ML14178A448
| ML14178A448 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/18/1994 |
| From: | Christensen H, William Orders NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A446 | List: |
| References | |
| 50-261-94-03, 50-261-94-3, NUDOCS 9402280095 | |
| Download: ML14178A448 (15) | |
See also: IR 05000261/1994003
Text
pfR REsG
UNITED STATES
0
NUCLEAR REGULATORY COMMISSION
REGION I
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
Report No.:
50-261/94-03
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: December 26, 1993 - January 22, 1994
Lead Inspector:
1 - -Yc-3/'14
.J1
W. T/ Orders, Synior dsident Inspector
Date Signed
Other Inspectors:
C. R. Ogle, Resident Inspector
P. A. Balmain, Resident Inspector, Vogtle
P. Byron, Resident Inspector, Brunswick
C. W. Rapp, Region II Inspector
M. N. Miller, Region II Inspector
J. L. Starefos, Project Engineer
Accompanying Personnel:
E. Wang, Reactor Engineer (Intern)
Approved by:
t i2<
H. 0. Christensen, Chief
Date Signed
Reactor Projects Section IB
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, followup of previously identified items and verification of the
completion of Confirmation of Action Letter commitments.
Results:
A non-cited violation was identified which involved the failure to make timely
NRC notification of licensed operator termination and failure to respond.to a
notice of violation within specified time, paragraph 3;
a violation was
.identified
which involved inadequate debris intrusion control measures
employed during maintenance, paragraph 4; a second violation was identified
involving the licensee's failure to post the response to a radiological
working condition violation, paragraph 6.
9402280095 940218
ADOCK 05000261
G
REPORT DETAILS
1.
Persons Contacted
- G. Attarian, Chief Electrical Engineer
- R. Barnett, Manager, Projects Management
C. Baucom, Shift Outage Manager
- 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
- W. Dorman, Acting Manager, Regulatory Affairs
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
- M. Herrell, Manager, Training
- 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, Acting Operations Manager
0. Morrison, Shift Supervisor, Operations
- M. Page, Manager, RESS Mechanical
D. Nelson, Shift Outage Manager, Outages and Modifications
- C. Olexik, Robinson Assessment Section
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
0. Winters, Shift Supervisor, Operations
Other licensee employees contacted included technicians, operators,
engineers, mechanics, security force members, and office personnel.
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2.
Plant Status
The Unit began the report period continuing the forced outage,
which began on November 17.
The Unit remained shutdown throughout
the report period while the licensee implementing corrective
actions to equipment and personnel deficiencies identified during
the forced outage and as required by an NRC Confirmation of Action
Letter issued on November 19, 1993.
2
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.
The inspectors reviewed shift logs, Operation's records, data
sheets, instrument traces, and records of equipment malfunctions
to verify equipment operability and compliance with TS. The
inspectors verified that the staff was knowledgeable of plant
conditions, responded properly to alarms, adhered to procedures
and applicable administrative controls, were cognizant of in
progress surveillance and maintenance activities, and were aware
of inoperable equipment status through work observations and
discussions with Operations staff members. 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 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.
Notification Of Unusual Event Due To Both EDGs Being
At 3:12 p.m. on January 17, 1994, the licensee declared an
Unusual Event when it was concluded that both EDGs were
inoperable. The A EDG was declared inoperable when the
licensee found water dripping onto the diesel's control
cabinet and current transformer cubicles. The B EDG had
previously been removed from service to support maintenance
and modification work. The licensee suspended work on the B
EDG and removed the clearance. The Unusual Event was exited
at 5:13 p.m. that day, following restoration and successful
testing of the B EDG.
The inspectors were notified of the event, reported to the site,
and witnessed the licensee's event response. In general the
inspectors concluded the response was satisfactory. The
3
inspectors also verified that appropriate notifications were
performed in accordance with regulatory requirements.
The licensee determined the source of the water leaking onto the
diesel to be coming from valve EV-6646, an EAC 2 Solenoid Valve.
Service water was spraying from the body to bonnet joint on the
valve, into the air intake enclosure of EAC-2. A portion of this
spray entered a normally open damper which penetrates the A EDG
room immediately above the current transformer and generator
control cubicles.
The licensee theorized that the valve failure occurred as a result
of freezing conditions experienced in the EAC air intake
enclosure. It was also noted that the air intake dampers on the
EAC were not properly closing which probably exacerbated the
situation.
The inspectors witnessed the satisfactory testing of B EDG in
accordance with procedure OP-604, Diesel Generators A and B, and
the system's return to service.
c.
Failure To Make Timely NRC Notifications
On December 28, 1993, the licensee informed the resident staff
that a notification to the NRC concerning the status of a licensed
operator as well as a violation response, were not made within the
prescribed timeframes.
The late notification involved a licensed operator who terminated
his employment effective October 29, 1993. The required written
notification to the NRC concerning the status change was not made
until December 24, 1993, which exceeded the allowed 30-day
reporting requirement specified in 10 CFR 50.74.
The late violation response involved the licensee's written
response to a violation documented in NRC Inspection Report
50-261/93-26. The licensee's response was dispatched on
December 29, 1993.
In as much as the Notice of Violation was
dated November 26, 1993, the response exceeded the allowed 30-day
response timeframe of 10 CFR 2.201.
An Adverse Condition Report was generated by the licensee in
response to these incidents. The inspectors were informed that
these events were reviewed with the cognizant individuals and that
a generic checklist/scheduling aid to track the timeliness of NOV
responses and LERs would be generated.
Additionally, the licensee stated that a process to allow track of
required correspondence to the NRC on issues related to licensed
operators would be developed.
4
The failure to communicate the notification and violation response
in accordance within the specified timeframes is a violation.
This violation will not be subject to enforcement action however,
because the licensee's effort in identifying and correcting the
violation meet the criteria specified in Section VII.B of the
This is identified as a non-cited violation, NCV:
94-03-01,
Failure To Make Timely NRC Notification Of Licensed Operator
Termination And Failure To Respond To A Notice Of Violation Within
Specified Timeframe.
d.
Confirmation of Action Letter Followup Efforts
On November 18, 1993, CP&L management made the decision to
place Robinson Unit 2 in cold shutdown due to a concern with
a mis-configured core reload.
Confirmation of Action Letter
(CAL) was issued documenting the licensee's planned actions
to identify the root cause of the mis-configuration,
determine the cause of detected nuclear instrumentation
anomalies, evaluate operator performance, and assess the
status of not only Robinson's organization, but also plant
equipment, to determine if the facility was ready for
restart.
The Resident Inspection Staff, assisted by Region II
inspectors, conducted independent reviews of the licensee's
actions. The issues inspected during this report period are
detailed below.
i)
General Plan For Restart Readiness
The inspectors reviewed procedure PLP-059, Plan
For Restart Readiness And Startup and Power
Ascension, Rev. 4. The procedure delineates the
licensee's program designed to complete a self
assessment for readiness to safely startup and
operate Robinson Nuclear Plant following the
forced outage which began on November 17, 1993.
Completion of this self-assessment is based upon
verification of the successful completion of the
"Startup Required Actions", specified in the NRC
Confirmation Action Letter dated November 19,
1993, as well as a review of system readiness,
organizational readiness, operational readiness
and verification of core configuration.
The Plant Manager was responsible for determining whether
improvement items identified during these reviews were
required to be completed before unit startup or long term
issues. The review of Systems Readiness augmented the
requirements of procedure PLP-027, System Startup Readiness
5
Determination, to include affirmations by the responsible
Systems Engineers that their respective systems were ready
to support safe, reliable operation. The affirmations were
based on reviews of system conditions that may have changed
since completion of PLP-027 reviews following Refueling
Outage 15, completion of "Startup Required Actions" and
verification that required activities are included in the
Startup And Power Ascension Schedule.
The review of Organizational Readiness performed
by each Unit Manager and the Plant Manager,
required each Unit Manager to affirm that their
organizations and personnel were prepared to
support plant operation and to demonstrate this
preparation to the Site Vice President.
Finally, the review of Operational Readiness was performed
to ensure each shift supervisor and operating crew were
satisfied with the plant material condition and were
prepared to operate the plant safely. A collective
evaluation was performed which led to the Plant Manager's
recommendation to the Vice President that plant heatup
activities commence.
ii) Action Item: Barriers To Prevent Repeating Industry
Events
The licensee addressed this issue with both long and short
term corrective actions.
The short term actions were listed
as Corrective Action #5 in the Nuclear Instrumentation
Incident Evaluation Team's (NIIET), Recommended Corrective
-Actions Prior to Restart memo to C.R. Dietz dated
November 24, 1993. The team recommended that Operations
Management ensure that Operations personnel do not develop
tunnel vision by concentrating only on Reactivity
Management. It was recommended that Operations Management
revisit the March 24, 1993, letter from Kenneth Strahm to
R.-A. Watson of CP&L which highlights the need to maintain
control of key primary plant parameters. The inspectors
reviewed the March 24, 1993, Strahm letter which contains
descriptions of six events which occurred during the
previous 12 months.
Each of the events related to operator
inattention during restart.
The inspectors also reviewed the December 18, 1993, memo
from the Acting Operations Manager to the Operations Staff
listing his expectations. The listed expectations appeared
to be adequate, addressing all aspects of the operators'
duties and responsibilities.
In addition, the inspectors reviewed the Pearson to Dietz
January 6, 1994, memo which documents the close out of
6
Corrective Action No. 5. The inspectors also reviewed the
January 7, 1994, memo (RAP/94-0060) from the Plant Manager
to Operation shift crew members which documents his
discussions with them.
Long term corrective actions were listed as Corrective
Action No. 14 for ACR 93-284. The corrective actions
include the following:
.
Communicate the importance of
incorporating industry operating
experience to enhance the equipment and
personnel performance at Robinson.
.
Use the power range NI indication event as a
case study to reinforce the importance of
barriers in the event and compare with the
operating experience from a similar 1989 event
at HNP, in series of employee information
meetings for all site employees.
Have one or more of the Investigation Team
members participate in the employee
meeting presentations.
Emphasize, during these employee meeting
presentations, the expectation that
managers and employees should consider how
lessons learned from industry experience
can be most beneficial or can be related
to experience at Robinson.
C. R. Dietz documented the closure of this item in his
January 21, 1994, memo to W. Dorman, Corrective Action
Program Manager. The licensee has assembled a notebook of
Operating Experiences for Plant Startup and plans to have
the onshift crews review it and have related discussions
prior to commencing selected major evolutions.
The inspectors concluded from their review and discussions
with licensee personnel that the licensee has completed both
the long and short term corrective actions.
iii)
Action Item: Independent System Walkdowns
Between January 4 and January 11, 1994, the inspectors
conducted detailed walkdowns of portions of the AFW, SI, and
A EDG systems. They were performed as an independent review
of the material condition of the systems as well as a check
on the thoroughness of the system engineer/SRO walkdowns
conducted as part of the PLP 27/59 process.
7
During the walkdowns, the inspectors observed a number of
deficiencies on each of the systems which had not been
detected by the system engineer/SRO walkdowns. The
deficiencies were identified to the system engineers for
disposition. Although the deficiencies were minor and did
not impact the operability of the systems, the number and
ease of discovery of the deficiencies, concerned the
inspectors about the thoroughness of the remainder of the
PLP 27/59 walkdowns. During discussions with licensee
management about these concerns, the inspectors became aware
of two factors that may have contributed to the lack of
walkdown thoroughness observed by the inspectors. One
factor was that plant management's initial expectations for
the performance of the walkdowns were not adequately
communicated to site personnel.
This was recognized by
management during the walkdown process and further guidance
was provided. Additionally, all Engineering Tech Support
Management was not uniformly performing verifications of the
walkdowns.
Following the discussions between licensee
management and the inspectors on this point, Engineering
Technical Support Management performed a series of intensive
verifications of the plant walkdowns. The inspectors were
informed that these walkdowns revealed additional
deficiencies, none of which however, impacted system
operability.
Overall, the inspectors concluded that the system walkdowns
were an enhancement in the licensee's system readiness
evaluation process. Although the walkdowns were sufficient
to determine system operability, they lacked the
thoroughness to identify all readily apparent system
deficiencies. Weak management oversight contributed to this
deficiency.
During the walkdowns, the inspectors noted that a number of
limit switch cover bolts were missing for actuators on the
following valves:
SI-866A (1 bolt missing); SI-867A (1 bolt
missing); and SI-867B (2 bolts missing).
The inspectors
questioned the impact of these missing cover bolts on the EQ
qualification of these motor operated valves. The
inspectors were provided documentation by the licensee that
demonstrated that the missing cover bolts did not impact
valve operability. The inspection also reviewed completed
maintenance work requests on these valves during RFO-15.
The packages required that the limit switch covers be
installed following maintenance. These observations were
discussed with the cognizant supervisor and the maintenance
manager. The inspectors were informed that based on these
observations, the licensee was in the process of conducting
a walkdown of readily accessible MOVS. Approximately 25
percent of the accessible MOV population was subsequently
- 0
8
inspected and only one other case of a missing cover bolt
had been detected.
During the EDG A walkdown, the inspectors observed that the
EDG A configuration did not match the controlled drawings.
Similarly drawing/system configuration errors were observed
during the AFW system walkdown. While none of the
deficiencies were significant, each was easily recognizable
by comparing the drawing to the system. While following up
on this deficiency the inspectors were informed by plant
management that it was not an explicit expectation that
drawing be used during the system engineer/SRO walkdowns.
The inspectors were also informed that the EDG A walkdown
was "preliminary" and that the PLP 27/59 for this system was
being held in abeyance pending the results of
troubleshooting on the EDG B.
During the SI system walkdown, the inspectors observed that
no flow existed through the "C" SI pump thrust bearing
cooler. Though the pumps were not required in the existing
plant configuration, SW flow had existed through the cooler
earlier that day. The inspectors were informed by the
system engineer and Operations Manager that the SW flow had
been throttled to prevent overflowing SW drains. The
inspectors were also informed that fluctuations in the SW
system pressure due to service water booster pump testing
was responsible for this observed change in SW flow.
iv) Action Item: Improve Shift Turnover Briefings
The inspectors reviewed revisions to Procedure OMM
008, Minimum Equipment List and Shift Relief, to
determine if the revisions provided additional
guidance to ensure sufficient information is turned
over for a proper relief. The inspectors reviewed
document change form 93-P-2301 and its accompanying 10
CFR 50.59 determination for revision 71 of the
procedure. The inspectors noted that procedure OMM
008 had been revised to add new shift relief
responsibilities for the Work Control-Center Senior
Control Operator (Section 5.1.5) and additional
turnover checklist for the offgoing Work Control
Center Senior Control Operator, Auxiliary Operators,
Fire Protection Technical Aide, and Makeup Water
Treatment Auxiliary Operator (sections 5.1.5, 5.1.7,
and 5.1.9)
The inspectors concluded that procedure OMM-008 had
been enhanced and that the additional attachments will
improve shift turnovers for several positions in the
control room.
09
v)
Action Item:
Expectations For Pre-job Briefings
The inspectors reviewed the licensee's restart
closeout package 02-13 which included Document Change
Form 93-P-2033 with a 10 CFR 50.59 determination for
revision 41 of procedure GP-003, Normal Plant Startup
From Hot Shutdown To Critical.
The inspector verified
that procedure GP-003 section 5.2, Instructions For
Taking The Reactor Critical contains instruction steps
(5.2.1, 5.2.2, and 5.2.3) to require that a Management
Designated Monitor (MDM) be assigned and given
permission to take the reactor critical. A pre-shift
briefing, SWAG/Outage Turnover meeting review and a
pre-job briefing checklist are also required to be
completed prior to taking the reactor critical.
The inspector also reviewed Document Change Form 93-P
2183 for revision 37 of Procedure GP-005, Power
Operation and the revised procedure. The inspector
verified that section 5.2, which deals with warming up
the secondary was revised to incorporate instruction
steps (5.2.1 and 5.2.2) to require MDM permission
prior to performing the evolution. A pre-shift
briefing, SWAG/Outage Turnover Meeting Review and Pre
job Briefing checklist and also required prior to
performing the evolution.
The inspector reviewed revisions to the outage
management manual and verified that a-format for shift
turnover meetings was developed and instructions were
incorporated to identify infrequently performed
evolutions and notify a MDM prior to the evolution.
Procedure PLP-037, Conduct of Infrequently Performed
Tests and Evolution Section 5.3.2 provides
requirements from the content of pre-job briefings and
management expectations for conduct of the evolutions.
A pre-Job Briefing Checklist (Attachment T.6) is
incorporated into the implementing documents and is
required to be performed prior to conducting the
evolution.
The inspectors concluded that the above changes
enhanced the guidance for the conduct of pre-job
briefings.
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, and approved procedures. The
10
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 followed.
In particular, the inspectors observed/reviewed the maintenance
activities detailed below.
WR/JO 94ABHC1
Examine A Diesel Switches/Mag Amps
For Water Damage
WR/JO 94AAMN
Remove, Inspect Air Start Check
Valves On A EDG
b.
Failure To Follow Procedure During Maintenance In Diesel
Room
The inspectors witnessed licensee activities to
resolve an electrical ground on the A EDG per WR/JO
94-ABHC1.
During the conduct of this effort, the
inspectors observed steel shot on the floor inside the
EDG control cabinet.
This observation was confirmed
by the I & C supervisor.
Additional shot was found
elsewhere in the control cubicle; in the current
transformer cubicle; in a drip pan beneath the engine
blower; and in the generator enclosure itself.
As a result of this discovery, the licensee conducted a
boroscope examination of accessible areas in the generator
enclosure and vacuumed accessible portions of the generator
housing.
Examination of the vacuum cleaner's contents
following the vacuuming of the generator enclosure and other
adjacent areas revealed approximately 35 steel shot.
The licensee determined the source of the steel shot to be
the use of a paint stripping machine in the A EDG room
during the refueling outage. The licensee stated that the
machine was only used briefly in the A EDG room in attempt
to remove paint from the floor. The inspectors learned that
the machine had also been used in the hallway in the
auxiliary building and in the charging pump room. On
January 19, 1994, the inspectors were informed that
approximately 3 steel shot were discovered in the C charging
pump motor frame, but none-were found in room's electrical
cubicles.
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 general procedures for the
control of maintenance. Maintenance Management Manual
Procedure, MMM-001, Maintenance Administration Program
1*1
requires the use of adequate debris intrusion control
measures during the performance of maintenance.
Contrary to the above, inadequate debris intrusion control
measures were used on November 15, 1993, during paint
stripping efforts on the Emergency Diesel Generator A room
floor. As a result, steel shot was introduced into
Emergency Diesel Generator A as well as its associated
generator control and current transformer cubicles. This is
identified as Violation, VIO 94-03-02: Failure To Employ
Adequate Debris Intrusion Control Measures.
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,
and test instrumentation was properly calibrated. Upon test completion,
the inspectors verified that the systems were properly returned to
service. Specifically, the inspectors witnessed/reviewed portions of
the following test activities:
B EDG Failure To Start Test
EST-048
Control Rod Drop Test (Refueling Outage)
Diesel Generators A and B
No violations or deviations were identified.
6.
Plant Support - Radiological Controls (71707)
Failure To Post A Response To A Radiological Working Condition Violation
On January 5, 1994, the inspectors observed that the licensee's response
to violation 50-261/93-26-01 and 93-26-03 had not been posted as
required by 10 CFR 19.11 (a)(4)(e). These violations involved
inadequate control .of locked high radiation area keys and improper
control of a basket containing an irradiated bolt in the spent fuel
pool.
The licensee's response was dispatched on December 29, 1993.
Hence, the Response was not posted within the 2-day timeframe specified
in 10 CFR 19.11 (a)(4)(e).
10 CFR 19.11 requires that the licensee's
response to a violation involving radiological working conditions be
posted within 2 days of dispatch.
Contrary to the above, on January 5, 1994, the licensee failed to follow
10 CFR 19.11 (a)(4)(e), in that, the response to violations 50-261
93-26-01 and 93-26-03 were not posted within two working days of
dispatch.
12
The inspectors noted that this violation was similar to NCV 92-24-03
documenting the failure to post a violation involving deficiencies
associated with contaminated vacuum cleaner servicing in July 1992.
7.
Review of Licensee Event Reports (92700)
The below listed LERs were reviewed to determine if the information
provided met NRC requirements. The determination included: adequacy of
description, verification of compliance with Technical Specifications
and regulatory requirements, corrective action taken, existence of
potential generic problems, reporting requirements satisfied, and the
relative safety significance of each event.
LER 91-002, Reactor Trip Due To Lo-Lo Steam Generator Level.
LER 92-002, Failure To Test All Circuitry Associated With Auxiliary
Feedwater Auto Start.
LER 92-015, Seismically Inoperable Service Water System Due To Corroded
Piping.
LER-92-022 , Potential For ESF Inoperability Due To Procedure
Defect.
LER-92-001, Degraded Condition Due To Inoperability Of Containment
Isolation Valve.
The corrective actions for the above LERs have been completed and
no violations or deviations were identified. These items are
closed.
8.
Licensee Action on Previous Findings (92701, 90702) (Followup)
(Closed) IFI 93-28-05, Documentation Of Lead-Lag Controller Accuracy.
Inspection Report 93-28 documents IFI 923-28-05, regarding an
inspector request for documentation to support the lead-lag
controller accuracy used in an error analysis of the pressurizer
pressure instrumentation. The lead-lag controller accuracy used
in the analysis was one percent instead of the two percent
specified in MMM-006, Calibration Program.
On January 17, 1994, the inspectors were provided a copy of Engineering
Evaluation, EE 94-012. This evaluation reviewed sixty-six calibration
of lead/lag units. Based on this review, the engineering evaluation
concluded that assigning a one percent calibration tolerance to the
lead-lag controllers was acceptable.
Based on the information presented in the EE, the inspectors have no
further questions. This item is closed.
13
(Closed) DEV 93-33-02, Failure To Install RHR Pump Suction Pressure
Instrumentation As Committed To In Response To Generic Letter 88-17.
The licensee performed an evaluation for Modification 1011,
"Instrumentation for Mid-Loop Operation" and determined that the
monitoring of RHR pump discharge pressure would be more appropriate.
The monitoring was implemented as required during Refueling Outage 13
(Spring, 1991).
This item is closed.
(Closed) VIO-92-28-02, SI-895K Valve Open When Safety Injection System
Is In Standby Mode.
Due to personnel error, open position was indicated
in OP-202. The licensee has revised OP-202. The inspector reviewed the
latest revision of OP-202, Revision 32, and found the position of SI
895K to be in the correct position of CLOSED. In addition, the
individual involved has been counseled. This item is closed.
(Closed) VIO-92-31-01, The Contaminated Process Equipment Area (CPEA)
Posting For The Charging Pump Room Entrance Door Was Removed. The
corrective action includes revising The Lesson Plans For Contracted
Health Physics Technicians to emphasize that, although CPEA designation
is not standard to the industry, it is used at HB Robinson as part of
the Contamination Control Program. This item is closed.
(Closed) VIO 92-02-01, Failure to Follow The Procedure When Stroke
Timing The Primary Sampling System Containment Isolation Valve. The
inspector reviewed OST-701, Inservice Inspection Valve Test,
Revision 26, the latest revision.
Changes have been made to reflect
the current testing method. In addition, Valve Data Sheet in OST-701
has been revised to eliminate any inconsistencies discovered between the
test data sheet and the test acceptance criteria. This item is closed.
9.
Exit Interview (71701)
The inspection scope and findings were summarized on January 28, 1994,
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.
Item Number
Description/Reference Paragraph
NCV 94-03-01
Failure To Make Timely Notifications To
The NRC Relative To Operator Termination
And Response To A Violation
VIO 94-03-02
Failure To Employ Adequate Debris
Intrusion Control Measures
VIO 94-03-03
Failure To Post Response To Radiological
Working Conditions Violation
(III
14
10.
List of Acronyms and Initialisms
ACR
Adverse Condition Report
Component Cooling Water
CFR
Code of Federal Regulation
CPEA
Contaminated Process Equipment Area
DEV
Deviation
Diesel Generator
Evaporative Air Conditioner
EE
Engineering Evaluation
Engineered Safety Features
General Procedure
Harris Nuclear Plant
Institute of Nuclear Power Operations
LER
Licensee Event Report
Motor Driven Auxiliary Feedwater
Maintenance Surveillance Test
Non-cited Violation
NI
Nuclear Instrumentation
OMM
Operations Management Manual
OP
Operating Procedure
OST
Operations Surveillance Test
Pressure Indicator
PLP
Plant Program
Robinson Nuclear Project
Safety Injection
TS
Technical Specification
Unresolved Item
Violation