-19-06
URI: Adequacy Of Control Room Ventilation
System Surveillance Testing (paragraph 6).
93-19-07
NCV: Degraded Diesel Generator Ventilation
System (paragraph 8).
10.
List of Acronyms and Initialisms
ACU
Air Cleaning Unit
Component Cooling Water
CFR
Code of Federal Regulations
DPI
Differential Pressure Instrument
ERFIS
Emergency Response Facility Information System
Heating Ventilation Air Conditioning
IEN
Inspection Enforcement Notice
LCO
Limiting Condition for Operation
LER
Licensee Event Report
Loss of Coolant Accident
MII
Management Information Items
MMM
Maintenance Management Manual
NRC
Nuclear Regulatory Commission
OST
Operations Surveillance Test
Process Instrument Calibration
Parts Per Million
QCR
Quality Check Report
Safety Injection
Spent Fuel Pool
Senior Reactor Operator
TAVE
Average Temperature of the Reactor Coolant
TI
Temporary Instruction
Three Mile Island
TREF
Reference Temperature of the Reactor Coolant
13
TS
Technical Specification
Unresolved Item
Violation
WCCU
Water Cooled Condensing Unit
0
ATTACHMENT
EMPLOYEE CONCERNS PROGRAMS
PLANT NAME: Robinson
LICENSEE: CP&L
DOCKET #: 50-261
NOTE: Please indicate yes or no as applicable and add comments in the space
provided.
A.
PROGRAM:
1.
Does the licensee have an employee concerns program? Yes
2.
Has NRC inspected the program? No. Quality Check site representative
discusses current issues with the Senior Resident Inspector on a routine
basis.
B.
SCOPE: (Indicate all that apply.)
1.
Is it for:
a. Technical? Yes
b. Administrative? Yes
c. Personnel issues? Yes
2.
Does it cover safety as well as non-safety issues? Yes
3.
Is it designed for:
a. Nuclear safety? Yes
b. Personal safety? Yes
c. Personnel issues - including union grievances? Yes
4.
Does the program apply to all licensee employees? Yes
5.
Contractors? Yes
6.
Does the licensee require its contractors and their subs to have a
similar program? No
7.
Does the licensee conduct an exit interview upon terminating employees
asking if they have any safety concerns? Yes.
C.
INDEPENDENCE:
1.
What is the title of the person in charge? Manager, Quality Check
2.
To whom do they report? Manager, Nuclear Assessment Department
3.
Are they independent of line management? Yes
4.
Does the ECP use third party consultants? The licensee does not
normally use outside consultants as part of the program.
5.
How is a concern about a manager or vice president followed up? A
review of the concern is conducted by the next level of management.
Concerns directed against the Manager, Nuclear Assessment Department are
immediately forwarded to the [Executive] Vice President, Nuclear
Generation Group
D.
RESOURCES:
1.
What is the size of the staff devoted to this program? Four. One
manager and three site representatives.
2.
What are ECP staff qualifications (technical training, interviewing
training, investigator training, other)? Minimal.
"Interviewing"
training including OJT. Experienced QA/QC personnel in this position.
E. REFERRALS:
1.
Who has followup on concerns (ECP staff, line management, other)?
Concern is identified, reviewed and classified by ECP staff members and
then forwarded to line management personnel for investigation and
resolution.
F. CONFIDENTIALITY:
1.
Are the reports confidential? Yes
2.
To whom is the identity of the alleger made known (senior management,
ECP staff, line management, other)? Senior management and ECP staff
3.
Can employees:
a. be anonymous? Yes
b. report by phone? Yes
G. FEEDBACK:
1.
Is feedback given to the alleger upon completion of the followup? Yes.
Verbal communication of results/resolution.
2.
Does program reward good ideas? Yes. Good ideas are rewarded with a
letter of appreciation from the President or Chief Operating Officer.
3.
Who, or at what level, makes the final decision of resolution? Manager,
Quality Check
4.
Are the resolutions of anonymous concerns disseminated? No, only to
submitter.
H. EFFECTIVENESS:
1.
How does the licensee measure the effectiveness of the program? The
licensee has no formal measure of program effectiveness.
2.
Are concerns:
a. Trended? Yes. Monthly status of number received and total YTD;
semi-annual report to senior management.
b. Used? Yes
3.
In the last three years how many concerns were raised?
111
Of the concerns raised, how many were closed? 110
What percentage were substantiated? The licensee does not substantiate
concerns.
4.
How are followup techniques used to measure effectiveness (random
survey, interviews, other)? A random survey conducted by senior
management.
5 )A-2
5.
How frequently are internal audits of the ECP conducted and by whom?
Infrequent. Only one internal audit of the program has been performed
since 1990, that one being conducted in August 1993.
I. ADMINISTRATION/TRAINING:
1.
Is ECP prescribed by a procedure? Yes
2.
How are employees, as well as contractors, made aware of this program
(training, newsletter, bulletin board, other)?
Initial GET training,
bulletin boards, ECP boxes located throughout the plant, posters, and
brochures.
A-3