ML14181A785
| ML14181A785 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/17/1995 |
| From: | William Orders, Shymlock M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14181A783 | List: |
| References | |
| 50-261-95-27, NUDOCS 9512110103 | |
| Download: ML14181A785 (17) | |
See also: IR 05000261/1995027
Text
- .pR REG&
UNITED STATES
0 oNUCLEAR
REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
Report No.:
50-261/95-27
Licensee:
Carolina Power & Light Company
P. 0. Box 1551
Raleigh, NC 27602
Docket No.:
50-261
License No.:
Facility Name: H. B. Robinson Unit 2
Inspection Conducted:
September 17 - October 21, 1995
Lead Inspector:
__11-17-95
W. T. Orders,
0enior Revsident Inspector
Date Signed
Other Inspector:
J. Zeiler, Resident Inspector
Approved by:
O>L
11-17-95
Milton B. ShymocW, Chief
Date Signed
Reactor Projects Branch 4
Division of Reactor Projects
SUMMARY
SCOPE:
This routine, resident inspection was conducted in the areas of plant
operations, maintenance activities, engineering efforts, and plant support
functions. As part of this effort, backshift inspections were conducted.
RESULTS:
In the Plant Operations area, one violation was identified involving an
inadequate clearance for removing the B Emergency Diesel Generator from
service. While implementing this clearance, the engine air start piping was
depressurized through the engine's air start distributor causing the engine to
unexpectedly start and run without normal engine support equipment properly
aligned (paragraph 3.a).
9512110103 951117
ADOCK 05000261
a
REPORT DETAILS
1.
PERSONS CONTACTED
Licensee Employees:
- B. Baum, Director, Human Resources
- M. Brown, Superintendent, Design Control
- P. Cafarella, Superintendent, Mechanical Systems
- G. Castleberry, Manager, Plant Electrical Engineering
- B. Clark, Manager, Maintenance
T. Cleary, Manager, Mechanical Maintenance
- D. Crook, Senior Specialist, Licensing/Regulatory Compliance
C. Gray, Manager, Materials and Contract Services
- D. Gudger, Senior Specialist, Licensing/Regulatory Programs
- M. Herrell, Manager, Training
- C. Hinnant, Vice President, Robinson Nuclear Plant
P. Jenny, Manager, Emergency Preparedness
- J. Keenan, Director, Site Operations
- R. Krich, Manager, Regulatory Affairs
E. Martin, Manager, Document Services
- B. Meyer, Manager, Operations
- G. Miller, Manager, Robinson Engineering Support Services
- H. Moyer, Manager, Nuclear Assessment Section
B. Steele, Manager, Shift Operations
D. Stoddard, Manager, Operating Experience Assessment
R. Warden, Manager, Plant Support Nuclear Assessment Section
- D. Whitehead, Manager, Plant Support Services
- T. Wilkerson, Manager, Environmental Control
- D. Young, Plant General Manager
Other licensee employees contacted included technicians, operators,
engineers, mechanics, security force members, and office personnel.
NRC Personnel:
- W. Orders, Senior Resident Inspector
- J. Zeiler, Resident Inspector
- Attended exit interview
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2.
PLANT STATUS AND ACTIVITIES
Operating Status
The unit operated at or near full power for the entire report period.
2
3.
OPERATIONS
a.
Plant Operations (NRC Inspection Procedure 71707)
The inspectors evaluated licensee activities to determine if the
facility was being operated safely and in conformance with
regulatory requirements. These activities were assessed through
direct observation of ongoing activities, facility tours,
discussions with licensee personnel, evaluation of equipment
status, and review of facility records. The inspectors evaluated
the operating staff to determine if they were knowledgeable of
plant conditions, responded properly to alarms, and adhered to
procedures and-applicable administrative controls. Selected shift
changes were observed to determine that system status continuity
was maintained and that proper control room staffing existed.
Routine plant tours were conducted to evaluate 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.
Emergency Diesel Generator B Unexpected Start During Tagout
On September 26, while operations personnel were in the process of
implementing LCTR 95-01384 for removing the B EDG from service for
scheduled maintenance, the engine started unexpectedly. The
engine ran for approximately 7 minutes until shutdown locally by
tripping the engine fuel racks.
Prior to the start, normal engine support equipment such as pre
lube and cooling water had been isolated in accordance with the
clearance. Due to this, the licensee performed an evaluation to
ensure that no engine damage had occurred during the event. This
evaluation was conducted with assistance from the engine
manufacturer. The inspectors reviewed the results of this
evaluation and discussed details with the EDG system engineer.
The engine manufacturer identified one area of concern involving
the engine lube oil system. Since the lube oil strainer drain
valve was open when the engine started, the manufacturer indicated
that the lube oil filters could have deformed under the increased
oil system flow condition. Subsequent inspection of these filters
revealed that there was no damage; however, as a preventative
measure, they were replaced. Following the completion of
maintenance and inspection, the engine was tested successfully and
returned to service without further complications. The inspectors
determined that the licensee's evaluation and testing was
adequate, although, greater consideration should have been given
for the potential damage to the air start distributor. During the
event, air was not automatically isolated to the distributor
shortly after startup as would occur on a normal start.
Increased
wear and potential damage to the internal valves and springs in
3
the distributor can occur if air is continuously admitted to
distributor. Subsequently, the licensee evaluated in greater
detail the potential for this to occur. The results of this
evaluation determined that there was not sufficient air volume
admitted during the event to damage the distributor.
The inspectors reviewed the initial operator responses to the
event. Upon hearing the engine start, an Auxiliary Operator who
was outside the EDG room contacted the control room and was
instructed to close the manual air start isolation-valves (to
prevent any further chance of air entering the engine) and then to
shutdown the engine from the local control panel.
The Auxiliary
Operator closed the air start valves, but was unsuccessful in
shutting the engine down from the local control panel.
This
should have been expected since prior steps in the clearance had
de-energized electrical power to the control panel, thus,
disabling the normal shutdown capability. In a subsequent call to
the control room, the Auxiliary Operator was instructed to close
the fuel racks, which was successful in stopping the engine. The
inspectors determined that shutdown of the engine could have been
accomplished sooner if the control room operators had been more
familiar with details of the clearance. However, since the engine
did not experience any damage during the event, the inspectors
concluded that the extra time involved did not adversely impact
the engine during this event.
The inspectors reviewed LCTR 95-01384, the sequence of events for
the unexpected engine start, and discussed the event with the
operators involved. The clearance was developed to remove the
engine from service in order to conduct an annual inspection and
general engine work. One of these work items included the
replacement of valve, DA18B, located in the engine's air start
system piping. DA18B is the upstream manual isolation valve to
one of the two parallel air start solenoid valves (DA19B) that
open on an engine start signal and allow the admission of
compressed air into the air start distributor which starts the
engine. The individual preparing the clearance selected upstream
air start valves DA14B and DA28 as the isolation boundary for
DA18B. This boundary configuration allowed a 65 foot section of 2
and 2.5 inch air start piping to remain pressurized directly
upstream of the air start solenoid valve DA19B. When DA19B was
deenergized in accordance with the clearance, it failed open
allowing the residual compressed air that was contained within the
isolation boundary to be admitted into the engine's air start
distributor. The clearance preparer indicated that he understood
that deenergizing the air start solenoid valves would vent air
trapped in the air start piping through the air start distributor.
A decision was made when the clearance was being prepared that
there was not enough isolated air volume to start the engine. The
inspectors noted that this decision was not based on a clear
understanding of the actual length of piping or volume involved
and a walkdown of the piping had not been performed.
4
The inspectors also reviewed procedure OMM-05, Clearance and Test
Request, which provides the requirements for properly isolating
equipment that is being removed from service. Section 5.1 of this
procedure requires that systems which normally operate at
temperatures and pressures above ambient condition shall be vented
and drained if necessary for the work to be performed. Further,
the procedure requires that vent and drain valves used to
depressurize a system should be tagged in the open position. The
inspectors determined that this procedure was not followed, in
that, proper provisions for depressurizing the air start piping,
such as opening a high point vent valve within the isolation
boundary, or loosening an existing flange in the piping, was not
considered or utilized in the clearance.
TS 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
controlling the clearance of safety-related equipment.
Contrary to the above, LCTR 95-01384 was inadequate in that, it
did not provide adequate instructions for ensuring that the ai.r
start system piping associated with the B EDG was properly
isolated and depressurized. This issue is considered a violation
of the requirements of TS 6.5.1.1 and is identified as Violation
50-261/95-27-01:
Inadequate Clearance Results in Unexpected
Emergency Diesel Start.
During review of this event, the inspectors recalled a similar
event involving an inadequate clearance that occurred on April 17,
1995, during maintenance on valve V1-18A, steam supply valve. The
clearance boundary for this work failed to properly isolate the
steam supply to the Steam Driven Auxiliary Feedwater Pump
resulting in it inadvertently starting. This issue was one of
three examples of Violation 95-19-01, addressed in NRC Inspection
Report 50-261/9519, dated July 17, 1995. The inspectors reviewed
CR 95-00961 which addressed this event. Corrective actions
included counseling the clearance preparer and enhancing the model
clearances for future work on valve VI-18B. The inspectors noted
that this CR had been classified as "Non-Significant," therefore,
a formal root cause evaluation was not performed. The inspectors
considered the effectiveness of corrective actions for this event
to have been questionable as result of the similarity to the
clearance problems identified with the unexpected EDG start. Both
of these issues involved improper clearance assumptions. The
licensee indicated that the root cause evaluation for the EDG
start event would address the corrective action for the clearance
program.
5
Control Room Instruments Affected by Radio Usage
The inspectors noted on several occasions during routine control
room tours, that hand held radio transmissions, seemed to be
having an adverse effect on the trace of the unit electrical
output chart recorder. When the inspectors asked the operators
about these observations, they were told that indeed the radios
did have an effect on the chart recorder, but to their knowledge,
no other control room equipment seemed to experience interference
from the radios. The inspectors also identified to operations
management that a sign which had been previously posted on the
door leading from the control room to the adjoining protection
electronics equipment (Hagan) room, warning that radios were not
to used inside, had been removed. This was identified to the
operations management.
The inspectors discussed this issue with the engineering staff to
determine if there was a formal program in place to address radio
frequency interference. The licensee informed the inspectors that
there was no formal program, and initiated a condition report to
facilitate an evaluation of the problem. At the end of this
report period, the licensee's efforts to address this issue are
incomplete, and will be addressed in the next report.
Housekeeping Discrepancies with Potential Seismic Impact
During a walkdown of the Hagan Room, the inspectors noted that
electrical test equipment and furniture (e.g., chair, file
cabinet, table, and ladder) were in close proximity to the reactor
protection system cabinets. The inspectors questioned engineering
personnel whether this unsecured material had been evaluated with
regards to its potential seismic interaction with the reactor
protection cabinets. They recalled performing seismic evaluations
for the furniture in the past, but were unable to provide this
documentation. Licensee engineering personnel conducted a
walkdown of the Hagan room. Several of the unsecured items were
removed or relocated, including the electrical test equipment.
The licensee initiated CR 95-02419 to address the improper storage
of this equipment. They determined that none of the items had
been close enough to be a significant interaction threat to the
reactor protection cabinets. The inspectors agreed with this
assessment, but, concluded that general housekeeping control of
electrical test equipment could be improved in this area. Based
on these observations and discussions with I&C personnel who
perform protection system testing in the Hagan room, there was not
a good understanding of the potential seismic impact when
storing/placing equipment or material near safety-related
equipment.
The inspectors reviewed procedures AP-02, Plant Conduct of
Operations, and, AP-10, Housekeeping Instructions, which describe
the plant housekeeping requirements for controlling work
6
activities, conditions, and environments. While these procedures
require that all employees properly store loose work items, it did
not provide guidance for evaluating the seismic acceptability of
storing/locating unsecured tools/material near safety-related
equipment. The inspectors discussed these observations with plant
management and reviewed the planned corrective actions for CR 95
02419. Specific corrective actions included the following: 1)
perform plant walkdowns to identify material which may represent a
seismic concern, 2) provide instructions for evaluating the
placement of unsecured equipment around safety-related equipment,
3) establishing storage areas for unsecured equipment, and, 4)
providing training to all plant personnel on the new guidance.
The inspectors concluded that these corrective actions were
comprehensive toward heightening plant personnel and management
awareness to the adverse impact of unsecured material in areas
containing safety-related equipment.
Onsite Follow-up Of Written Reports Of Non-Routine Events
The following Licensee Event Reports were reviewed to assess the
safety significance of the issue, the corrective actions proposed
or taken by the licensee, the licensee's compliance with the
applicable reporting requirements, and the validity of the
licensee's review and evaluation of the subject of the report:
LER 93-001
TS 3.0 Implementation Due To Excessive PPS
Leakage
LER 93-004
Unusual Event Caused By Reactor Coolant
System Leakage
LER 93-005
Apparent Temperature Violation Of The
Boric Acid Storage Tank
LER 93-006
Inadequate EDG Ventilation System Due To
Bypassed Air
LER 93-007
Ventilation System Outside Design Basis
Due To Positive Pressure Condition
LER 93-007-01
Ventilation System Outside Design Basis
Due To Positive Pressure Condition
LER 93-009
TS 3.0 Entry For Service Water Pump
Operability Testing
LER 93-012
Engineered Safety Feature Actuation
LER 93-013
TS Specification 3.10.1.3 Implementation
Due To Exceeding Rod Insertion Limits
LER 93-014
Surveillance Tests Exceeded Technical
Specification Test Intervals
7
After having reviewed the licensee's corrective actions proposed
or taken, the licensee's compliance with the applicable reporting
requirements, and the validity of the licensee's review and
evaluation of the issues addressed by these reports, these LER's
are closed.
b.
Effectiveness of Licensee Control in Identifying, Resolving, and
Preventing Problems (NRC Inspection Procedure 40500)
NAS Identified Clearance Deficiencies and Resulting Site Stand
Down
On September 6, NAS personnel were witnessing work activities
associated with WR/JO 95-ADTI1 for troubleshooting degraded
service water flow through the Primary Air Compressor. During
this activity, NAS observed a maintenance individual manipulate a
valve that was incorrectly believed to be within the valve
clearance boundary established for the work. In accordance with
OMM-005, Clearance and Test Request, only operations personnel are
allowed to manipulate valves or components within clearance
boundaries. The only exception is components on which maintenance
is actually being performed. Based on these observations, NAS
determined that the maintenance personnel did not have a clear
understanding of the clearance boundaries or the requirements of
OMM-005 regarding manipulation of components within clearance
boundaries. NAS ordered the work to be stopped until the problems
were corrected. The inspectors reviewed the assessment results
performed by NAS and considered them to be an example of good
performance based assessment capability. The actions to stop work
and correct the deficiencies were representative of a good safety
focus.
On September 13, licensee management initiated a work "stand-down"
to address the clearance problems identified. The following
actions were taken associated with this stand-down:
-
all section and unit managers met with their personnel and
discussed details of the event, management expectations that
personnel verify and understand clearance boundaries prior
to beginning work, and, expectations that personnel
understand and comply with the requirements of OMM-005,
-
this event was to be included in refueling outage training
for contract personnel,
and,
-
an analysis was to performed within 60 days to determine if
additional training on other site programs was warranted.
The inspectors reviewed these actions and determined that they
were comprehensive toward preventing recurrence. The inspectors
noted that licensee management was sensitive to the seriousness of
8
the potential consequences involved with this issue and was
supportive of NAS efforts to correct the weaknesses identified.
No violations or deviations were identified. Based on the
information obtained during the inspection, the area/program was
adequately implemented.
C.
Followup - Operations (NRC Inspection Procedure 92901)
(Closed) IFI 50-261/93-21-06: Vital Battery Terminal Fractures
This IFI documented observations of deformed and cracked vital
battery terminal posts.
Both vital batteries were replaced during Refueling Outage 16.
Procedure PM-411, Disassembly, Cleaning, Assembly, And Testing Of
A and B Station Battery Cell Connections, has been revised to
incorporate appropriate torque valves.
Engineering Evaluation 93-134 was performed to verify that the B
battery was operable with the degraded terminal posts until it was
replaced. This item is closed.
(Closed) IFI 50-261/93-33-03:
Need For Verification Of CV Spray
And Turbine Auto Stop Circuitry Continuity Following Routine
Testing
This IFI documented deficiencies in routine testing of the
containment spray system and turbine auto stop circuitry. The
deficiencies were associated with continuity testing of circuitry
following routine testing.
The procedures involved, OST-351, CV Spray and MST-11, Turbine
Autostop Testing, were revised to incorporate continuity tests.
This item is closed.
(Closed) VIO 50-261/93-28-04:
Three Examples Of Inadequate Or
Failure To Follow Procedure
This violation involved the following three issues:
1.
A situation on September 13, 1993, in which the licensee
failed to follow procedure, MMM-006, Calibration Program,
for documenting an engineering evaluation or other
appropriate justification to support using a dead weight
tester for the calibration of a pressurizer pressure
transmitter;
2.
An occurrence on November 8, 1993, in which Maintenance
Procedure CM-121, Pressurizer Spray Valve Maintenance, PCV
455A/B was inadequate to facilitate maintenance on valve
9
PCV-455B in that it did not represent the valve as
installed;
3.
An incident on September 16, 1993, in which, procedure CM
704, Service Water Pump Motor Maintenance, was inadequate to
facilitate maintenance on the D service water pump in that
it provided erroneous guidance for setting the pump impeller
clearance.
The corrective steps that have been taken included the following:
1.
Plant personnel have reviewed the calibration records
associated with the dead weight testers used to calibrate
the Pressurizer pressure transmitters. They determined that
the accuracy of calibration of the transmitters exceeds the
0.25% of reading stated in MMM-006, Calibration Program.
MMM-020, Control Of Portable Measuring And Test Equipment,
will be changed to reflect an allowed accuracy of 0.06% of
reading. This will provide an accuracy of reading that
exceeds the accuracy of the pressurizer pressure
transmitters. The Pressurizer Pressure Protection
Transmitters,1[6XPT-455?T-456, and PT-457 were recalibrated.
2.
Procedure CM-121, Pressurizer Spray Valve Maintenance, PCV
455A/B, has been revised to require verification of match
marks prior to proceeding with valve disassembly and
reassembly during maintenance. Also, the procedure now
reflects the "as installed" orientation of the actuator on
the valve body.
3.
A revision to CM-704, Service Water Pump Motor Maintenance,
has been completed to correct the deficiencies noted
pertaining, in part, with impeller clearance.
This item is closed.
(Closed) VIO 50-261/93-11-01:
Failure to Make a Timely
Notification to the NRC of a Notification to State Authorities
This issue involved the licensee's failure to make a timely 4-hour
non-emergency notification to the NRC after contacting the State
of South Carolina regarding an NPDES permit limit violation. In
accordance with 10 CFR 50.72(b)(2)(vi), notifications to other
government agencies, regarding among other topics, protection of
the environment, require a 4-hour non-emergency NRC notification.
to be made.
The licensee responded to this violation by letter dated August 2,
1993.
The root cause was attributed to the failure to understand
the specific reporting requirements of 10 CFR 50.72(b)(2)(vi).
Licensee personnel had historically interpreted this criteria to
apply to the communications involving offsite radiological
10
releases or plant deaths. The inspectors reviewed procedure AP
30, NRC Reporting Requirements. The procedure was revised to
include clarification of the NRC reporting requirements. Specific
plant examples were provided for each of the notification
requirement categories. One of the examples added to the 4-hour
notification category included notifications made as a result of
exceeding NPDES permit requirements. In addition, formal training
was provided for operations and regulatory affairs personnel on
the lessons learned from this issue and clarifications of the NRC
reporting requirements. The inspectors determined that licensee
corrective actions for this issue was adequate and had been
properly implemented. Based on this review, this violation is
closed.
(Closed) VIO 50-261/93-18-01:
Operations Failure to Follow
Procedures, Three Examples
This issue involved three separate examples where operations
personnel failed to follow plant procedures. The first issue
involved three valves that were found improperly locked using
chain link. The second issue involved an ERFIS alarm for control
rod position deviation that went undetected and not acted upon by
the control room reactor operator for several hours. The third
issue involved a reactor operator who flashed the field of the
emergency diesel generator at the wrong engine speed.
The licensee responded to this violation by letter dated October
11, 1993.
Licensee corrective actions for these issues were part
of broader actions to address weaknesses in personnel procedure
adherence and attention to detail.
Specific corrective actions
for the first issue included re-verifying that all valves in the
locked valve program were properly secured using chain devices.
The inspectors reviewed completed valve lineup documentation and
verified that this action was completed. Licensee corrective
actions to address the second violation example included adding
administrative controls for providing increased observation and
monitoring of Control Room indications. The inspectors reviewed
OMM-23, Operator Logs and Rounds, which requires that the reactor
operator review important plant parameters via the ERFIS Group
Trend printout on an hourly basis. The inspectors verified that
the operators were completing these reviews. Specific licensee
corrective actions for the third issue involved counselling the
operator involved relative to management expectations of procedure
compliance. This emphasis on procedure compliance was also
discussed with all other licensed and non-licensed operators.
The inspector determined that licensee corrective actions for
these issues were adequate and had been properly implemented.
Based on this review, this violation is closed.
(Closed) VIO 50-261/93-18-03:
Failure to Maintain Design Control
of Reactor Auxiliary Building Ventilation System
This issue involved the failure to implement adequate measures to
maintain the integrity of the Reactor Auxiliary Building
Ventilation System design between January 1992 until July 1993.
The licensee had implemented modifications and performed
maintenance during this period which degraded the system and had
not adequately performed post maintenance testing to verify the
system's design requirement for maintaining a negative building
pressure. A negative building pressure ensures that the air flow
is directed into the building and not outward.
The licensee responded to this violation by letter dated
October 11, 1993. Corrective actions included rebalancing the RAB
ventilation system (flow balance test completed on June 9, 1994)
to ensure, among other design requirements, that the RAB was
maintained at a negative pressure. The inspectors reviewed the
flow balance test results verifying that the acceptance criteria
for negative pressure in the RAB was met. As part of the flow
balance evaluation, the number and location of existing pressure
gauges in the RAB were reviewed by the licensee and determined to
be adequate. As a backup to the existing building pressure
gauges, provisions were made for installing portable pressure
instrumentation at various locations in the building.. Provisions
for periodically monitoring the RAB negative air pressure were
also developed. The inspectors reviewed the Inside Auxiliary
Operator's Log which was revised to include a check of the RAB
pressure once per shift. The licensee also provided formal
training for design engineering personnel on the need to consider
the effect of modifications on the RAB ventilation system
capability to maintain its design requirements. This training was
completed for selected personnel on April 8, 1994.
The inspector determined that licensee corrective actions for
these issues were adequate and had been properly implemented.
Based on this review, this violation and LER are closed.
4.
MAINTENANCE
a.
Maintenance Observation (NRC Inspection Procedure 62703)
The inspectors observed safety-related maintenance activities on
systems and components to determine if the activities were
conducted in accordance with regulatory requirements, approved
procedures, and appropriate industry codes and standards. The
inspectors reviewed associated administrative, material, testing,
radiological, and fire prevention controls requirements to
determine licensee compliance. In particular, the inspectors
observed/reviewed the following maintenance activities detailed
below:
12
WR/JO ABIL-001:
Calibration of Spray Additive Flow
Instruments FI-949 and FIT-949
WR/JO ABBW-001:
Calibration of Containment Spray Pump A
Pressure Gauge PI-945
WR/JO 95-AMNL1:
Investigate Problem with Boric Acid Bypass
Meter Flow Indication
Troubleshooting of Unexplained Turbine Governor Valve Movement
On October 3, the control room reactor operator noticed that the
number 2 turbine governor valve was slowly closing as indicated by
valve position on the RTGB. The operator placed the turbine
controls in manual which stopped the valve movement. During this
time period, the Net Megawatt recorder indicated that turbine load
had decreased by 5 Megawatts (electric). Following the event, I&C
was instructed to investigate this problem by checking for any
electrical problems with the turbine Electro-Hydraulic Controller
which controls the movement of the governor valves. These efforts
included taking voltage measurements in the controller panel with
the turbine in both automatic and manual mode to verify that the
governor valve demand signals were proper. The test results
confirmed that the valves were operating properly. The licensee
later determined that the problem may have been related to higher
than expected moisture in the turbine EHC oil and was continuing
with this investigation at the end of the report period.
The inspectors witnessed I&C technicians troubleshooting the
turbine Electro-Hydraulic Controller under WR/JO 95-AMDH1.
Overall, the conduct of this troubleshooting was satisfactory.
Noteworthy was the continuous I&C supervision and engineering
support provided during the activity. However, the inspectors did
note one item that was not indicative of good maintenance
practice. This involved the I&C technician's use of turbine
control system training material to reference voltage test points
as opposed to using controlled, technical information. When this
was brought to the attention of the I&C supervisor, who was
present during the activity, the inspectors were informed that he
had already instructed the technician to not use this information
during the field activity work.
b.
Surveillance Observation (NRC Inspection Procedure 61726)
The inspectors evaluated certain safety-related surveillance
activities to determine if 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, test instrumentation was properly
calibrated, the tests were completed at the required frequency,
and that the tests conformed to TS requirements. Upon test
13
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 and/or reviewed portions of the following test activity:
T-Average and Delta-Temperature Protection
Channel Testing
No violations or deviations were identified. Based on the information
obtained during the inspection, the area/program was adequately
implemented.
5.
ENGINEERING
a.
Engineering Support Activities (NRC Inspection Procedure 37551)
Throughout the inspection period, engineering evaluations of
problems and incidents were reviewed and discussions were held
with engineering personnel to assess the effectiveness of the
licensee's controls for identifying, resolving, and preventing
problems. Based on these inspections, the engineering staff was
effective and timely in responding to plant problems and
interfacing with operations.
b.
Engineering Followup (NRC Inspection Procedure 92703)
(Closed) URI 50-261/95-23-01:
Inadequate Justification for Plant
Operation With One Pressurizer Spray Valve Inoperable
This issue involved the adequacy of the licensee's operability
justification that the pressurizer pressure control system was
operable with one of the two pressurizer spray valves (PCV-455A)
out of service. Spray valve PCV-455A was removed from service and
isolated on August 8, 1995, after experiencing erratic position
indication. During the previous inspection, the inspectors
reviewed Expert Operability Analysis For OD 95-015, dated
August 7, 1995, which documented the licensee's evaluation of the
impact with the inoperable spray valve. It was determined that
the evaluation did not fully justify operation with only one spray
valve. Specifically, it did not adequately address design basis
information that implied that both spray valves were necessary for
controlling pressure during a 10 percent step load reduction, as
well as the need for redundant emergency power requirements for
the spray valves.
During this report period, the inspectors reviewed revisions 1 and
2 to Expert Operability Analysis For OD 95-015, dated August 11
and September 1, respectively. The inspectors determined that
these evaluations provided adequate justification for continued
operability of the pressurizer pressure control system with one
valve unavailable. This was based primarily on the licensee's
14
review of Chapter 15 of the Final Safety Analysis Report, which,
determined that there were no accidents that the plant was
designed for that took credit for the spray valves to help
mitigate. While the second spray valve is required to accommodate
step load changes between 5 and 10 percent without challenging the
Pressurizer Power Operated Relief valves, this loading or
unloading rate is considered to be initiated by planned operator
actions. The inspectors verified that limitations existed to
restrict operator loading and unloading to 5 percent. With regard
to emergency electrical power, the licensee determined that there
was no design requirement for the valves to receive redundant
electrical power. The inspectors discussed the licensee's
position and evaluation results with NRC personnel in the
department of Nuclear Reactor Regulation, who agreed with these
conclusions. The inspectors considered this URI closed.
No violations or deviations were identified. Based on the information
obtained during the inspection, the area/program was adequately
implemented.
6.
PLANT SUPPORT (NRC Inspection Procedures 71707 and 71750)
Throughout the inspection period, facility tours were conducted to
observe personnel activities as they relate to radiation protection and
security. The tours included entries into the protected areas and the
radiologically controlled areas of the plant and included assessment of
radiological postings and work practices. During these inspections,
discussions were held with radiation protection and security personnel.
The inspections confirmed the licensee's compliance with 10 CFR,
Technical Specifications, License Conditions, and Administrative
Procedures.
The inspectors considered noteworthy the good radiation controls
observed while witnessing maintenance personnel check the calibration of
the A Containment Spray Pump discharge pressure associated with WR/JO
ABBW-001. This activity was continuously controlled and monitored by
radiation control personnel to ensure that there was no contamination
spread during the maintenance activity.
No violations or deviations were identified. Based on the information
obtained during the inspection, the area/program was adequately
implemented.
7.
EXIT INTERVIEW
The inspectors met with licensee representatives (denoted in paragraph
1) at the conclusion of the inspection on October 26. During this
meeting, the inspectors summarized the scope and findings of the
inspection as they are detailed in this report. The licensee
representatives acknowledged the inspector's comments and did not
identify as proprietary any of the materials provided to or reviewed by
15.
the inspectors during this inspection.
No dissenting comments from the
licensee were received
Item Number
STATUS
Description/Reference Paragraph
VIO 95-27-01
Opened
Inadequate Clearance Results in Unexpected
Emergency Diesel Start (paragraph 3.a)
LER 93-001
Closed
TS 3.0 Implementation Due To Excessive PPS
Leakage (paragraph 3.a)
LER 93-004
Closed
Unusual Event Caused By Reactor Coolant
System Leakage (paragraph 3.a)
LER 93-005
Closed
Apparent Temperature Violation Of The
Boric Acid Storage Tank (paragraph 3.a)
LER 93-006
Closed
Inadequate EDG Ventilation System Due To
Bypassed Air (paragraph 3.a)
LER 93-007
Closed
Ventilation System Outside Design Basis
Due To Positive Pressure Condition
(paragraph 3.a)
LER 93-00-01
Closed
Ventilation System Outside Design Basis
Due To Positive Pressure Condition
(paragraph 3.a)
LER 93-009
Closed
TS 3.0 Entry For Service Water Pump
Operability Testing (paragraph 3.a)
LER 93-012
Closed
Engineered Safety Feature Actuation
(paragraph 3.a)
LER 93-013
Closed
T.S. Specification 3.10.1.3 Implementation
Due To Exceeding Rod Insertion Limits
(paragraph 3.a)
LER 93-014
Closed
Surveillance Tests Exceeded Technical
Specification Test Intervals (paragraph
3. a)
IFI 93-021-06
Closed
Vital Battery Terminal Fractures
(paragraph 3.c)
IFI 93-33-03
Closed
Need For Verification Of CV Spray And
Turbine Auto Stop Circuitry Continuity
Following Routine Testing (paragraph 3.c)
VIO 93-28-04
Closed
Three Examples Of Inadequate Or Failure To
Follow Procedure (paragraph 3.c)
16
VIO 93-11-01
Closed
Failure to Make a Timely Notification to
the NRC of a Notification to State
Authorities (paragraph 3.c)
VIO 93-18-01
Closed
Operations Failure to Follow Procedures,
Three Examples (paragraph 3.c)
VIO 93-18-03
Closed
Failure to Maintain Design Control of
Reactor Auxiliary Building Ventilation
System (paragraph 3.c)
URI 95-23-01
Closed
Inadequate Justification for Plant
Operation With One Pressurizer Spray Valve
Inoperable (paragraph 5.)
8.
ACRONYMS AND INITIALISMS
Administrative Procedure
CFR
Code of Federal Regulation
CR
Condition Report
CV
Containment Vessel
ERFIS
Emergency Response Facility Information System
Instrumentation And Control
IFI
Inspector Followup Item
LCTR
Local Clearance and Test Request
LER
Licensee Event Report
MMM
Maintenance Management Manual
Maintenance Surveillance Test
NAS
Nuclear Assessment Section
National Pollutant Discharge Elimination System
OMM
Operations Management Manual
Preventative Maintenance
Penetration Pressurization System
Reactor Auxiliary Building
Reactor Turbine Gauge Board
TS
Technical Specifications
Unresolved Item
Violation
WR/JO
Work Request/Job Order