ML14178A499
| ML14178A499 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/15/1994 |
| From: | Christensen H, William Orders NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A495 | List: |
| References | |
| 50-261-94-08, 50-261-94-8, NUDOCS 9405230019 | |
| Download: ML14178A499 (18) | |
See also: IR 05000261/1994008
Text
61k REGo/
UNITED STATES
0 oNUCLEAR
REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
Report No.:
50-261/94-08
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:, February 26 - March 26, 1994
Lead Inspector:
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W T. Orders, S hior)Resident Inspector
Date Signed
Accompanying Inspectors:
C. R. Ogle, Resident Inspector
R. C. Haag, Senior Resident Inspector - Summer
P. C. Hopkins, Resident Inspector - Catawba
J. L. Starefos, Project Engineer
M. T. Widmann, Project Engineer
Accompanying Personnel:
E. Carpenter, Project Engineer, NRR
B. Mozafari, Project Manager, NRR
Approved by:
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H. 0. Christensen, Acting Chief
Dite 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, plant safety review committee
activities, and followup.
Results:
One violation was identified involving the licensee's failure to follow
procedure when terminating CV purge, paragraph 3.
9405230019 940415
ADOCK 05000261
a
2
A second violation with two examples was identified involving the licensee's
failure to take adequate corrective actions pertaining to entry into a high
radiation area without a survey meter, paragraph 3, and inadequate corrective
action pertaining to diesel engine maintenance, paragraph 5.
A non-cited violation was identified involving deficiencies in calibration and
issue of mechanical test equipment, paragraph 5.
REPORT DETAILS
1.
Persons Contacted
R. Barnett, Manager, Projects Management
S. Billings, Technical Aide, Regulatory Compliance
- A. Carley, Manager, Site Communications
B. Clark, Manager, Maintenance
T. Cleary, Manager, Technical Support
D. Crook, Senior Specialist, Regulatory Compliance
J. Eaddy, Manager, Environmental and Radiation Support
- D. Gudger, Specialist, Regulatory Affairs
S. Farmer, Manager, Engineering Programs, Technical Support
- J. Harrison, Manager, E&RC Technical Support
B. Harward, Manager, Engineering Site Support, Nuclear Engineering
Department
- S. Hinnant, Vice President, Robinson Nuclear Project
- K. Jury, Manager, Licensing, Regulatory Programs
J. Kozyra, Acting Manager, Licensing/Regulatory Programs
- R. Krich, Manager, Regulatory Affairs
A. McCauley, Manager, Electrical Systems, Technical Support
R. Moore, Acting Operations Manager
A. Padgett, Manager, Environmental and Radiation Control
- M. Pearson, Plant General Manager
M. Scott, Manager, Reactor Systems, Technical Support
E. Shoemaker, Manager, Mechanical Systems, Technical Support
D. Winters, Shift Supervisor, Operations
L. Woods, Manager, Technical Support
- Attended exit interview.
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 in cold shutdown. The licensee
was forced to shut the unit down on February 18, 1994, when the
scavenging air blower on the B EDG failed during a post
maintenance test. The unit remained shut down until March 20,
1994 while the licensee completed repairs on the B EDG, and
retrieved a loose part which had been detected in the C S/G. The
unit was made critical at 7:42 p.m. on March 20, and was placed on
line at 11:55 p.m. on the following day. The report period ended
with the plant stable at 90% power in preparation for reactor
physics testing.
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 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 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.
Mid-Loop Operation
The inspectors reviewed the licensee's preparations for RCS
draindown and subsequent mid-loop operation to support an eddy
current inspection of the C SG. Eddy current inspection was
implemented following the discovery of 2 loose parts on the
generator secondary side and is discussed in Inspection Report
94-10. The inspectors also attended the PLP-37, Conduct Of
Infrequently Performed Tests Or Evolutions, brief for the first
crew involved in the draindown; verified the calibration of
selected instruments used for the draindown; and witnessed a
portion of the operator training provided for the evolution.
Additionally, the inspectors were in attendance for key portions
of the draindown commencing on March 3, 1994. The inspectors were
also present for the termination of the draindown at approximately
-66 inches below the vessel flange on March 4, 1994.
3
Overall, the inspectors concluded that the licensee's preparations
and subsequent control of the inventory reduction were good.
Particular strengths were noted in control room communications;
awareness of RCS water level and deviations between redundant
instruments; and control of maintenance which could impact the
plant or distract watchstanders.
On March 5, 1994, with the RCS in mid-loop, a noise was detected
by the licensee coming from the operating RHR pump. The noise was
depicted in the shift supervisor's log as an unusual noise perhaps
like gas in solution. RHR system flows, pump discharge pressures,
vibration readings, and RHR motor currents were all evaluated as
normal by the licensee. The licensee concluded that the condition
was probably moderate but acceptable vortexing or flow
oscillations in the system. The licensee stated that contact with
the pump vendor revealed that the noise was not an immediate
concern but could lead to increased seal leakage if extended
operation with the noise was conducted.
The inspectors entered the RHR pit to monitor the noise firsthand.
The inspectors heard a low frequency rumbling noise coming from
the suction of the pump. The noise was cyclic in nature and
occurred approximately every 10-15 seconds. No vibrations or
movement of the A RHR pump-or its associated piping was observed
by the inspectors coincident with the noise. Based on these
observations and the licensee's evaluation, the inspectors have no
further questions on this noise.
While in the RHR pit, the inspectors noted several minor material
deficiencies such as duct tape on the B RHR motor junction box and
missing air intake screens for A RHR motor. These were identified
to the licensee for resolution.
On March 8, 1994, while reviewing GP-008, Draining the Reactor
Coolant System, the inspectors noted that the procedure as
written, deviated from the licensee's commitment to Generic Letter 88-17. Section 5.5 of the procedure required that 4 core exit
thermocouples from ICCM "A" or 4 core exit thermocouples from ICCM
"B" be operable with the RCS less than -36 inches. The licensee's
response to Generic Letter 88-17 stated that 8 core exit
thermocouples, 4 per train, would be available for this evolution.
This discrepancy was identified to the licensee.
On March 9, 1994, the inspectors noted that GP-008 had been
revised to reflect that 4 core exit thermocouples from each train
were required. The inspectors reviewed the shift supervisor's log
for the draindown and noted that the licensee did not take
advantage of the procedural authorization to reduce the
temperature monitoring to 4 thermocouples. Both trains of
thermocouples remained operable for the evolution. Therefore, the
licensee did not deviate from their commitment to the NRC during
this particular evolution. The inspectors did not review
4
documentation for any prior entries into mid-loop to see if the
same was true due to the infrequent performance of this evolution
and the difficulty in recovering information related to
thermocouple operability. However, a review of previous revisions
to GP-008 by the inspectors revealed that this procedural
capability to reduce the thermocouples required was carried
forward from the revision which originally incorporated the GL 88-17 guidance.
On March 10, 1994, the licensee filled the RCS in accordance with
GP-008, Draining the Reactor Coolant System and GP-001, Fill and
Vent of the Reactor Coolant System, thereby, exiting the mid-loop
and reduced inventory conditions. The inspectors witnessed the
increase in RCS inventory from -6 inches to the indicating range
of the pressurizer. The evolution was adequately controlled. The
inspectors have no further questions on this evolution.
c.
Incorrect Radiation Monitor Setpoints
On March 14, 1994, E&RC technician sampling the plant vent,
recognized that an incorrect setpoint was entered in R-14C, Plant
Stack, Noble Gas Radiation Monitor. Following discussions with
control room personnel, the setpoints of R-14C as well as R-11 and
R-12, CV Air Or Plant Stack Particulate Radiation Monitor and CV
Air Or Plant Stack Noble Gas Radiation Monitor respectively, were
restored to the proper values.
Subsequent licensee investigation revealed that the incorrect
setpoints occurred while securing a continuous CV purge earlier
that day. As required by step 8.1.2.12 of Operating Procedure,
OP-921, Containment Air Handling, adjustments to the radiation
monitor setpoints were made when the purge was terminated.
However, the setpoints were incorrectly taken from release permit
GRW 94-050. This release permit had expired two weeks earlier on
February 26, 1994. However, at the time the continuous CV purge
was secured, the control room copy of this permit had not been
administratively closed out nor had it been purged from the RO's
desk. Thus, it incorrectly remained in the active release folder
and was available for use by the operator. The licensee's
investigation concluded that only R-14C was set non
conservatively. It further concluded that due to inherent safety
margins associated with the instrument setpoint calculations, at
"..no time was a setpoint used that would not have caused an alarm
if a 10 CFR 20 concentration [had] been exceeded."
The inspectors reviewed the licensees ACR evaluation generated in
response to this event. Additionally, the inspectors reviewed OP 921 and key release forms associated with the incident. The
inspectors also interviewed the reactor operator who used the
incorrect release form.
5
Overall, the inspectors concluded that the reactor operator failed
to follow OP-921 when securing the continuous CV purge. As a
result, an expired release permit was used to set three radiation
monitor setpoints. 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 operation of the reactor
building ventilation and gaseous effluent monitoring systems.
Operating Procedure, OP-921, Containment Air Handling, requires
that radiation monitor setpoints be properly established following
the termination of a continuous containment vessel purge.
Contrary to the above, three radiation monitor setpoints were
improperly established following the termination of a continuous
containment vessel purge on March 14, 1994. As a result, a non
conservative setpoint existed for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on
radiation monitor R-14C, Plant Stack, Noble Gas Radiation Monitor.
This is identified as a violation, VIO: 94-08-01, Failure to
Follow Procedure When Terminating CV Purge.
d.
High Radiation Area Entry Without Survey Meter
On March 17, 1994, four individuals entered the non-regenerative
heat exchanger room, a posted high radiation area without a survey
meter as required by TS 6.13.1.A.
This was discovered when a licensee chemistry instructor observed
the individuals in the area without a survey meter. The three
contractors and one NED engineer had entered the non-regenerative
heat exchanger room as part of a modification walkdown of the
auxiliary building ventilation system. In response to this event,
the licensee denied RCA access to the individuals involved,
generated an ACR, and subsequently modified the controls of HRAs.
This included locking HRA doors where possible and increased
-postings and warning signs.
The inspectors reviewed the licensee's ACR generated for the
event, interviewed the licensee engineer and lead contractor
involved, and interviewed the cognizant E&RC manager involved.
The inspectors also reviewed written statement obtained from
individuals involved in the entry.
-- Overall, the inspectors concluded that the individuals entered the
room, despite the posting, as a result of a non-cognitive error on
the part of the individuals conducting the walkdown. As described
by one of the individuals involved, the walkdown team was so
engrossed with following the ventilation system that they did not
observe the high rad area posting at the door.
The inspectors noted that this occurrence was similar to a
November 1, 1993, event in which two mechanics entered the
6
mechanical penetration area, a high radiation area, without a
survey meter. Though an ACR was generated, the corrective
actions identified failed to prevent this occurrence.
10 CFR 50, Appendix B, Criterion XVI, requires that corrective
actions be taken to preclude repetition of conditions adverse to
quality.
Contrary to the above, the licensee failed to take adequate
corrective action to a November 1, 1993, entry into a high
radiation area by two maintenance technicians without a survey
meter in that a similar event occurred on March 17, 1994. This is
one of two examples which in the aggregate constitute Violation
94-08-02, Inadequate Corrective Action To Preclude Repetitive
Entry Into A High Radiation Area Without A Survey Meter, And
Inadequate Corrective Action To Preclude Recurring Diesel Engine
Failure.
Two violations were identified in this area.
4.
Followup of NOUE - RCS Leakage Greater Than 10 GPM (93702)
At 5:15 a.m. on March 18, 1994, a NOUE was declared, in accordance with
EAL-2 flowchart criteria, for RCS leakage greater than 10 gpm. The leak
had been recognized at approximately 2:15 a.m. earlier that morning
while in the process of removing the RHR system from service and
restoring it to a normal standby injection mode. The leak was
terminated at approximately 2:45 a.m. when the RHR to letdown line
valve, HCV-142 was isolated. A subsequent leak rate calculation at 4:08
a.m. in accordance with OST-051 established that the post-leak leakage
rate was 0.36 gpm. The NOUE was terminated at 5:39 a.m..
The inspectors were notified of the event from a phone call by the shift
supervisor at 5:43 a.m. and via the licensee's beeper notification
system at approximately 5:50 a.m..
The inspectors reported to the site
and monitored the licensee's post-leak activities from approximately
7:15 a.m. to 9:00 a.m..
In response to the event, the licensee formed an incident investigation
team to review the event. The team's report (Final, Rev 1) identified
the leakpath as from the CVCS to RHR system through HCV-142, and then
through the RHR system minimum flow recirculation line and RWST to RHR
valves to the RWST. The report established that the leak occurred as a
result of seat leakage past HCV-142, RHR to letdown line valve, and
commenced when the RWST to RHR valves, SI-862 A & B, were opened at
approximately 1:17 a.m..
The report stated that the leak rate was
between 14 and 22 gpm and leakage was stopped when the leaking HCV-142
was isolated. The report also identified that the seat leakage of HCV
142 was a known, documented material deficiency, the repairs to which
had been deferred.
7
In response to this event, the inspectors reviewed the incident review
team's (Final, Rev 1) report as well as selected ERFIS data used in its
preparation. The inspectors also reviewed log entries for the event and
interviewed key individuals involved.
Based on this inspection effort, the inspectors concurred with the
review team's identification of the leak path and start time. The
inspectors independently calculated an RCS leak rate of approximately 12
gpm and hence, concluded that the licensee's NOUE declaration was
appropriate. However, the inspectors were troubled by the delay which
occurred between the recognition of the leak by the on-shift operators
and the NOUE declaration. According to log entries, the operators
become concerned about the potential for an RCS leak at approximately
2:15 a.m. based on excessive makeups. Log entries and operator
interviews revealed that the licensee continued to pursue these
indications and by about 2:45 a.m. had identified and isolated the
leaking HCV-142. However, the NOUE declaration was delayed until 5:15
a.m.; approximately 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the leak was terminated. The
inspectors interviewed key individuals involved in the decision making
process for the NOUE declaration to better understand the basis for this
delay.
From these interviews, the inspectors determined that the operating crew
was unable to accurately establish whether the RCS leak rate exceeded
the 10 gpm threshold for the NOUE. This was attributed to inconclusive
data gathered on plant parameters even after the leak was isolated. The
shift supervisor indicated to the inspectors that he was aware of the
leak and understood the 10 gpm NOUE threshold. However, he indicated a
strong desire to determine the leak rate accurately prior to declaring
the NOUE. Faced with this situation, and after consultation with
management, the shift supervisor requested the STA manager come to the
site to assist in the leak rate determination. After this decision was
made, the onsite NAD manager contacted the Plant General Manager and
informed him of the onshift control room NAD observer's estimate of RCS
leakage in excess of the NOUE threshold. At 5:15 a.m., after additional
consultation with the plant general manager, the shift supervisor
declared the NOUE.
The inspectors reviewed data available to the operators to assist in the
determination of the leak rate. Eleven, near continuous makeups of
approximately 75 gallons each occurred between about 1:50 a.m. and 2:45
a.m..
These makeups occurred despite no net change in pressurizer level
and a 6 inch decrease in VCT level.
The change in RCS temperature
during these makeups was about 0.6F. While the RHR system was being
cooled down and realigned during a portion of this interval, the
inspectors noted that the vast majority of this cooldown was complete by
2:15 a.m.. While RHR contraction may have added to the apparent RCS leak
rate, the inspectors noted that VCT level continued to decrease even
after the RHR system cooldown was completed.
Based upon this information the inspectors concluded that the operating
shift had sufficient information available to allow a more timely NOUE
8
declaration. The failure of the operating crew to properly determine
the leak rate in an expeditious fashion is considered a weakness.
After additional investigation, and after the end of the inspection
period, the licensee issued a supplement to the incident review team's
report. This supplement primarily examined issues regarding the
timeliness of the declaration of the NOUE. It concluded that the shift
supervisor had sufficient information to declare the event prior to the
termination of the leak. Furthermore, the supplement stated that 3
supervisory/oversight personnel external to the crew, but present in the
control room, all recommended a more timely NOUE declaration. It also
revised the report's leak rate estimate to 10.8 gpm. The inspectors
reviewed the supplemental report and have no further questions on this
event.
During their review of the ERFIS data the inspectors noted that the VCT
level control system was terminating makeup prematurely. This was
identified to the licensee for resolution.
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 detailed below:
WR/JO 94-AERJI
Troubleshoot the Speed Sensing Switch For
LSR/EER Contact On A EDG
WR/JO 94-ADXZ6
Steam Generator C Manway Installation
WR/JO 94-AEMW1
Check Closing Time On RHR Pump A Breaker
WR/JO 94-AERK1
Calibration Of EDG A Cylinder Number
8 Thermocouple
WR/JO 94-AEQZ1
Camera Inspection Of EDG A Cylinder Number
8
a.
Inadequate Corrective Actions To Repair EDG "B"
On Saturday, February 12, 1994, the licensee formed a team to
investigate problems that caused the EDG "B" to fail to start
during a routine surveillance test.
9
On February 17, a mechanic identified that the pin on the
counterweight side of the air flapper valve was missing.
Replacing the valve internals was evaluated but it was determined
that replacement parts for the valve were not in stock.
The pin was subsequently found wedged between the valve body and
the diffuser plate below the flapper valve. It was visually
inspected and evaluated as being in good shape.
The team members discussed several repair options:
Replacing the pin with a new one.
This was ruled out because there was not a replacement pin
in stock.
Performing a test to determine if the pin could be tack
welded or duplicated.
This was ruled out because the valve was made of aluminum
and could not be welded; and there was not enough time to
duplicate the pin and meet the time requirements of the TS
action statement.
.
Replacing the pin with a bolt.
This was ruled out because the drawing for the diesel
indicated a pin was used in the original design. To replace
the pin with a bolt would require a Engineering Evaluation
(EE) and the team did not believe this could be accomplished
within the remaining TS action statement time.
Reusing the old pin and staking the flapper valve.
This option was chosen. Maintenance was to put 4 indentions
in the end of the pin to increase the "interference" fit.
At approximately 9:45 a.m. that morning a mechanic reinstalled
the pin and made two stakes on the flapper using a hammer and
center punch. The mechanic was concerned about making any
additional stakes believing it would weaken the metal.
The
opposite end of the pin was not staked.
At approximately 10:00 a.m., the installation of the pin was
complete. Upon completion of the job, the mechanical maintenance
foreman inspected the job and indicated that he felt the staking
was adequate to hold the pin in place.
Several members of the team and management visually inspected the
repair and found no problem. Permission to reassemble the valve
90
was given.
10
At approximately 1:13 p.m. that afternoon, the diesel was started
and loaded to 2500 kw and ran for an hour without incident. At
approximately 3:00 p.m. a fast speed start was performed. The EDG
was secured at 5:07 p.m..
At 6:10 p.m. a PNSC meeting convened to discuss the "B" EDG
problems and repair efforts. The PNSC discussed the fact that the
pin had been replaced and that slow and fast speed starts had been
completed. The resident inspectors brought to the PNSC's
attention that neither of the starts had been conducted at normal
standby system conditions. The PNSC agreed to that a cold start
at ambient condition should be successfully completed prior to
At 11:56 p.m. that evening, the licensee started the EDG per OST
409. The engine start was considered normal.
At 12:01 a.m., the
output breaker was closed and engine was loaded to 11 kw. A few
minutes later, a clanging noise was heard in the blower inlet
piping immediately followed by a loud noise in the scavenging air
blower. The operator shutdown the engine.
Subsequent maintenance activities located the aforementioned air
flapper valve pin. It had fallen out of the valve, had been
ingested by the scavenging air blower, and had inflicted
catastrophic damage to both the blower and both turbochargers.
The air flapper valve failure demonstrates inadequate corrective
actions taken in response to a malfunction.
10 CFR 50 Appendix B, Criterion XVI, Corrective Action, requires
in part that measures be established to assure that conditions
adverse to quality, such as failures, malfunctions, defective
material and equipment, are promptly identified and corrected
including the measures to assure that the cause of the condition
is determined and corrective action taken to preclude repetition.
Contrary to the above, on February 17, 1994, the licensee's
corrective actions to repair the B EDG air flapper valve was
inadequate to assure that the cause of the condition was
determined and preclude recurrence in that the valve pin was
improperly secured, a fact which led to extensive engine damage.
This is one of two examples which in the aggregate constitute
Violation 94-08-02, Inadequate Corrective Action To Preclude
Repetitive Entry Into A High Radiation Area Without A Survey
Meter, And Inadequate Corrective Action To Preclude Recurring
Diesel Engine Failure.
b.
Primary Manway Installation
On the evening of March 9 and early morning of March 10, 1994, the
inspectors witnessed the installation of the hot and cold leg
primary manways on steam generator C. This was accomplished in
11
accordance with CM-206, Removal And Reinstallation of the Steam
Generator Primary Manway Covers.
Overall, the conduct of this maintenance evolution was
satisfactory. Noteworthy was the strong performance on the part
of the mechanical maintenance technicians assigned to this effort.
Despite the fact that manway installations are typically performed
by contractor personnel at H. B. Robinson, the work was
accomplished smoothly in the high dose, confined work area of the
steam generator platform.
However, the inspectors did note several items which may have
distracted from the smoothest possible performance of the task.
These included a cluttered laydown area immediately adjacent to
the crane wall; ineffective communications headsets; and a 400
mR/hr hot spot on the manway insert shielded container which went
undetected until well into the evolution. The inspectors also
noted a minor inconsistency in the manway stud installation
technique between the two manways. The hot leg team used speed
wrenches to install them, the cold leg team performed the same
activity by hand. The speed wrenches allowed for quicker stud
installation in the high dose environment. While none of these
items rose to the level of a safety concern, they were discussed
with the cognizant management personnel.
The inspectors have no
further questions on this activity.
No violations or deviations were identified. Based on the
information obtained during the inspection, the area/program was
adequately implemented.
c.
Deficiencies In Calibration And Issue Of Mechanical Test Equipment
On March 10, 1994, the licensee's Nuclear Assessment Department
(NAD) discovered significant deficiencies in the calibration and
issue of mechanical test equipment (M&TE). Specifically, these
deficiencies were:
1)
Calibration standard were being incorrectly utilized
resulting in the issuance of non-calibrated torque
wrenches.
2)
Qualification of personnel calibrating and issuing torque
wrenches was determined to be unsatisfactory. This was
evidenced by improper calibration techniques as well as a
lack of documentation certifying personnel qualification.
The calibration, control, and issue of M&TE at RNP is the
responsibility of Materials and Contract Services (M&CS).
At approximately 6:00 p.m. on March 10, 1994, NAD issued a "Stop
Work" order, suspending the issuance of M&TE. Parameters for
rescinding the "Stop Work" order were specified as follows:
12
1)
Personnel calibrating and issuing torque wrenches were
to be appropriately qualified.
2)
Short term compensatory measures were to be established to
provide reasonable assurance that mechanical M&TE provide
reasonable assurance that mechanical M&TE calibration and
issues were being properly conducted.
At approximately 4:00 P.M. on March 11, 1994, the Manager
Materials and Contract Services presented a letter to the Plant
Manager and the Manager of RNP, NAD, outlining compensatory
measures that had been implemented. Based on these measures, the
"Stop Work" order was rescinded.
Three primary concerns were identified - 1) inadequate
documentation relative to the training of personnel, 2) suspect
calibration capabilities of "Qualified" personnel, 3) the validity
of torque wrench calibrations prior to work stoppage.
The issue of inadequate documentation of training focused on the
inability of the NAD team to locate training records and
qualification certificates in the HBR Training Section's records.
The training records were located in the supervisors desk. In
three instances he had failed to sign the qualification sheets for
individuals and in numerous cases failed to forward the training
records to the HBR training Section as required. All of the
employees had received the required training.
The capability of the responsible personnel to accurately perform
calibrations was questioned by NAD personnel.
It was determined
that four factors tend to mitigate these concerns:
1)
Independent review of paperwork - M&TE is calibration
checked prior to issuance to the field and upon return to
the issue area. The calibration certificates are reviewed
by a third party prior to close-out. Any unresolved
discrepancies-or abnormalities are addressed at this time.
2)
Ongoing calibrations by various individuals - Typically the
pre-check of M&TE and the post-check are performed by
different individuals. Subsequent issues are likely to be
performed by different individuals still.
Any problems in
performing the calibrations would be quickly discovered due
to the ongoing process by different individuals.
3)
Rechecks of equipment using the newly implemented standards
have failed to reveal any problems with the equipment or
out-of-spec calibrated equipment.
4)
Requalification testing of individuals did not reveal any
areas of concern relative to the calibration and checking of
M&TE.
13
An overriding concern involved the validity of torque wrench
calibrations prior to the work stoppage and the consequences with
regard to plant equipment operability. A multi-disciplined team
was formed to determine the answer to this question.
The team determined that there were approximately 2200 Certificate
of Calibration sheets completed since 1991, in which improperly
certified torque wrenches (a torque wrench certified with a
transducer below 20 percent of full scale) were used in the plant.
Testing performed by a contractor lab indicated that the
transducers were actually acceptable to approximately one percent
of scale. This reduced the number to 26 calibration sheets where
torque wrenches were certified with a transducer below one percent
of scale. All 26 instances were reviewed and the licensee
concluded that the plant equipment was not affected by the
improper torque wrench calibration check.
10 CFR 50, Appendix B, Criterion XII, Control Of Measuring And
Test Equipment requires that measures be established to assure
that tools, gages, instruments, and other measuring and testing
devices used in activities affecting quality be properly
controlled, calibrated, and adjusted at specified periods to
maintain accuracy within necessary limits.
Contrary to the above, measures established were inadequate in
0
that:
1)
Calibration standards were being incorrectly utilized
resulting in the issuance of non-calibrated torque wrenches.
2)
Qualification of personnel calibrating and issuing torque
wrenches was inadequate as evidenced by improper calibration
techniques as well as a lack of documentation certifying
personnel qualification.
The failure to establish adequate M&TE control measures 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 Enforcement Policy.
This is identified as a non-cited violation, NCV: 94-08-03 Failure To
Establish Adequate M&TE Control Measures.
d.
Diesel Generator Room Cooler Operability
In report 94-04, the inspectors identified an Unresolved Item, 94
04-03, involving the evaporative air coolers which were installed
to cool the emergency diesel generator rooms.
In that report, the inspectors documented that on January 20,
1994, the service water supply to one of the coolers failed due to
14
freezing. A review of the system's design determined that the
service water piping was installed as non-Q/non-seismic. The
licensee's immediate corrective action entailed isolating service
water to the coolers.
The inspectors asked the licensee to determine if the coolers are
required diesel generator support equipment. Current design
documentation is not specific in that regard. The licensee's
initial opinion was that the coolers are not required for diesel
operability. At the end of report period 94-04, the licensee had
not completed the analysis to support their contention. Pending
completion of that analysis, the issue was carried as an
Unresolved Item, 94-04-03, Evaporative air Cooler/Diesel Support.
During the current report period, the inspectors were provided a
copy of Engineering Evaluation 94-023, Rev. 0. On page 1 of 2 of
that evaluation, the licensee states in part, that during normal
plant operation, with the diesels not operating, temperature
maintenance of the diesel rooms is provided by the reactor
auxiliary building normal ventilation system. At diesel start-up,
the diesel room cooling function is provided by the respective
diesel generator room ventilation systems. At the time of diesel
start-up, the diesel generator room ventilation system supply fan,
cooler, and the exhaust fan are required to maintain the room
below the specified design limit of 104*F on a design basis summer
day of 950F.
Contrary to the above information, the inspectors noted in
memorandum dated March 28, 1994, that "There is no evidence that
cooling beyond that provided by the room supply and exhaust fans
is required for operability. Therefore, EAC-1 & 2 coolers are not
required and are appropriately designated non-Q."
The inspectors brought the conflicting information to the
licensee's attention and requested that adequate technical
justification be supplied to support continued diesel operability.
Pending the receipt of this analysis, this issue will remain
Unresolved.
One violation and one non-cited violation were identified in this
area.
6.
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, and testing was
accomplished by qualified personnel in accordance with an approved test
procedure. Upon test completion, the inspectors verified the recorded
15
test data was complete, and 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:
Diesel Generators "A" and "B" (A EDG only)
EST-109
Auxiliary Feedwater Pumps Flow Testing
(Refueling)
No violations or deviations were identified in this area.
7.
Exit Interview (71701)
The inspection scope and findings were summarized on April 5, 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. There were no dissenting comments nor did the
licensee identify any of the materials provided to or reviewed by the
inspectors during this inspection as proprietary.
Item Number
Description/Reference Paragraph
VIO: 94-08-01
Failure to Follow Procedure When
Terminating CV Purge.(paragraph 3)
VIG: 94-08-02
Inadequate Corrective Action To Preclude
Repetitive Entry Into A High Radiation Area
Without A Survey Meter, And Inadequate
Corrective Action To Preclude Diesel
Engine Failure.
(paragraphs 3 & 5)
NCV: 94-08-03
Failure To Establish Adequate M&TE Control
Measures. (paragraph 5)
8.
List of Acronyms and Initialisms
ACR
Adverse Condition Report
E&RC
Environmental and Radiation Control
Emergency Action Level
EE
Engineering Evaluation
ERFIS
Emergency Response Facility Information System
GL
Generic Letter
General Procedure
gpm
gallons per minute
Hand Control Valve
Maintenance and Test Equipment
M&CS
Materials and Contract Services
NAD
Nuclear Assessment Department
Notice of Unusual Event
Radiation Control Area
16
Robinson Nuclear Project
Refueling Water Storage Tank
Safety Injection
Volume Control Tank
0