ML14191B032
| ML14191B032 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/09/1988 |
| From: | Fredrickson P, Garner L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14191B031 | List: |
| References | |
| 50-261-88-30, NUDOCS 8812200338 | |
| Download: ML14191B032 (10) | |
See also: IR 05000261/1988030
Text
RREG
UNITED STATES
WLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, NAN.
ATLANTA, GEORGIA 30323
Report No.:
50-261/88-30
Licensee:
Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC 27602
Docket No.:
50-261
License No.:
Facility Name:
H. B. Robinson
Inspection Conducted: October 11 - November 10, 1988
Inspector:
to
L. W. Garner,
nior
de
Inspector
Date Signed
Approved by:
//q
I 'g
Pr-P. E. Fredrickson, Section Chief
Oate Signed
Reactor Projects Section 1A
Division of Reactor Projects
SUMMARY
Scope:
This routine,
announced inspection was conducted in the areas of
operational safety verification, physical protection, surveillance
observation, maintenance observation, onsite followup of events at
operating power reactors and onsite review committee.
Results: A weakness was identified in the Operation Department's review for
applicable
Technical
Specification
action
statements -upon
determination of inoperable equipment, paragraph 7.a.
Within the areas inspected, no violations or deviations were
identified.
Four unresolved items were identified involving:
Improper setpoints of MCC-5 and MCC-6 feeder breakers,
paragraph 7.a.
-
HVH 1-4 penetration splices being non-EQ, paragraph 7.b.
- Declaration of an Unusual Event when shutdown by TS is determined,
paragraph 7.b.
-
Unreinforced masonry block wall, paragraph 7.c.
FDR
ADOCK 05000261
Q
D
REPORT DETAILS
1. Licensee Employees Contacted
R. Barnett, Maintenance Supervisor, Electrical
R. Chambers, Engineering Supervisor, Performance
- J. Curley, Director, Regulatory Compliance
C. Dietz, Manager, Robinson Nuclear Project Department
R. Femal, Shift Foreman, Operations
W. Flanagan, Manager, Design Engineering
W. Gainey, Support Supervisor, Operations
R. Johnson, Manager, Control and Administration
D. Knight, Shift Foreman, Operations
E. Lee, Shift Foreman, Operations
D. McCaskill, Shift Foreman, Operations
R. Moore, Shift Foreman, Operations
- R. Morgan, Plant General Manager
M. Page, Engineering Supervisor, Plant Systems
D. Quick, Manager, Maintenance
- D. Sayre, Senior Specialist, Regulatory Compliance
D. Seagle, Shift Foreman, Operations
- J. Sheppard, Manager, Operations
R. Steele, Shift Foreman, Operations
- H. Young, Director, Quality Assurance/Quality Control
Other licensee employees
contacted included technicians, operators,
mechanics, security force members, and office personnel.
NRC Resident Inspector
- L. Garner
- Attended exit interview on November 22, 1988.
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2.
Licensee Action on Previous Enforcement Matters (92702)
Not Inspected.
3.
Operational Safety Verification (71707)
The inspector observed licensee activities to confirm that the facility
was being operated safely and in conformance with regulatory requirements,
and that the licensee management control system was effectively dis
charging its responsibilities for continued
safe operation.
These
activities were confirmed by direct observations, tours of the facility,
interviews and discussions with licensee management and personnel,
2
independent verifications of safety system status and limiting conditions
for operation, and reviews of facility records.
Periodically, the inspector reviewed shift logs, operations records, data.
sheets, instrument traces, and records of equipment malfunctions to verify
operability of safety related equipment and compliance with TS.
Specific
items reviewed include control
room
logs, auxiliary logs,
operating
orders, standing orders, and equipment tagout records.
Through periodic
observations of work in progress and discussions with operations staff
members, the inspector verified that the staff was knowledgeable of plant
conditions;
responding properly to
alarm conditions;
adhering to
procedures and applicable administrative controls; and aware of equipment
out of service,
surveillance testing,
and maintenance activities in
progress. The inspector also observed that access to the control room was
controlled and operations personnel were carrying out their assigned
duties in an attentive and professional manner.
The control room was
observed to be free of unnecessary distractions.
The inspector performed
channel checks, reviewed component status and safety related parameters to
verify conformance with the TS.
During this reporting interval,
the inspector verified compliance with
selected LCOs. This verification was accomplished by direct observation
of monitoring instrumentation,
valve positions, switch positions,
and
review of completed
logs
and records.
Plant tours were routinely
conducted to verify the operability of standby equipment; assess the
general
condition of plant equipment;
and verify that radiological
controls, fire protection controls, and equipment tag out prodedures were
being properly implemented. These tours verified the absence of unusual
fluid leaks; the lack of visual degradation of pipe, conduit and seismic
supports; the proper positions and indications of important valves and
circuit breakers; the lack of conditions which could invalidate EQ; the
operability of safety related instrumentation; the calibration of safety
related and control instrumentation including area radiation monitors,
friskers and portal monitors; the operability of fire suppression and fire
fighting equipment; and the -operfability of 'emergency lighting equipment.
The inspector also verified that housekeeping wa's adequate and areas were
free of unnecessary fire hazards and combustible materials.
No violations or deviations were identified within the areas inspected.
4.
Physical Protection (71707)
In the course of the monthly activities, the inspector included a review
of the licensee's physical security program. The inspector verified by
general observation and interviews, that measures taken to assure the
physical protection of the facility met current requirements.
The
performance of various shifts of the security force was observed to verify
that daily activities were conducted in accordance with the requirements
of the security plan. Activities inspected included protected and vital
areas; access controls; searching of personnel, packages, and vehicles;
3
badge
issuance and retrieval; patrols; escorting of visitors;
and
compensatory measures.
No violations or deviations were identified within the areas inspected.
5. Monthly Surveillance Observation (61726)
The inspector observed certain surveillance related activities of safety
related systems and components to ascertain that these activities were
conducted in accordance with license requirements.
For the surveillance
test procedures listed below, the inspector determined that precautions
and LCOs were met, the tests were completed at the required frequency, the
tests conformed to TS requirements, the required administrative approvals
were obtained prior to initiating the tests,
and the testing was
accomplished by qualified personnel in accordance with an approved test
procedure. The inspector independently verified that the systems were
properly returned to service.
Specifically, the inspector witnessed/
reviewed portions of the following test activities:
o
OST-010 (revision 9) Power Range Calorimetric During Power Operation
The
test compares the power range neutron indications to. the
calculated thermal
power
as required by TS
Table 4.1-1.
The
inspector verified that the neutron indications were within accepted
tolerances and required no adjustments.
o
RST-001 (revision 29) Radiation Monitor Source Checks
The test is a channel functional test of the Radiation Monitoring
System monitors as required
by
TS Table 4.1-1.
The inspector
verified that for selected monitors the test procedure was performed
properly and the acceptance criteria was met.
No violations or deviations were identified within the areas inspected.
6. Monthly Maintenance Observation (62703)
The inspector observed several maintenance related activities of safety
related systems and components to ascertain that these activities were
conducted in accordance with approved procedures,
TS,
and appropriate
industry codes and standards.
The inspector determined that these
activities were not violating TS
LCOs and- that redundant components were
operable. The inspector also determined that activities were accomplished
by qualified personnel using approved procedures,
QC hold points were
established where required, required administrative approvals and tagouts
were obtained prior to work initiation, proper radiological controls were
adhered to, appropriate ignition and fire prevention controls were
implemented, replacement parts and materials used were properly certified,
and the effected equipment was properly tested before being returned to
service.
In particular, the inspector observed/reviewed the following
maintenance activities:
4
0 W/R 88-ALBM1 Replace HVH 1-4 Cable Splices
o
CM-309 (revision 4) Environmental Sealing Low Voltage Electrical
Splices
The inspector verified that the butt splices were performed in
accordance with the procedure. This included verification of proper
cleaning of the cable jacket, sufficient overlap of sleeve and cable
jacket, removal of rough edges, sealing of the ends as demonstrated
by adhesive flow, and proper inspection of installation by QC as
specified by attachments 8.3 and 8.4.
No violations or deviations were identified within the areas inspected.
7.
Onsite Followup of Events at Operating Power Reactors (93702)
a.
On October 5, 1988, during reconstitution of the design basis for the
electrical loading of safety related MCCs, the licensee discovered a
potential overload condition could exist under certain postulated
accident conditions.
A LOCA with offsite power available and the
loss of either MCC-5 or MCC-6 would result in the starting of standby
non-vital loads on the other MCC.
This starting of standby loads
would trip the feeder breaker to the operating
MCC,
thereby,
resulting in a loss of all 480 V safety related MCC power.
The
condition would not be expected to exist with the loss of offsite
power because the standby non-vital loads are stripped from the MCCs
under this condition in order to limit the loading on the EDGs.
Anticipated loads on MCC-5
and MCC-6 are 794 and 820 amps,
re
spectively. These loads could cause the feeder breakers to MCC-5 and
MCC-6 to trip, since the feeder breakers' trip setpoints are 800 amps
+/- 10%. In addition, the MCCs' continuous rating of 600 amps would
be exceeded.
While verification of the initial calculations were being performed,
the licensee implemented compensatory actions on October 6, 1988, to
lock out certain non-vital loads on MCC-5 and MCC-6 in order to limit
anticipated loads under the postulated scenario to less than 700
amps.
On October 10,
1988,
the potential setpoint problem was
confirmed and the event reported to the NRC in accordance with
10 CFR 50.72. Pending further review by the NRC of the circumstances
surrounding the event,
this is considered an
UNR:
Investigate
Circumstances Surrounding Improper Setpoints of MCC-5
and
MCC-6
Feeder Breakers (261/88-30-01).
On October
11,
1988, subsequent reviews of limiting components
identified that the feeder cables to MCC-6 from emergency bus E-2
were potentially undersized. In accordance with design standards the
derated cable ampacity for continuous duty was determined to be 474
amps.
A similar problem did not exist with MCC-5 because those
cables had been changed to a larger ampacity due to Appendix R
modifications.
Based
upon
engineering
judgement,
the
licensee
believed that refined calculations, with actual plant configurations
5
taken into account,-would demonstrate the acceptability of the MCC-6
feeder cables.
On
October 13,
1988, preliminary calculations
indicated a continuous duty ampacity of approximately 750
amps.
However, the licensee was informed by a consultant who was performing
similar independent calculations that the value was approximately 450
amps.
Based upon this information the licensee declared MCC-6
inoperable at 9:00 p.m., on October 13, 1988. On October 14, 1988, a
plant shutdown was commenced. The unit was placed in hot shutdown by
1:00 p.m.
that
same day and in cold shutdown at 9:45 a.m.
on
October 15, 1988.
Upon reaching cold shutdown,
MCC-6 was removed from service and the
cables were replaced.
'In addition, critical portions of MCC-5
and
MCC-6,
as well
as other safety related cables were physically
inspected for signs of overheating. None were found. The inspector
witnessed the replacement of the MCC-6 feeder cables and independ
ently inspected parts of MCC-5 and MCC-6.
No conditions effecting
operability were noted.
Subsequent calculations verified that the
continuous duty ampacity of the removed MCC-6 feeder cables had in
fact been adequate to assure MCC-6
operability.
Apparently,
a
miscommunication problem between the licensee and their consultant
had resulted in the consultant utilizing the incorrect plant
configuration. Even though this *was thought to be the case prior to
the shutdown,
plant management determined that it
was prudent to
shutdown and replace the cables.
The licensee issued JCO no.88-010 to address. the potential safety
significance of cable sizing of loads fed from MCC-5
and MCC-6.
Although some cables were determined to be undersized, the licensee
demonstrated that either a failure would not occur or would not
result in a safety problem. The inspector reviewed the JCO and had
no outstanding concerns.
The unit was returned to service at
3:45 p.m. on October 18, 1988.
On October 14, 1988, a review by a licensed operator on rotation into
the regulatory compliance group identified that on October 13,
at
9:00 p.m.,
the plant should have- declared a phase B containment
isolation valve inoperable when MCC-6 was declared inoperable.
This
automatic isolation valve, CC-735,
is associated with the reactor
coolant pumps' component cooling water return line from containment.
Consequently, it can not be shut when the reactor coolant pumps are
running.
PEP-101,
Initial Emergency- Actions, item 6, Loss of CV
integrity, requires an unusual event be declared if
one or more
automatic isolation valves are inoperable for greater than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />
and are not isolated or repaired. Thus in accordance with PEP-101,
an unusual event was declared at 11:06 a.m.,
on October 14,
1988.
The plant remained in an unusual event status until 9:45 a.m.
on
October 15,
1988,
when the unit was placed in cold shutdown.
Containment integrity is not required per TS when the unit is in cold
shutdown. The failure to identify that a containment isolation valve
6
was effected resulted in the unusual event being declared approxi
mately 11
hours late.
Additionally, TS 3.6.3 LCO was unknowingly
entered when the MCC was declared inoperable, but was not violated
in that the plant was in cold shutdown within 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of the
initial inoperability determination.
As stated above,
after the
fact, it
was proven that MCC-6 had been operable and declaration of
an unusual event had not been required.
Neverthelest,
it
is of
significant concern that all the relevant TS Action Statements and
regulatory requirements were not properly assessed by the operations
department personnel.
This is of significant concern because of the
long period of time that was available for review prior to declaring
MCC-6 inoperable (e.g. from October 5, 1988, when the operability of
MCC-6
came into question,
to October 13,
1988,
when
MCC-6
was
declared inoperable).
b.
Non-EQ Splices on Containment Fan Coolers
On October 27, 1988, while performing field verifications to resolve
documentation discrepancies,
it
was determined that the pigtail
splice to the penetrations for the containment fan coolers HVH 1-4
were not as expected. Engineering review and subsequent review by
the
PNSC determined that the splices were non-EQ and were
not
qualifiable.
The HVH 1-4
units were declared inoperable at
10:20 p.m.
Reactor
shutdown
was
commenced
from
91% power at
11:00 p.m.
Hot shutdown was obtained at 2:03 a.m.,
on October 28,
1988. HVH 1 and 3 were removed from service and the splices upgraded
to be in conformance with a qualified configuration.
The inspector
verified that the repairs were performed in accordance with approved
procedures. These units were returned to service at 1:16 a.m.
on
October 29,
1988.
HVH 2 and 4 were then removed from service,
upgraded, tested, and declared operable at 10:36 a.m.
on the same
day. Reactor startup was commenced at 4:39 p.m.
and the generator
synchronized to the grid at 5:46 p.m., on October 29, 1988.
The reason why the Cruise-Hinds supplied penetration splices on power
cables were
not replaced with an
EQ configuration during the
August 1987 shutdown to upgrade Cruise-Hinds supplied penetration
splices for instrumentation cables in not
known at this time.
Pending further inspection, this item is considered an UNR:
Review
Circumstances Surrounding HVH 1-4 Penetration Splices Being Non-EQ
(261/88-30-02).
During review of the event, the inspector questioned if
an unusual
event should have
been declared
per PEP-101,
Initial Emergency
Actions. Item 1 of Attachment 9.1 to the PEP requires an unusual
event be declared upon "violation of any limiting condition for
operation
requiring
shutdown
....
Preliminary
discussions
with regional specialists in this area indicates that the intent
of these words is that if
a shutdown is required per
(e.g.,
if
an
LCO cannot be satisfied because of circumstances in
excess of those addressed,
place the unit in hot shutdown within
7
eight hours) then an unusual event is to be declared.
However, the
licensee indicates that it
has always been their position that
violation of a LCO has meant not meeting the time limitation (e.g.,
eight hours to be in hot shutdown).
The licensee also polled other
utilities within Region II and determined that there is no consistent
practice of declaring an unusual event involving shutdowns due to TS 3.0 type statements.
Furthermore, the
licensee provided the
inspector a draft final report,
Methodology
For Development of
Emergency Action Levels,
by the Nuclear Management
and Resource
Council which documents an industry initiative to standardize this
practice in a fashion similar to the licensee's position.
Pending
further review by the NRC, this item is considered an UNR:
Determine
If a Shutdown per TS 3.0 Requires Declaration of an Unusual Event
(261/88-30-03).
c. AFW Hanger Attached to An Unreinforced Block Wall
On November 2, 1988, while drilling into a wall for pre-outage work,
the licensee determined that wall penetration no. P4 in the AFW pump
room had been filled with unreinforced masonry block.
One brace of
AFW hanger no.
FW-2-136 was determined to be attached to this wall.
This is the first seismic support from the B MDAFW pump discharge
nozzle. Subsequent analysis indicated that this block wall could
fail. under lateral compressive loads during a seismic event. Such a
failure could potentially render the support inoperable. A design
change notice was issued to existing modification no.
937 to add
additional support members and remove the effected brace from the
hanger. Upon notification of the inoperable hanger, the B MDAFW pump
was declared inoperable in accordance with TS 3.4.4.6 at 5:29 p.m.,
on November 3, 1988.
The system was returned to service at
9:35 p.m.,
on November 5, 1988,
after final QC inspection of the
modified support.
The inspector verified that the redundant AFW
pumps were operable in accordance with TS during this period.
The
licensee is submitting a special report to the NRC concerning this
event. Pending further review by the NRC, this item is considered an
UNR:
Review special report and related corrective actions regarding
unreinforced..masonry block wall (261/88-30-04).
No violations or deviations were identified within the areas inspected.
8. Onsite Review Committee (40700)
The inspector evaluated certain activities of the PNSC to determine
whether the onsite review functions were conducted in accordance with TS
and other regulatory requirements. In particular, the inspector attended
a PNSC meeting on October 27,
1988, concerning non-qualified splices to
containment cooling fans HVH 1-4. It was ascertained that provisions of
the TS dealing with membership,
review process, frequency, and qualifi
cations were satisfied. Previous meeting minutes were reviewed to confirm
that decisions and recommendations
were accurately reflected in the
minutes.
8
No violations or deviations were identified within the areas inspected.
9. Exit Interview (30703)
The inspection scope and findings were summarized on November 22,
1988,
with those persons indicated'in paragraph 1. The inspector described the
areas inspected and discussed in detatl the inspection findings listed
below, as well as the NRC concern over the exhibited weakness in identi
fying the applicable TS action statement upon declaring MCC -6 inoperable.
In addition, the identification of UNR 261/88-30-04 was discussed with the
licensee on December 9, 1988. Dissenting comments were not received from
the licensee. Proprietary information is not contained in this report.
No written material was given to the licensee by the Resident Inspector
during this report period.
Items Numbers
Status
Description/Reference Paragraph
88-30-01
Open
UNR -
Investigate Circumstances
Surrounding Improper Setpoints of MCC-5
and -6 Feeder Breakers. Paragraph 7.a.
88-30-02
Open
UNR -
Review Circumstances Surrounding
HVH 1-4
Splices
Being
Non-EQ. Paragraph 7.b.
88-30-03
Open
UNR -
Determine
If
a Shutdown
per
Requires Declaration
of an
Unusual Event. Paragraph 7.b.
88-30-04
Open
UNR -
Review
Special
Report and
Related Corrective Actions Regarding
Unreinforced
Masonry
Block
Wall.
Pararaph 7.c.
10.
List of Abbreviations
CFR
Code of Federal Regulations
Corrective Maintenance
Carolina Power & Light
CV
Containment Vessel
Environmental Qualifications
HVH
Heating Ventilation Handling
JCO
Justification For Continued Operation
LCO
Limiting Condition for Operation
Loss of Coolant Accident
Motor Control Center
Motor Driven Auxiliary Feed Water
NRC
Nuclear Regulatory Commission
9
OMM
Operations Management Manual
OST
Operations Surveillance Test
PEP
Plant Emergency Procedure
PNSC
Plant Nuclear Safety Committee
Quality Control
TS
Technical Specification
- UNR
Unresolved Item
W/R
Work Request
- Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or deviations.