ML14178A442
| ML14178A442 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 01/20/1994 |
| From: | Christensen H, Ogle C, William Orders NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A438 | List: |
| References | |
| 50-261-93-33, NUDOCS 9402080109 | |
| Download: ML14178A442 (12) | |
See also: IR 05000261/1993033
Text
v REcu
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION il
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
Report No.:
50-261/93-33
Licensee:
Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC 27602
Facility Name: H. B. Robinson Unit 2
Inspection Conducted:
November 21 - December 25, 1993
Lead Inspector:
2
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5&'
W. . Orders, enior esi
t Inspector
Date Signed
Other Inspector:
Lz i-2
Og le,
Residenl/ nsplyor
Date Signed
Approved b :_
_
_
_-_-----
S0. C r stensen, Chief
Date Sgn d
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, plant safety review committee
activities, and followup.
Results:
One Violation was identified which involved a failure to take adequate
corrective action for pressurizer pressure transmitters found out of
tolerance, paragraph 4; a non-cited violation was identified which involved a
failure to have a procedure to control a transfer canal pumpdown, paragraph
3.b; a Deviation was identified which involved the failure to install RHR pump
suction pressure instrumentation as committed to in response to Generic Letter 88-17, paragraph 3.c; and an Inspector Followup Item was identified involving
the need for verification of CV spray and turbine auto stop circuitry
continuity following routine testing, paragraph 3.d.
9402080109 940120
ADOCK 05000261
Q
REPORT DETAILS
1.
Persons Contacted
- R. Barnett, Manager, Projects Management
C. Baucom, Senior Specialist, Regulatory Compliance
D. Bauer, Regulatory Compliance Coordinator, Regulatory Compliance
J. Benjamin, Shift Outage Manager, Outages and Modifications
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
B. Harward, Manager, Engineering Site Support, Nuclear Engineering
Department
- S. Hinnant, Director, Site Operations
P. Jenny, Manager, Emergency Preparedness
D. Knight, Shift Supervisor, Operations
E. Lee, Shift Outage Manager, Outages and Modifications
A. McCauley, Manager, Electrical Systems, Technical Support
R. Moore, Manager, Operations
D. Morrison, Shift Supervisor, Operations
D. Nelson, Manager, Outage Management
A. Padgett, Manager, Environmental and Radiation Control
- M. Pearson, Plant General Manager
D. Seagle, Shift Supervisor, Operations
M. Scott, Manager, Reactor Systems, Technical Support
E. Shoemaker, Manager, Mechanical Systems, Technical Support
W. Stover, Shift Supervisor, Operations
D. Winters, Shift Supervisor, Operations
Other licensee employees contacted included'technicians, operators,
engineers, mechanics, security force members, and office personnel.
- Attended Exit Interview on January 12, 1993.
Acronyms and initialisms used throughout this report are listed in the.
last paragraph.
2.
Plant Status
The Unit began the report period in a forced outage which began on
November 17, when a drain valve on the discharge of one of the main
feedwater pumps was determined to be leaking. On November 20, 1994, a
RH based Augmented Inspection Team reported to the site to investigate
problems which had been identified with the Unit's restart from RFO15.
During that startup, a number of problems were identified involving
operator performance, and fuel manufacturing errors. Details of that
inspection are delineated in Inspection Report 50-261, 93-34. The Unit
remained shutdown through the end of the report period performing
2
required maintenance on the diesel generators and implementing
corrective actions to equipment and personnel deficiencies identified
during the forced outage.
3.
Operational Safety Verification (71707)
a.
General
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, 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.
b.
SFP Draindown
At 5:15 a.m. on December 3, 1993, a SFP low level alarm was
received in the control room. An AO dispatched to investigate
reported that the SFP level was between 36 feet and 36 feet 2
inches, just below the nominal SFP low level alarm setpoint of 36
feet 2.5 inches. The AO observed that the SFP level was
decreasing as a result of the transfer canal pump discharge hose
siphoning SFP water back into the canal when the pump was secured.
The hose was approximately 1 to 2 inches below the surface of the
water. The siphon was broken by lifting the hose clear of the
surface of the SFP and the transfer canal was subsequently pumped
down to restore SFP level.
3
In response to the event, the Operations manager directed the
cessation of SFP transfer canal pumping operations. An ACR was
written and a team formed to review the event. As a result of the
licensee investigation, the need for a procedure to govern the
pumpdown of the SFP transfer was identified. The licensee
committed to developing this procedure prior to February 1994.
The inspectors reviewed log entries associated with the event;
interviewed the cognizant shift supervisor, system engineer, and
the plant manager; and inspected the general arrangement of the
pump discharge hose used to reduce the transfer canal water level.
The inspectors also reviewed the evaluation completed in response
to the ACR for the event.
Based on this effort, the inspectors determined that the.siphoning
occurred as a result of not removing the hose from the higher
elevation SFP following the pumpdown of the transfer canal.
This
pumping was necessitated by weir gate leakage to the canal.
No
procedure existed to govern this evolution. Furthermore, licensee
management was aware of this lack of procedural guidance prior to
the SFP draindown.
While no TS violation occurred as a result of this level
excursion, the inspectors did note that the placement of the hose
had bypassed an anti-siphon hole in the SFP cooling water return
line located at approximately 36 feet 5 inches. This feature is
credited in a safety evaluation in the FSAR as providing
protection against inadvertently siphoning the SFP.
The failure to perform the transfer canal pumpdown in accordance
with a procedure is a violation of 10 CFR 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings. 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 is identified as a non-cited violation, NCV 93-33
01:
Failure to Proceduralize Transfer Canal Pumpdown.
C.
Preparations For RCS Draindown
The inspectors reviewed preparations for reducing RCS water level
to approximately 16 inches below the vessel flange to support
vessel head reinstallation. This review was documented on a mid
loop/reduced inventory checklist and forwarded to Region II under
separate cover on December 13, 1993.
For this draindown, the
vessel water level remained well above the reduced inventory
setpoint of -36 inches. However, the checklist verifies items
from Generic Letter 88-17 which minimize the potential for and
consequences of a loss of decay heat removal with less than full
vessel.
4
Overall, the inspectors noted that the licensees preparations were
good and in general, fulfilled the recommendations of GL 88-17.
The inspectors did note that the draindown procedure used for this
evolution, did not contain a precaution to minimize perturbations
in RCS level when the vessel inventory was reduced. (This
precaution was contained in the appropriate procedure for reduced
inventory.)
Following questions on this point by the inspectors,
GP-009, Filling, Purification, and Draining of the Refueling
Cavity was revised to include a precaution to this effect.
The inspectors also observed that the licensee's sensitivity to
the plant's performance while in this condition was adequate. For
example, a camera monitor was installed in the control room to
provide a remote indication of the RCS water level as measured on
the tygon tube standpipes. Though the camera monitor has been
used in the auxiliary building in the past, its placement in the
control room was a significant enhancement in the control room
monitoring capability. Furthermore, a watchstander was dedicated
to this monitor when the RCS was lower than 5 feet above the
flange. The inspectors also observed that the responsible control
room watchstanders were cognizant of the RCS water level and
sensitive to variation between the indicators. These observations
are considered strengths.
However, on December 16, 1993, the inspectors observed that all
incore thermocouples displayed "bad" instead of the incore
temperature. The inspectors were advised that this was the result
of RCS temperature being reduced below the 80* F low end setpoint
of the incore thermocouple system. This had been deliberately
accomplished to ensure that the mismatch between the head and
vessel temperatures was within procedural limitations.
The inspectors questioned the shift supervisor and the Engineering
Technical Support staff on the prudence of intentionally disabling
all incore temperature monitoring equipment. The inspectors were
advised that RCS temperature was being raised to restore the
temperature indication. On a subsequent tour of the control room
on December 17, 1993, the inspectors observed that RCS temperature
had been raised and that incore thermocouple indication had been
restored. The inspectors were also advised that since RHR flow
existed through the core, alternate indications of core
temperature conditions existed. Furthermore, the inspectors were
informed that in the event core cooling was lost, core
temperatures would rise and upon exceeding 80' F, the thermocouple
indication would be restored. The inspectors determined from
interviews of Engineering Technical Support personnel that
alternatives to reducing RCS temperature below 80' F and
subsequently disabling the incore thermocouples may have existed.
For example, the head could have been permitted to warm up after
placement on the vessel.
Alternatively, the incore thermocouple
temperature could have been determined using measuring and test
equipment. The inspectors concluded that the licensee's
5
temporarily disabling incore thermocouple temperature indication
with a reduced RCS water level was a Weakness.
In reviewing the licensee's written response to Generic Letter 88-17, Serial NLS 89-024 dated February 1, 1989, the inspectors
noted that the licensee committed to the installation of a
"suction pressure indicator and associated low pressure alarm [on]
No such features exist. RHR
indication on the RTGB consists of: RHR total flow, pump discharge
pressures, and temperatures of pump and heat exchanger discharges.
Alarms are provided for low RHR pump cooling water flows, high and
low RHR pump discharge pressures, RHR heat exchanger low flows,
and RHR pump motor overload/trip. In response to the inspectors'
questions on why this commitment was not satisfied, the inspectors
were provided extracts Modification 1011, Instrumentation for Mid
loop Operation. This information documented the licensees
evaluation and subsequent installation of RHR pump discharge
pressure instruments and alarms in lieu of the suction pressure
instrumentation. This is identified as a deviation, DEV 93-33-02,
Failure to Install RHR Pump Suction Pressure Instrumentation as
Committed To In Response To Generic Letter 88-17.
d.
ESFAS/RPS Logic Testing
On December 20, 1993, in response to NRC Information Notice 93-38,
Inadequate Testing of Engineered Safety Features Actuation
Systems, the licensee determined that routine testing performed on
the CV spray system was deficient. Specifically, Maintenance
Surveillance Test Procedures, MST-016:
Containment Pressure
Protection Channel (SET I, II, and III) Testing (Bi-Weekly); MST
022: Safeguard Relay Rack Train "A" (Monthly); and MST-023:
Safeguard Relay Rack Train "B" (Monthly) were all found deficient,
in that, following testing the actuation circuit continuity was
not completely verified. The CV spray system is designed such
that the actuation relays are normally de-energized. On a high
high containment pressure condition, the containment spray logic
matrix operates to energize the CV spray actuation relays. The
licensee determined that no continuity checks were performed on
test switches in series with the input relay coil or the bistable
outputs upon their restoration to the normal position at the end
of the surveillances. The failure to establish this continuity
could interrupt a valid actuation signal and hence, render the
circuit inoperable.
Subsequently, the licensee also determined that similar
deficiencies existed in routine testing performed to verify proper
operation of the turbine auto stop circuitry (reactor trip
coincident with turbine trip if greater than P-7 interlock).
In response to these discoveries, the licensee stated that they
satisfactorily conducted testing to verify the continuity of these
circuits. Furthermore, the licensee was evaluating the need to
6
modify existing testing for these circuits. Pending the
resolution of these reviews this item will be tracked as an
inspector follow-up item, IFI
93-33-03: Need For Verification Of
CV Spray And Turbine Auto Stop Circuitry Continuity Following
Routine Testing.
The inspectors reviewed the operation of the CV spray and auto
stop circuits with the system engineer. Additionally, the
inspectors reviewed portions of the WR/JO used to document the
testing performed after the discovery of the MST deficiencies.
Other than the IFI identified above, the inspectors have no
further questions.
One deviation was identified. Except as noted above, the
area/program was adequately implemented.
4.
Maintenance Observation (62703)
a.
General
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:
Cycle 16 Fuel Assembly Inspection (Video Review)
WR/JO 93-APAH1
Install New Air Start Distributor On B EDG
WR/JO 93-AKXD1
Replace Pressurizer Transmitter PT-457
WR/JO 93-APAH1
Install New Air Start Distributor On B EDG
b.
Fuel Assembly Inspection
On December 10, 1993, the inspectors reviewed a videotape taken
during the performance of Special Procedure, SP-1280, Cycle 16
Fuel Assembly Inspection. This special procedure was accomplished
to verify the position of gadolinium bearing fuel elements in
assemblies X-43 and X-39. As a result of this special procedure,
the licensee concluded that the gadolinium bearing fuel elements
were properly positioned in these assemblies. Based upon the
inspectors comparisons of fuel element serial numbers recorded on
the videotape and on fuel assembly bundle maps, the inspectors
concurred with this conclusion. The inspectors have no further
questions on this special procedure.
7
c.
EDG Air Start Distributor Maintenance
On December 20, 1993, in response to concerns raised by the
licensee during the root cause analysis of B EDG start failures,
the air start distributor for that engine was replaced. During
the installation of the new distributor, while torquing the drive
shaft nut to the 185 ft - lbs of torque specified in the assembly
procedure, the camshaft threads failed. Following procurement of
a new camshaft, the air distributor was successfully installed on
December 22, 1993.
The engine was successfully operated in accordance with OST-401,
Emergency Diesels (Slow Speed Start), on December 21, 1993. ( A
subsequent failure to start, however, was observed for the engine
on December 26, 1993.)
The inspectors witnessed portions of the air start distributor
maintenance performed on December 20 and 21, 1993. Overall, the
inspectors noted that the maintenance was well performed and the
work was accomplished in accordance with appropriate procedures.
Maintenance supervisory participation was also evident.
Though not in attendance for the camshaft thread stripping, the
inspectors concluded from their review of maintenance
documentation and interviews of cognizant personnel that the
threads were overtorqued as a result of erroneous torque valves
provided by the vendor. The torque valves for this nut provided
by the manufacturer have ranged as high as 480 ft-lbs. In fact,
while attempting to achieve 480 ft-lbs of torque on November 24,
1993, a failure of the air start cam was incurred. The licensee
has revised Corrective Maintenance Procedure, CM-627, Emergency
Diesel Generator Air Start System Maintenance, to reflect a
required torque of 55 ft-lbs. This revision was based on a
written recommendation received from the vendor. The inspectors
reviewed the vendor's letter specifying the revised torque and the
licensee's review performed to change CM-627. The inspectors have
no further questions on this maintenance.
C.
Pressurizer Pressure Transmitter Calibration/Replacement
On November 30, 1993, the licensee determined though a special
calibration, that pressurizer pressure transmitters PT-455 and PT
457 were out of tolerance. These instruments provide pressure
inputs for the low pressure reactor trip, high pressure reactor
trip, and safety injection initiation. Both instruments
experienced a maximum drift of 0.017 mV resulting in both
instruments reading at worst approximately 3.4 psig too high. In
response to this out of tolerance condition the licensee replaced
the two transmitters. Additionally, the licensee performed an
analysis of the out of tolerance condition and concluded that no
violation of TS resulted.
8
The inspectors reviewed the instrument calibration data sheets and
work packages associated with this event as well as the licensee's
evaluation of the as found calibration data. Additionally, on
December 14, 1993, the inspectors witnessed the replacement of PT
457 in accordance with WR/JO 93-AKXD1. The inspectors have no
further questions on this documentation. The inspectors concurred
that no violation of TS occurred.
Inspection Report 93-28 discussed a series of calibrations
performed on PT-455, PT-456, and PT-457 during RFO-15. That
report outlines instrument adjustments of PT-455, PT-456, and PT
457 on October 15, 1993, following drift outside allowed tolerance
just 2 days after the instruments had been calibrated on October
13, 1993. Transmitter PT-456 was also found out of tolerance on
October 15, 1993, however, on November 30, 1993, it was within
calibration tolerances.
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires
that measures be established to assure that the cause of
conditions adverse to quality be determined and corrective action
taken to preclude repetition. Contrary to the above, on November
30, 1993, the licensee determined that pressurizer pressure
transmitters PT-455 and PT-457 had drifted out of calibration
tolerance. The licensee's corrective action to a similar
occurrence of these instruments drifting out of tolerance between
October 13 and October 15, 1993, failed to prevent this event.
This is identified as a violation, VIO 93-33-04:
Failure To Take
Adequate Corrective Action For Pressurizer Pressure Transmitters
Found Out Of Tolerance.
One violation was identified. Except as noted above, the
area/program was adequately implemented.
5.
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,
the tests were completed at the required frequency, and that the tests
conformed to TS requirements. Upon test completion, the inspectors
verified the recorded test data was complete, accurate, and met TS
requirements, test discrepancies were properly documented and rectified,
and that the systems were properly returned to service. Specifically,
the inspectors witnessed/reviewed portions of the following test
activities:
OST-401
Emergency Diesels (Slow Speed Start) (EDG B
Only)
9
No violations or deviations were identified. Based on the information
obtained during the inspection, the area/program was adequately
implemented.
6.
Fire Protection/Prevention Program (64704)
The inspectors toured the plant routinely throughout the report period.
During those tours, the fire protection features of the following areas
were inspected:
Diesel Generator "A" Room
Diesel Generator "B" Room
Safety Injection Pump Room
Auxiliary Building First and Second Level Hallways
Emergency Switchgear Room
Component Cooling Pump Room
Turbine Building
The manual fire fighting equipment, automatic fire detection systems,
and fire area/fire zone boundary walls, floors, and ceilings associated
with the above plant areas were inspected and verified to be in service
or functional.
Based on these observations, it was concluded that the
fire protection features associated with these areas were being
adequately maintained.
During this inspection period, the inspectors did not witness any
instances of inadequate implementation of fire prevention administrative
procedures, such as the posting of fire watches, there have been a
number of cases during the last 6 months in which a fire watch left his
watch station before being relieved. This is considered a weakness in
the licensee's implementation of the fire protection/prevention program
and the instances were identified in Inspection Reports 50-261/93-19 and
50-261/93-21 as Non-cited Violations.
The licensee's implementation of housekeeping procedures were reviewed
during the inspectors' tours. Other than minor discrepancies which were
identified to the licensee and immediately resolved, the licensee's
control of combustibles and flammable materials, liquids and gases, as
well as general housekeeping were found to be adequate.
The inspectors visually verified the proper alignment of the sectional
control valves in the main fire protection water supply system.
Except as noted above, the licensee's fire protection/prevention program
appeared to be adequately implemented.
10
7.
Followup (92700, 92701, 90702)
(Closed) Unresolved Item 93-19-06, Adequacy of Control Room Ventilation
System Surveillance Testing
Unresolved item, URI 93-19-06, documented that testing accomplished by
OST-163 and OST-924 failed to fully comply with the requirements of TS 4.15.f.3. This TS requires verification that on a SI test signal or
high radiation test signal the control room ventilation system switches
into the emergency pressurization mode with flow through the ACU.
Instead, both OSTs merely check for proper alignment of dampers and
starting of fans in the system. In response to the URI, the licensee
stated that OST-750, Control Room Emergency Ventilation System,
Biweekly, verified flow through the ACU while in the emergency
pressurization mode on a biweekly basis. The licensee stated that the
flow data obtained from OST-750 on a biweekly basis in combination with
the observations of OST-163 and OST-924 provided sufficient evidence to
satisfy the requirements of TS 4.15.f.3. However, the licensee also
committed to modifying OST-163 and OST-924 to require the verification
of air flow through the ACU so that each OST can satisfy TS
independently. URI 93-19-06 is considered closed.
8.
Exit Interview (71701)
The inspection scope and findings were summarized on January 12, 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. 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. The following items were identified and reviewed during
this inspection period:
Item Number
Description/Reference Paragraph
NCV 93-33-01
Failure to Proceduralize Transfer Canal
Pumpdown.
DEV 93-33-02
Failure to Install RHR Pump Suction Pressure
Instrumentation as Committed To In Response To
IFI
93-33-03
Need For Verification Of CV Spray And Turbine
Auto Stop Circuitry Continuity Following Routine
Testing.
VIO 93-33-04
Failure To Take Adequate Corrective Action For
Pressurizer Pressure Transmitters Found Out Of
Tolerance.
9.
List of Acronyms and Initialisms
ACR
Adverse Condition Report
ACU
Air Cleaning Unit
Auxiliary Operator
10
11
CFR
Code of Federal Regulation
Corrective Maintenance
CV
Containment Vessel
DEV
Deviation
Final Safety Analysis Report
GL
Generic Letter
General Procedure
IFI
Inspection Followup Item
LCO
Limiting Condition for Operation
Maintenance Surveillance Test
Mv
Milli-volt
Non-cited Violation
NRC
Nuclear Regulatory Commission
OST
Operations Surveillance Test
psig
Pounds Per Square Inch Gauge
Reactor Turbine Gauge Board
Spent Fuel Pit
Safety Injection
Special Procedure
TS
Technical Specification
Unresolved Item
Violation
WR/JO
Work Request/Job Order