ML14181A805

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Insp Rept 50-261/96-01 on 960101-20.Violations Noted.Major Areas Inspected:Plant Operations,Maint & Surveillance, Engineering & Plant Support Physical Security Program
ML14181A805
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 02/16/1996
From: William Orders, Shymlock M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14181A803 List:
References
50-261-96-01, 50-261-96-1, NUDOCS 9603050113
Download: ML14181A805 (18)


See also: IR 05000261/1996001

Text

SREG(,

UNITED STATES

o

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, N.W., SUITE 2900

ATLANTA, GEORGIA 30323-0199

Report No.: 50-261/96-01

Licensee:

Carolina Power & 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: January 1-20, 1996

Lead Inspector:

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1,

T. Ordels, Senior Resident Inspector

Date Signed

Other Inspector: J. Zeiler, Resident Inspector

J. Coley, Region II Inspector (3.1.1; 3.1.2; 3.3.1)

W. Miller, Region II Inspector (2.3; 3.1.3; 3.3.2; 4.2.1;

4.2.2; 5.1.3.1)

Approved by:

__

_

_

_

_

__,1

'-49k

Milton B. Shymfck, Chief

Date Signed

Reactor Projects Branch 4

Division of Reactor Projects

SUMMARY

SCOPE:

Inspections were conducted by resident and regional inspectors in the areas of

plant operations which included Engineered Safety Features Walkdown

Auxiliary Feedwater System, Effectiveness of Licensee Control in Identifying,

Resolving, and Preventing Problems; maintenance and surveillance which

included A CVCS Charging Pump Packing Leakage Repairs, RHR Pump Room Cooler

HVH-8A Replacement, Spent Fuel Building Exhaust Air Handling Unit,

Surveillance Observations of OST 302-1 Service Water Component Test and, Close

Out of Open Issues; engineering which included ESR 95-00929, Rev. 3, RHR Pump

Room Cooler Equipment Evaluation, Expert Operability Analysis Number 96-01,

ESR 96-00028, Rev.1, Evaluate Replacement Motor for HVH-5A and, Close Out of

Open Issues; and plant support Physical Security Program, Radiological

Protection Program, Inadequate Training on New Personnel Contamination

Monitors, Fire Protection Program and, Motor Driven Fire Pump Test.

ENCLOSURE 2

9603050113 960216

PPR ADOCK 05000261

G

PDR

2

RESULTS:

Plant Operations

Walkdown inspection of the Auxiliary Feedwater System verified that the system

was operable and, except for two valves found to be throttled as opposed to

fully open, the system was well maintained. The misalignment of these valves

was identified as Violation 50-261/96-01-01 (paragraph 2.3).

Maintenance

Plant corrective maintenance was properly controlled and coordinated and was

conducted in accordance with applicable approved instructions by knowledgeable

and skilled craft personnel (paragraph 3.1).

The initial measurement method

used to determine the minimum wall thickness for RHR pump room cooler piping

was identified as being weak (paragraph 3.1.2).

The effectiveness of licensee

corrective actions to resolve instrument line configuration problems

associated with Residual Heat Removal flow transmitter FT-605 was determined

to be weak. However, management attention and planned corrective actions to

address these, as well as other transmitter configuration problems was now

evident (paragraph 3.3.1).

Engineering

Several engineering evaluations reviewed in detail were considered to be

detailed, utilized conservative assumptions, and were developed and approved

in accordance with licensee administrative requirements (paragraph 4.1).

In general, the engineering staff was effective and timely in responding to

plant problems and interfacing with operations. However, an example was

identified where a detailed evaluation of worn equipment parts and abnormal

noise heard in the A Charging Pump was not planned until questioned by the

inspectors (paragraph 3.1.1 and 4.1).

Plant Support

Initial plant personnel training on new Radiation Control Area exit

contamination monitors was ineffective. Subsequent training and instructions

were provided which corrected this condition (paragraph 5.1.2.1).

The motor driven fire pump was satisfactorily tested using a well written

procedure, performed by conscientious test personnel who demonstrated a

knowledge of the fire protection water system and the test requirements

(paragraph 5.1.3.1).

REPORT DETAILS

1.0

PERSONS CONTACTED

Licensee Employees:

  • Clark, B., Manager, Maintenance

Clements, J., Manager, Site Support Services

  • Crook, D., Senior Specialist, Licensing/Regulatory Compliance

Gudger, D., Senior Specialist, Licensing/Regulatory Programs

Hinnant, C., Vice President, Robinson Nuclear Plant

  • Keenan, J., Director, Site Operations

Krich, R., Manager, Regulatory Affairs

  • Meyer, B., Manager, Operations
  • Miller, G., Manager, Robinson Engineering Support Services
  • Moyer, J., Manager, Nuclear Assessment Section
  • Stoddard, D., Manager, Operating Experience Assessment

Warden, R., Superintendent, Plant Support Assessment

Wilkerson, T., Manager, Environmental Control

  • Young, D., Plant General Manager

Other licensee employees contacted included office, operations,

engineering, maintenance, and chemistry/radiation 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.

2.0

PLANT OPERATIONS (71707 and 92901)

2.1

Plant Status

The unit operated at or near full power for the entire report period with no

major problems.

2.2

Plant Operations Observation Activities

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, control room observations, 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

2

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 and to assess the general condition of plant

equipment.

2.3

Engineered Safety Features Walkdown - Auxiliary Feedwater System

The inspectors performed a review and walkdown inspection of the accessible

portions of the AFW System to verify system operability and to determine if

the system alignment procedure conformed to plant drawings and the as-built

configuration. This evaluation and inspection used the following documents:

Drawing Nos. G-190197, Sheets 1 - 4, Feedwater, Condensate, and Air

Evacuation System Flow Diagram

System Description SD-027, Feedwater System (Revision 15, 12/6/95)

Updated FSAR, Section 10.4.8

OP-402, AFW System (Revision 38, 6/29/95)

OP-402 Attachment 9.1, AFW Valve Checklist

Based on review of the feedwater system flow diagrams and the 'W System valve

alignment checklist procedure, appropriate valves were found to be included in

the checklist procedure.

During the walkdown inspection of the AFW System, the inspectors reviewed the

following:

alignment of electrical breakers to the AFW pumps and MOV valves

and alignment of principle valves in the system; installation of hangers and

supports; closure of valves to drain and vent pipe openings and installation

of pipe caps; labeling and identification of pumps, valves, and components;

and lubrication levels in all visible oil and lubrication devices. The AFW

piping system was inspected for leakage. The housekeeping in the AFW System

areas was inspected to determine if transient combustibles were stored in the

areas.

The equipment condition of the AFW system was good and no major system leaks

were noted. Several small minor leaks were noted but the licensee had

previously identified these leaks and had submitted work requests to correct

them. Housekeeping in these areas was satisfactory.

One discrepancy was identified. Two valves, AFW-110, AFW Pump A Recirculation

Isolation Valve, and AFW-111, AFW Pump B Recirculation Isolation Valve, were

found by the inspector to be in a throttled position, approximately 40 percent

closed or 60 percent open. The AFW System Valve Checklist, OP-402 Attachment

9.1, requires these valves to be in the full open position.

3

These discrepancies were reported to the Shift Supervisor. The Shift

Supervisor promptly sent an Auxiliary Unit Operator t o check these valves.

The operator confirmed that these valves were not fully op,..

The valves were

subsequently opened. In addition, all of the AFW valves in the AFW pump room

were also promptly checked and verified by Operations to be correctly aligned.

The inspector reviewed the most current valve alignment checklist for the AFW

System which was completed on June 1, 1995. This checklist indicated that

these valves had been inspected and independently verified to be in the fully

open position. Procedures OMM-1, Operations - Conduct of Operations, and PLP

030, Independent Verification, required that correct valve positions should be

determined and verified by hands-on checking of the valve, except for valves

located in radiation areas for ALARA concerns. The licensee issued Condition

Report 96-0126 to review this event, determine the cause, and to identify

action necessary to prevent recurrence. One of the actions in process by the

licensee was an evaluation to determine if any work activities had required

these valves to be realigned since completion of the June 1995 valve

checklist. At the conclusion of this inspection the Condition Report was

still in review.

The AFW System was operable and the throttling of valve Nos. AFW-110 and AFW

111 had no operational effect on the AFW System since restrictive orifices

were installed downstream from these valves. However, the failure to maintain

the alignment of an engineered safety system in accordance with design

drawings, procedures and operational requirements could result in a

potentially serious problem. Therefore, this item is identified as Violation

50-261/96-01-01, AFW System Valve Misalignment.

The calibration data for AFW System instrumentation was also reviewed by the

inspectors. Current calibration records (ie., stickers) were not installed on

AFW instrumentation but, were maintained by calibration procedures controlled

by the I&C Department. The inspectors reviewed the calibration data for a

sample of five pressure instruments (PI-1425, PI-1426, PI-1478-1, PI-1479-1,

and PI-1480-1) and verified that these instruments were included in the

licensee's routine calibration program and that the calibration for each of

these instruments was up to date.

The inspectors reviewed the completed test procedures for the MDAFW pumps,

OST-201-A, MDAFW System Component Test - Train "A" (Monthly), and OST-201-B

MDAFW System Component Test - Train "B" (Monthly), which were completed on

January 3, 1996, and January 16, 1996, respectively. The results of these

completed tests indicated that the MDAFW pumps met the acceptance criteria.

The inspectors did not note any discrepancies in the completed test

procedures. The most recent test on the turbine driven AFW pump was

satisfactory and was witnessed by the NRC. The results of this test were

documented in NRC Inspection Report No. 50-261/95-30.

Based on this evaluation, the AFW System was operable and, except for the two

misaligned valves, the system appeared to be well maintained.

Within the area inspected, one violation was identified.

4

2.4

Effectiveness of Licensee Control in Identifying, Resolving, and

Preventing Problems

The inspectors evaluated certain activities of the Plant Nuclear Safety

Committee to determine whether the onsite review functions were conducted in

accordance with TS and other regulatory requirements. In particular, the

inspectors attended meetings conducted on January 10 and January 16, 1996. It

was ascertained that provisions of the TS dealing with membership, review

process, frequency, and qualifications were satisfied. The minutes from these

meetings were reviewed to confirm that decisions and recommendations were

accurately reflected.

3.0

MAINTENANCE (61726, 62703, and 92902)

3.1

Maintenance Observations

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, and radiological control requirements to determine licensee

compliance. The inspectors witnesses and/or reviewed portions of the

following maintenance activities:

3.1.1 A CVCS Charging Pump Packing Leakage Repairs

On January 4, the licensee initiated planned maintenance to repair leakage

identified from the secondary stuffing box packing of the A positive

displacement CVCS charging pump.

TS 3.2.2 requires only two of the three

charging pumps be operable while operating at power, therefore, maintenance

could be performed on the A charging pump without entering a TS LCO while it

was inoperable.

The repair activity was performed under WR/JO 95-AQCA1.

Corrective

Maintenance procedure CM-034, Charging Pump Stuffing Box Maintenance, was used

to disassemble, replace the packing, and reassemble the pump. In addition to

the packing, engineering personnel also decided to replace all three fluid

cylinder plungers due to the extended service life already experienced with

the existing plungers. During the subsequent post-maintenance testing, the

pump did not develop the expected flow rate and an abnormal noise was heard

from inside the pump casing. Based on these irregularities, the licensee

decided to disassemble the pump and replace the internal suction and discharge

check valves. It was believed that these valves were not seating properly

resulting in the problems experienced. This work was performed under WR/JO

96-AABD1 using procedure CM-035, Charging Pump Maintenance Valve Disassembly

and Reassembly. The inspectors witnessed aspects of work activities

associated with WR/JOs 95-AQCAl and 96-AABD1 and verified the following: 1)

the pump was properly cleared (tagged out) by operations personnel, 2) proper

approvals were obtained prior to beginning work, 3) the proper revision of CM

034 was utilized and being followed, 4) required tools were properly

calibrated and utilized, 5) correct parts were used, and, 6) personnel were

qualified and knowledgeable.

5

In addition, the inspectors reviewed the vendor manual for the pump (Union

Pump Company) and verified that applicable assembly and reassembly guidance

was incorporated into CM-034 and CM-035. Based on these inspection

activities, no discrepancies were identified. However, after the pump was

tested and returned to service following the check valve replacement, the

inspectors noticed a distinct metallic ping noise originating from inside the

pump. This noise appeared to be connected with the opening and closing of the

suction or discharge check valves and was not characteristic in the B or C

charging pumps. To obtain additional information on the cause of the noise in

the pump, the inspectors discussed this observation with the system engineer.

The inspectors learned that while engineering had looked briefly at the valves

as they were removed, a detailed evaluation of the worn valve parts had not

been conducted. This was due primarily because a decision was made based on

service life of the valves to replace them with new ones. The inspectors

requested to see the old valves to determine whether the wear on these valves

would indicate why this pump made a metallic noise while the others did not.

The inspectors were told that the valves had been thrown in radwaste, but they

would be retrieved for the licensee's engineering support and the inspectors

to examine. The inspectors subsequent examination revealed that two of the

discharge valves had significant wear on the inboard and middle guide

indicating the discharge valve seat may have a slight irregularity in its

seating surface. Subsequent discussions with the previous system engineer for

the charging pumps indicated that the A pump had always made a metallic noise

while operating, however, a detailed evaluation of this condition and its

potential impact-to the pump had never been performed. The inspectors

believed that the noise could be an indication of a problem that may be

contributing to the valve ware. Following discussions with the mechanical

engineering manager regarding these concerns, the licensee indicated that a

more detailed evaluation of the pump noise and valve wear would be performed.

Regardless of the conclusions of this investigation, the inspectors considered

that engineering had not been proactive or thorough in evaluating potentially

adverse pump conditions (i.e., abnormal pump noise and worn equipment parts)

when they were initially identified.

3.1.2 RHR Pump Room Cooler HVH-8A Replacement

This corrective maintenance involved the replacement of one of the RHR pump

room coolers (HVH-8A) due to an excessive service water tube leak. The

maintenance was performed under WR/JO 95-AQC1.

The inspectors witnessed

aspects of the work activities and verified the following: 1) proper approvals

were obtained prior to beginning work, 2) approved procedures/instructions

were used and followed, 3) correct parts and tools were used, 4) required

tools were properly calibrated, 5) safety and radiation controls were

observed, 6) personnel were qualified and knowledgeable, and, 7) supervision

and QC was adequate. When the service water lines were disconnected from the

cooler and taken to the hot machine shop for modification, pipe wall corrosion

was found in the copper service water piping. During the initial evaluation

process to determine whether the pipe could be used again, a rapid response

team engineer was assigned to support the work activities.

6

The engineer directed maintenance personnel to obtain the minimum pipe wall

thickness. The method selected was to use inside calipers for the pipe

internal surface and outside calipers which would fit in the thread root of

the outside portion of the pipe. The inspectors observed the measurements

being taken and questioned how this method could determine minimum wall

thickness. What was being obtained was the average wall thickness since the

good side of the pipe wall was being averaged with the bad.

In addition, the

corroded area of the pipe also had some significant pits which were not being

considered in the measurement method. The engineer instructed a maintenance

technician to obtain a needle point micrometer in order to consider the pipe

pits in the measurement method. The inspectors later learned that a materials

engineer had examined and rejected the pipe due to it not meeting minimum

thickness criteria. The inspectors determined that this measurement was

properly obtained. The inspectors considered the methods used to take the

initial measurements of the pipe minimum wall thickness to indicate a weakness

in the licensee's evaluation of pipe discontinuities which could have resulted

in defective material possibility being reinstalled into the system.

The licensee subsequently substituted 316L stainless steel pipe for the copper

pipe. Work was completed for the service water pipe modification and the

service water pipe was reconnected to the cooler.

3.1.3 Spent Fuel Building Exhaust Air Handling Unit

The Fuel Handing Building, including the Spent Fuel Pool area, has two

ventilation systems. The system normally in operation uses supply fan HVS-2

and exhaust fan HVE-15. The emergency system uses two different fans, supply

fan HVS-4 and exhaust fan HVE-15A. Exhaust fan HVE-15A also includes an

electric heater and charcoal filter unit. The emergency ventilation system is

normally only operated during fuel movement in the spent fuel pool.

Both of

these systems discharge to the plant stack.

On January 16, during the performance of fuel movement and fuel inspection

activities in the spent fuel pool, air handling supply fan HVS-4 and exhaust

fan HVE-15A tripped. The fuel inspection activities were discontinued and

WR/JO 96-AAGH1 was issued to investigate and determine why these fans had

tripped.

The maintenance investigation per WR/JO 96-AAGH1 found that the electrical

connecting leads to the motor winding within the motor raceway terminal box

for fan HVE-15A had been loose and shorted to ground. This short caused the

breaker for fan HVE-15A to trip. The inspectors monitored the repair

activities. The repair activities included replacement of approximately 50

feet of power cable from the motor for fan HVE-15A to the motor starter,

connecting the power cables to the motor leads, megger testing of the power

supply wiring and the wiring for the motor to fan HVE-15A, verification of

correct motor rotation, and post maintenance testing by running the fan for

several hours to assure proper operation.

The inspectors reviewed the completed work package and noted that appropriate

hold points had been included in the WR/JO and that appropriate inspection and

verification had been performed by a QC Inspector or independent verifier. No

7

discrepancies were noted. The licensee issued a condition report for

additional review of this event to determine the root cause of the motor fan

failure and to determine what additional actions were warranted.

3.2

Surveillance Observations

The inspectors evaluated certain 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, 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 the tests conformed to TS requirements. Upon test

completion, the inspectors verified that the recorded test data was complete,

accurate, and met TS requirements, test discrepancies were properly documented

and rectified, and the systems were properly returned to service.

Specifically, the inspectors witnessed and/or reviewed portions of the

following test activities:

OST 302-1

Service Water Component Test - Quarterly

3.3

Close Out Issues

3.3.1 (Closed) VIO 50-261/94-17-02:

Failure to Correct Improperly Routed

Instrument Sensing Lines While Troubleshooting Repetitive Gas Binding of

RHR Flow Indicator

The licensee responded to this violation by letter dated September 14, 1994.

As a result of the FT-605 air entrapment issue, some of the sensing line

piping was rerouted to provide the slope of 1 inch rise per foot as

recommended by the vendor (Rosemount). The licensee performed a walkdown of

all flow transmitter sensing lines (in July, 1994) and determined that the

sensing lines were either routed properly or were evaluated as acceptable. On

November 26, 1995, flow transmitter (FT-605) was again reported to be

indicating a flow of up to 900 gpm with no flow in the RHR system. This event

occurred shortly after the flow transmitter had been dry calibrated. At this

point the licensee discovered that not all the sensing lines were properly

sloped. The remaining sensing lines for this transmitter were determined to

be properly routed at that time. However, during the investigation of the

Significant Condition Report (No. 95-2800) generated for this latest event,

the engineer discovered that one utility had found that performing wet

calibrations and backfilling from the bottom of the transmitter were effective

and a cost efficient means of resolving air entrapment difficulties in sensing

lines which do not have the recommended slope. These recommendations,

however, were not implemented as corrective action for FT-605.

On November 29, 1995, following an investigation of a discrepancy in Safety

Injection system accumulator LT indication, engineering personnel discovered

that, between October 28, 1995, and November 3, 1995, both of the LTs for the

C accumulator had been offset upscale to the extent that the actual level was

6 to 7% lower than indicated. This event was caused by failure to implement

8

adequate calibration procedures for the accumulator LTs and inadequacies in

the configuration of the transmitter piping and tubing. This resulted in

difficulties in removing trapped gasses. The licensee reported the event in

LER 95-009-00, dated December 29, 1995 and issued a Significant Condition

Report (CR 95-02762).

Violation 50-261/95-30-01 was issued for inadequate

procedures.

Corrective actions for these issues included a field walkdown and maintenance

history review on all safety related differential pressure transmitters (flow

and level). The purpose of the walkdown was to provide information on the

actual field installed configuration of the process sensing tubing. The

licensee identified the corrective actions as item #2 on the Robinson Nuclear

Plant "Top Ten" Equipment Issues List. This required that all safety related

transmitters be identified, walkdowns be performed of all accessible tubing

configurations, a history search be performed for problem instruments, a "hit

list" of problem instruments be established, a corrective action plan

developed for each problem instrument, and establish the industry standard for

the calibration of differential pressure transmitters cells (i.e. dry, wet,

backfill, etc.).

Since the corrective action in LER 95-009-00 for the

accumulators level transmitters will re-evaluate the corrective actions taken

on Violation No. 50-261/94-17-02 (FT-605), the inspectors considered this

violation closed. The adequacy of the licensee's corrective actions to

address this and other transmitter configuration inadequacies will be tracked

as part of the closeout review for LER 95-009-00 and VIO 50-261/95-30-01.

3.3.2 (Closed) LER 261/94-003-02: Technical Specification Required Shutdown

Due to Emergency Diesel Generator Inoperability

This event occurred on February 18, 1994, when a locking pin for the

modulating air damper to EDG B came loose and was propelled through the

engine's air system damaging the scavenging air blower and turbocharger. The

damaged components were replaced and EDG B was returned to service.

The corrective action for this event included enhancements in the

investigation procedures for plant events. The NRC review and evaluation of

this event resulted in the issuance of Violation 50-261/94-08-02. This issue

was documented in NRC Inspection Report Nos. 50-261/94-04 and 94-08. The

licensee's corrective actions to prevent recurrence for the violation and the

corrective action for this LER are the same. The corrective action for the

violation was reviewed and found acceptable, and was closed as documented in

NRC Inspection Report 50-261/95-29. Therefore, based on this previous review,

LER 94-003-02 is closed.

3.3.3 (Closed) LER 50-261/94-006-00: Manual Reactor Trip Due to Electro

Hydraulic System Oil Leak

On April 3, 1994, with the unit operating at full power, a load reduction was

initiated due to a leak in the E-H oil system. The E-H oil pumps tripped on

low E-H oil level and the operators manually tripped the reactor prior to an

9

automatic reactor trip on load reduction. The cause of this event was the

failure of an 0-ring which was incorrectly installed in a turbine governor

valve. Following the unit's shutdown, all of the other E-H Control System

turbine valve 0-rings were replaced.

The corrective actions taken for this LER included: covering this event in the

craft training program, counselling of individuals responsible for the

improperly assembled turbine valve, and inclusion of the E-H Control System

into the plant's preventive maintenance program.

The inspectors reviewed Adverse Condition Report 94-0598 and verified that the

corrective actions discussed above had been completed. This LER is closed.

3.3.4 (Closed) LER 50-261/94-011-01:

Technical Specification 3.0:

Emergency

Diesel Generator Inoperability, and,

(Closed) LER 50-261/94-015-01:

Technical Specification 3.0:

Emergency

Diesel Generator Inoperability

These LERs identified a number of dates in which the plant was operating at

full power with one EDG out of service for maintenance and the redundant EDG

out of service for approximately three hours per day to meet the operability

testing requirements of the TS.

During these testing evolutions, off site

power was available to the unit and operators were located in the room of the

EDG being tested with the ability to manually place the EDG in service should

off-site power be lost.

To resolve this issue, the licensee submitted a TS change request to the NRC

that eliminated, in most cases, the requirement to test the redundant EDG when

one of the two EDGs is inoperable. The inspector reviewed the TS and verified

that this change had been incorporated into the TS by Amendment 158.

Based on

this review, these LERs are closed.

4.0

ENGINEERING (37551 and 92903)

4.1

Engineering Support Activities

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. The following engineering evaluations

were reviewed:

4.1.1 ESR 95-00929, Rev. 3, RHR Pump Room Cooler Equipment Evaluation

Due to excessive service water tube leakage, the licensee decided to replace

the cooler associated with HVH-8A. The RHR room coolers, HVH-8A and HVH-8B,

are designed to limit the RHR pump room temperature increase during a design

basis accident.

This cooling function provides protection for the associated

RHR components (RHR pump, valves, and cables) located in the room. The ESR

and associated 10 CFR 50.59 were developed to justify the RHR system

operability with one of the RHR room coolers, HVH-8A, out of service. The

10

analysis was conducted assuming HVH-8A was out of service for period of time

not to exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The evaluation considered the room temperature to be

below 113 F when the postulated design basis accident began. As long as the

starting room temperature remained below 113'F, the temperature gradient

during the accident would not exceed the maximum allowed temperature for the

most limiting safety-related components in the room. One of the main concerns

addressed was the effect on the RHR pump motor bearing oil and grease which

can degrade at the higher temperatures. Based on recently changing these

lubricants, the Environmental Qualification concerns were not considered to be

a problem. As a precaution, however, a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> cooler inoperability period

was recommended to ensure the quality of the lubricants would not degrade to a

questionable status over the duration of the design basis accident.

4.1.2 Expert Operability Analysis Number 96-01

On January 8, during the performance of MST-903, Station Battery Charge

Monthly, the licensee identified on Battery A that cells 33, 34, and 35 were

slightly below the 67*F acceptance criteria required by the procedure. A 72

hour operability determination was initiated for engineering to determine the

impact of this condition on the operability of Battery A.

The inspectors reviewed Operability Determination 96-01 which indicated that

Battery A was capable of supporting its required electrical loads even if the

electrolytic temperature of all of the battery cells were to reach 55'F.

Therefore, Battery A was considered past-operable since none of the battery

cells approached this temperature. The cause of the lower than normal

electrolyte temperature was due to the close proximity of outside makeup air

that was directed on these cells. In order to prevent this from recurring, a

temporary baffle was constructed using plastic to prevent the makeup air from

blowing directly on the battery cells. Periodic monitoring ensured that

battery cell temperatures remained above 67.F. The licensee planned to

install a permanent baffle arrangement in the near future. Based on this

review, the inspectors determined that the disposition of this operability

issue was adequate.

4.1.3 ESR 96-00028, Rev.1, Evaluate Replacement Motor for HVH-5A

This engineering evaluation was to evaluate the equivalency for a replacement

motor for one of the Control Rod Drive Mechanism Cooling Fans, HVH-5A. These

cooling fans are not safety-related, but provide necessary cooling of the

Control Rod Drive Mechanisms during power operation. On January 20, the HVH

5A motor failed unexpectedly due to a motor short. An identical replacement

motor was not available. The replacement motor differed in that the Full Load

Amperes was slightly lower and the RPM was slightly higher than the original.

The evaluation was detailed in its consideration of motor equivalency. Those

items reviewed in the equivalency determination included: seismic, both

electrical and mechanical characteristics, system interfaces, and design

impact. The replacement motor was determined to be equal to or exceeded the

original motor in all respects.

Based on these inspections, the engineering evaluations were determined to be

detailed, utilized conservative assumptions, and were developed and approved

in accordance with licensee administrative requirements.

Besides the weakness in engineering support for not initiating a more detailed

evaluation of worn equipment parts and abnormal noise heard in the A CVCS

Charging Pump following maintenance, the engineering staff was effective and

timely in responding to plant problems and interfacing with operations.

4.2

Close Out Issues

4.2.1 (Closed) LER 50-261/94-004-00:

Auxiliary Building Outside Design Basis

Due to Positive Pressure Conditions

On March 12, 1994, during an outage, containment purge and the auxiliary

building supply and exhaust fans were in operation while testing was in

progress on an EDG. The EDG testing required the EDG supply and exhaust fans

to be in service. This configuration resulted in a decrease in the exhaust

flow from the auxiliary building due to back pressure from the plant stack,

thereby, creating a positive pressure condition in the Auxiliary Building.

This positive pressure condition for the auxiliary building was contrary to

the design basis for the building.

The corrective action for this item included a change to Procedure OST-401,

EDGs (Slow Speed Start), to require the monitoring of the auxiliary building

pressure indicator for negative pressure during operational testing of the

EDGs. If the building pressure is not negative, the door to the EDG room

being tested is required to be closed and the auxiliary building supply fan

(HVS-1) shutdown. If negative pressure still can not be maintained,

Operations is required to perform the following: inform Engineering of the

condition, determine reporting requirements, and start recording the room

temperature hourly for Auxiliary Building Rooms El and E2.

The inspector reviewed Adverse Condition Report 94-0488 on this event and

Procedures OST-401, EDG (Slow Speed Start) (Revision 45, 7/18/95), OST-409,

EDG (Rapid Speed Start) (Revision 17, 7/18/95), OST-410, EDG A (24 Hour Load

Test) (Revision 5, 1/5/96), and OST-411, EDG B (24 Hour Load Test) (Revision

5, 1/12/96) and verified that this corrective action had been completed. This

item is closed.

4.2.2 (Closed) LER 50-261/94-008-00: Condition Outside Design Basis Due to

Control Room HVAC Inoperability

On May 7, 1994, with the unit operating at full power, flow balancing was

being performed on the auxiliary building HVAC system. During the process of

flow balancing, the licensee discovered that the pressure in a room adjacent

to the control room exceeded the pressure that would exist in the control room

in the event of an emergency pressurization mode of operation. This condition

was outside of the plant's design basis.

12

Following an NRC evaluation, this item was identified as Deviation 50-261/94

14-01.

The licensee responded to this deviation by letter dated July 15,

1994.

'lie corrective action for the deviation included revisions to testing

procedures to reflect the requirements of the Technical Specifications and the

FSAR commitments. This corrective action was reviewed by the NRC and found

acceptable and the deviation was closed by NRC Inspection Report 50-261/95-04.

The corrective action for this deviation is essentially the same as the

corrective action for LER 94-008-00. This LER is closed.

Subsequently, LER 50-261/94-008-01 (Supplemental) was issued which revised and

expanded the analysis and corrective actions identified in the original LER.

These additional items were addressed by the NRC through escalated enforcement

action and have not yet been reviewed by the NRC.

LER 94-008-01 remains open

and will be evaluated during the review of the corrective actions for the

escalated enforcement violation.

4.2.3 (Closed) VIO 50-261/93-10-01:

Failure to Establish Adequate Procedures

to Verify Proper AMSAC Operation After Microprocessor Replacement

On April 20, 1993, the resident inspectors identified that complete logic

testing of the AMSAC circuitry was not being performed after the A AMSAC

channel's microprocessor was replaced and the channel was returned to service.

The post-maintenance test procedure that was performed did not include testing

of the output logic contacts associated with the A channel.

This was

determined to be a violation of 10 CFR 50, Appendix B, Criterion V, requiring

activities affecting quality be prescribed by documented procedures.

The licensee responded to this violation via letter dated July 1, 1993.

Corrective actions involved revision to Special Procedure SP-1198, AMSAC

System Test, to incorporate steps for testing the output logic contacts. In

addition, the licensee determined that when SP-1198 was originally developed,

it had not been reviewed by the proper engineering individual responsible for

the AMSAC circuitry. Engineering personnel were counseled on the importance

of assuring qualified individuals are utilized to review procedures.

The inspectors reviewed WR/JOs 93-AESZ1 and 93-AEKL1, which were performed

April 23 and May 6, 1993, respectively, using the revised procedure to test

the output logic contacts of the A and B train AMSAC channels. This testing

verified that the contacts were operating properly. Based on this review,

this item is closed.

4.2.4 (Closed) IFI 50-261/93-10-02:

Lack of Spare Parts Could Result in

Prolonged Unavailability of AMSAC

During review of maintenance related to replacing the microprocessors for the

AMSAC circuitry, the inspectors noted that spare microprocessors were

unavailable and the vendor no longer manufactured the components. Due to

microprocessor unavailability approximately three weeks elapsed before another

microprocessor could be obtained and the B AMSAC channel returned to service.

The inspectors were concerned that future failures of the microprocessors

could lead to prolonged unavailability of the AMSAC system.

13

The inspectors reviewed ESR 9500048 which was initiated to address the AMSAC

spare parts unavailability and discussed the status of the licensee's progress

in resolving this issue. In July 1995, the licensee located a vendor which

could refurbish the microprocessors. At that time, the vendor supplied the

licensee with two spare microprocessors. Two additional microprocessors were

sent to the vendor for refurbishment. These parts were returned in December

1995. Therefore, the licensee presently has four spare parts available.

Based on the availability of a vendor which can supply the licensee with

refurbished microprocessors, this IFI was closed.

5.0

PLANT SUPPORT (71707, 71750 and 92904)

5.1

Plant Support Activities

The inspectors conducted plant tours, work activity observations, personnel

interviews, and documentation reviews, to determine if plant physical

security, radiological protection, and fire protection programs, were properly

implemented.

5.1.1 Physical Security Program

The inspectors toured the protected area and observed the protected area

fence, including the barbed wire, to ensure that the fence was intact and not

in need of repair. Isolation zones were maintained and clear of objects which

could shield or conceal personnel.

Personnel and packages entering the

protected area were searched by detection devices or by hand for firearms,

explosive devices, and other contraband. Vehicles were searched, escorted,

and secured as required. No deficiencies were identified in this area.

5.1.2 Radiological Protection Program

The inspectors observed radiological control activities to ensure that they

were conducted in accordance with regulatory and licensee requirements.

Observations included personnel entry and exit from the Radiation Control

Area, proper donning of radiological monitoring instrumentation and protective

clothing when entering the RCA and contaminated areas, and, proper

radiological area postings and controls. No deficiencies were identified in

this area.

5.1.2.1 Inadequate Training on New Personnel Contamination Monitors

On December 29, 1995, the licensee completed construction of a new RCA

Processing Area. The old processing area was removed from service following

activation of the new area. This new RCA entrance was relocated closer to the

Auxiliary Building and should allow easier access of personnel and equipment

into and out of the RCA. In addition to remodeling, new exit personnel

contamination monitors were installed to replace the existing PCM-1 monitors.

On January 4, the inspectors observed traffic into and out of the new

processing area and noted numerous instances where personnel failed to

properly use the personnel contamination monitors during exit of the RCA.

14

These instances involved improper placement of the hands such that the

opposite side of the palms were not scanned by the monitors.

The inspectors brought each of these instances immediately to the attention of

RC personnel on duty in the processing area. The individuals exiting

improperly were detained by RC personnel and instructed on re-exiting the

monitors properly. As a result, none of the individuals exited without

properly using the monitors.

The inspectors reviewed the training/instruction provided for plant personnel

on how to properly use the monitors.

Information on the opening of the new

RCA entrance area was communicated to plant personnel via the weekly plant

newsletter (Robinson Review).

The inspectors reviewed this newsletter article

and noted that it included information regarding the proper use of the

monitors.

However, the inspectors determined that this was an ineffective

mechanism for providing guidance on the use of the monitors, especially since

this newsletter is not required reading by plant personnel. After discussions

with RC management personnel regarding the problems observed, the licensee

decided to provide additional instructions on the proper use of the monitors

at upcoming plant employee safety meetings. These meetings were held with all

plant employees. The inspectors periodically monitored personnel exiting the

RCA during the remainder of the report period and did not observe any further

instances of inadequate monitoring.

5.1.3 Fire Protection Program

The inspectors periodically reviewed aspects of the licensee's fire protection

program including fire brigade staffing controls, flammable materials storage,

housekeeping, control of hazardous chemicals, and maintenance of fire

protection equipment. No discrepancies were identified.

5.1.3.1 Motor Driven Fire Pump Test

On January 18, the inspectors witnessed the performance of OST-622, Fire

Suppression Water System Motor Driven Fire Pump Test (Annual). The test met

the acceptance criteria and verified that the motor driven pump started

between 95 and 105 psig and developed a minimum flow of 2,500 gpm at a

pressure of 125 psig or greater. The inspectors reviewed the test procedure

and noted that the procedure was well written and met the general industry

practice for the test of fire pumps. The test procedure required the pump to

be tested at shut-off head with no flow, rated head at rated flow, 150 percent

of rated flow at 65 percent of rated head, and at two additional points on the

original test curve.

This test was performed by two fire protection technicians, two system

engineers and two auxiliary unit operators. The test personnel

conscientiously performed the test and the system engineers and fire

technicians appeared to be knowledgeable of the system and the test

requirements.

Within the area examined, no violations or deviations were identified.

15

6.0

EXIT

The inspection scope and findings were summarized on January 25, 1996, with

those persons indicated by an asterisk in paragraph 1. The inspectors

described the areas inspected and discussed in detail the inspection results.

A listing of inspection findings is provided.

Proprietary information is not

contained in this report. Dissenting comments were not received from the

licensee.

Type/Item Number Status

Description and Reference Paragraph

VIO 96-01-01

Open

AFW System Valve Misalignment (paragraph 2.3).

VIO 94-17-02

Closed

Failure to Correct Improperly Routed Instrument

Sensing Lines While Troubleshooting Repetitive

Gas -Binding of RHR Flow Indicator (paragraph

3.3.1).

LER 94-003-02

Closed

Technical Specification Required Shutdown Due to

Emergency Diesel Generator Inoperability

(paragraph 3.3.2).

LER 94-004-00

Closed

Auxiliary Building Outside Design Basis Due to

Positive Pressure Conditions (paragraph 4.2.1).

LER 94-006-00

Closed

Manual Reactor Trip Due to Electro-Hydraulic

System Oil Leak (paragraph 3.3.3).

LER 94-008-00

Closed

Condition Outside Design Basis Due to Control

Room HVAC Inoperability (paragraph 4.2.2).

LER 94-011-01

Closed

Technical Specification 3.0:

Emergency Diesel

Generator (EDG) Inoperability (paragraph 3.3.4).

LER 94-015-01

Closed

Technical Specification 3.0:

Emergency Diesel

Generator (EDG) Inoperability (paragraph 3.3.4).

VIO 93-10-01

Closed

Failure to Establish Adequate Procedures to

Verify Proper AMSAC Operation After

Microprocessor Replacement (paragraph 4.2.3).

IFI 93-10-02

Closed

Lack of Spare Parts Could Result in Prolonged

Unavailability of AMSAC (paragraph 4.2.4).

7.0

ACRONYMS

AFW

-

Auxiliary Feedwater

ALARA -

As Low As Reasonably Achievable

AMSAC -

ATWS Mitigation Actuation Circuitry

CFR

-

Code of Federal Regulations

CM

-

Corrective Maintenance

CP&L -

Carolina Power & Light Company

16

CR

-

Condition Report

CVCS -

Chemical and Volume Control System

ECCS -

Emergency Core Cooling System

EDG

-

Emergency Diesel Generator

E-H

-

Electro-Hydraulic

ESR

-

Engineering Service Request

FSAR -

Final Safety Analysis Report

ESF

-

Engineered Safety Feature

FT

-

Flow Transmitter

gpm

-

gallons per minute.

HVAC -

Heating Ventilation and Air Conditioning

HVE

-

Heating Ventilation Exhaust

HVS

-

Heating Ventilation Supply

I&C

-

Instrumentation & Control

IFI

-

Inspector Followup Item

LCO

-

Limiting Condition for Operation

LER

-

Licensee Event Report

LT

-

Level Transmitter

MDAFW -

Motor Driven Auxiliary Feedwater

MOV

-

Motor Operated Valve

OMM

-

Operations Management Manual

OP

-

Operating Procedure

OST

-

Operations Surveillance Test

PLP

-

Plant Program

,*

QC

-

Quality Control

RC

-

Radiation Control

RCA

-

Radiation Control Area

RHR

-

Residual Heat Removal

SP

-

Special Procedure

TDAFW -

Turbine Driven Auxiliary Feedwater

TM

-

Temporary Modification

TS

-

Technical Specifications

VIO

-

Violation

WR/JO -

Work Request/Job Order