ML14191B099

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Insp Rept 50-261/89-03 on 890111-0210.Violations Noted.Major Areas Inspected:Operational Safety Verification,Physical Protection,Surveillance Observation,Maint Observation,Esf Sys Walkdown & Onsite Review Committee
ML14191B099
Person / Time
Site: Robinson 
Issue date: 03/10/1989
From: Dance H, Garner L, Jury K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14191A976 List:
References
50-261-89-03, 50-261-89-3, NUDOCS 8903300247
Download: ML14191B099 (11)


See also: IR 05000261/1989003

Text

HE

-

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION

.

101 MARIETTA STREET, N.W.

ATLANTA, GEORGIA 30323

Report No.:

50-261/89-03

Licensee:

Carolina Power and Light Company

P. 0. Box 1551

Raleigh, NC 27602

Docket No.:

50-261

License No.: DPR-23

Facility Name: H. B. Robinson

Inspection Conducted: January 11 -

February 10, 1989

Inspector:

C

.

L. W. Garner, Sehior Resident Inspector

0 e igned

K. R Jury, Resident Inspector

ate

igned

,Approved by:

.14

-rU

H. C. Dance, Section Chief

te

igned

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, ESF system walkdown, and onsite

review committee.

Results:

One violation for which a Notice of Violation is being issued was

identified concerning failure to properly implement surveillance

procedure OST-162, paragraph 3.c.

The failure resulted from

improperly controlling the OST-162 test configuration valve lineup

while

performing the

valve

restoration, lineup

portions of

-surveillance procedure OST-163.

Two licensee identified violations (no Notices of Violation are being

issued)

involving failure to follow procedures are discussed in

paragraphs 2 and 3.c.

The first violation involved an operator

verifying a circuit breaker associated with instrument bus 3 as being

ON when it was actually in the OFF position. The inspectors observed

a second operator discover this fact while he was performing

independent verification activities. The method and conditions under

which this alignment is performed is considered awkward and prone to

human error,

and is being reviewed by the licensee.

The second

violation involved an operator failing to restart safety-related

89033C)027 890310

PDR

ADOCK

0/0002C1:,f

2

battery charger A in accordance with procedure OP-601.

Failure to

open the A battery charger output breaker prior to re-energizing the

battery charger resulted in degraded mode operation. In addition, a

failure to utilize redundant indications was observed (i.e.,

the

operator failed to notice the battery charger was malfunctioning).

He only relied on an indicator lamp to verify the battery charger was

inservice, when other readily available indications revealed it

was

not performing correctly.

A potential

need to provide refresher training to control room

operators on certain auxiliary operator evolutions is discussed in

paragraph 3.c. A licensed operator was observed not being familiar

with manually closing a DB-50 breaker during a surveillance test.

The licensee demonstrated a high degree of responsiveness to and

cooperation with the inspectors in resolving a concern with the

seismic qualification of the DB-50 breakers, paragraph 3.c.

The licensee has expended a substantial effort during the refueling

outage to improve housekeeping.

The improved CV conditions are

especially noteworthy, paragraph 2.

REPORT DETAILS

1. Licensee Employees Contacted

R. Barnett, Maintenance Supervisor, Electrical

R. Chambers, Engineering Supervisor, Performance

P. Crocker, Supervi-sor, Radiation Control

J. Curley, Director, Regulatory Compliance

C. Dietz, Manager, Robinson Nuclear Project Department

R. Femal, Shift Foreman, Operations

W. Flanagan, Manager, Des ign Engineering

W. Gainey, Support Supervisor, Operations

P. Harding, Project Specialist, Radiati.on Control

E. Harris, Director, Onsite Nuclear Safety

R. Johnson, Manager, Control and Administration

D. Knight, Shift Foreman, Operations

D. McCaskill, Shift Foreman, Operations

R. Moore, Shift Foreman, Operations

  • R. Morgan, Plant General Manager

M. Page, Acting Manager, Technical Support

D. Quick, Manager, Maintenance

  • D. Sayre, Senior Specialist, Regulatory Compliance

D. Seagle, Shift Foreman, Operations

  • J. Sheppard, Manager, Operations

R. Steele, Operating Supervisor, Operations

  • H. Young, Director, Quality Assurance/Quality Control

Other licensee employees contacted included technicians,

operators,

mechanics, security force members, and office personnel.

NRC Resident Inspectors

  • L. Garner
  • K,. Jury
  • Attended exit interview on February 15, 1989.

Acronyms and initialisms used throughout this report are listed in the

last paragraph.

2.

Operational Safety Verification (71707)

The inspecto rs observed licensee activities to confirm the facility was

being operated safely and in conformance with regulatory requirements, and

that the licensee's management control system was effectively discharging

its responsibilities for continued safe operation. These activities were

confirmed- by direct observations,

facility tours,

interviews and

discussions with

licensee

management

and

personnel,

independent

verifications of safety system

status

and

limiting conditions for

0

operation, and reviews of facility records.

2

Periodically, the inspectors 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 inspectors verified that the staff was knowledgeable of

plant conditions; responding properly to alarm conditions; adhering to

procedures and applicable administrative controls; aware of equipment out

of service;

and cognizant of surveillance testing and maintenance

activities in progress. The inspectors observed shift changes to verify

that continuity of system status was maintained and that proper control

room staffing existed. The inspectors 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.

On January 27,

1989,

the inspectors observed independent verification

activities required by OP-001,

Reactor Control and Protection System, to

place the reactor protection

system in service.

During the

second

operator check,

it

was'discovered that circuit breaker

no.

17 on

instrument bus 3 was in the OFF position and had not been noted by the

first operator

as being in the OFF position.

OP-001 requires all

non-spared breakers to be turned ON or noted as being out of position if

under clearance. This breaker was labeled as being a supply to the fixed

incore neutron monitors and had no clearance tag on it. Subsequently, the

inspectors were informed by the licensee that the breaker had been spared

more than ten years earlier. The failure of the first operator to perform

OP-001 correctly is considered to be a violation:

Failure to Follow

Procedure OP-001, LIV (261/89-03-01). This violation meets the criteria

specified in-

Section V of the NRC Enforcement Policy for not issuing a

Notice of Violation and is not cited.

The inspectors determined that the method

used by the licensee to

determine which breakers are spares is awkward and readily lends itself

to human error.

SD-16,

Electrical Systems,

is the document used by

operations

personnel *to determine which

breakers supply vital and

safety-related instrumentation.

SD-16 incorrectly describes circuit

breaker 17 as being in-service even though it had previously been spared

by a plant modification.

The need

was discussed with the Operations

Manager to upgrade the methodology for verifying correct instrument bus

breaker alignment to include human factor considerations and the concern

over the accuracy of SD-16. The Operations Manager indicated that these

items would be reviewed and a determination made on what actions, if any,

will be taken.

On January 30, 1989, the inspectors conducted a general tour of the CV in

anticipation of a restart from the 1988 refueling outage. The inspectors

visually verified that safety-related equipment such as the containment

fan coolers,

PZR PORVs,

accumulators,

and major valves were operable

3

and/or aligned for service as required

by plant conditions.

The

inspectors observed that the substantial effort during the outage to

improve the overall site cleanliness and housekeeping had resulted in

significant improvements inside the CV. Though additional future measures

will be necessary to stay in line with evolving industry norms,

the

licensee has improved

CV

housekeeping from marginally adequate (as

discussed in the most recent SALP report) to good, and in some areas

outstanding.

Minor conditions observed during the tour were reported to

the licensee for correction as they deemed necessary.

The inspectors verified by general observation, perimeter walkdowns, and

interviews that measures taken to assure the physical protection of the

facility met current requirements.

The performance of various security

force shifts 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 and packages, badge issuance and retrieval,

patrols,

escorting of visitors, and compensatory measures.

In addition, the

inspectors routinely observed protected and vital .area

lighting and

barrier integrity.

One licensee identified violation was identified within the areas

inspected.

3. Monthly Surveillance Observation (61726)

The inspectors observed certain surveillance 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 inspectors 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

and tagouts were obtained prior to initiating the tests, the testing was

accomplished by qualified personnel in accordance with an approved test

procedure, and the required test instrumentation was properly calibrated.

Specifically, the inspectors witnessed/reviewed portions of the following

test activities:

a. EST-048 (revision 6), Control Rod Drop Test

The inspectors verified that the test was performed in accordance

with the procedure.

b.

EST-049 (revision 3), Rod Drive Mechanism Operation Testing

The inspectors witnessed performance of the test and verified that

TS, prerequi.stes, and other limitations were complied with.

c. OST-162 (revision 12), Emergency Diesel Generator Auto Start On Loss

of Power And Safety Injection - Emergency Diesel Trips Defeat

4

The inspectors witnessed and reviewed selected parts of the subject

test on January 24 and 25,

1989.

While verifying that the initial

test configuration was in conformance with that specified in the OST,

the inspectors noted that BIT inlet valves SI-867 A and B indicated

OPEN on the RTGB, whereas steps 7.1.7.1. and 7.1.7.2 of the the OST

had been initialed that they were in the CLOSED position.

This

discrepancy was discussed with the test coordinator and the valves

were positioned in accordance with the OST.

The partial performance

of the restoration section of OST-163, Safety Injection Test, and the

initial lineup for OST-162 had not been coordinated properly.

This

allowed performance of OST-163 to position the valves in a different

position than required by OST-162.

This failure to control the

evolutions properly is considered to be indicative of a weakness in

procedure utilization.

This was discussed with the Operations

Manager and during the exit on February 15,

1989.

The failure to

establish the proper test configuration in accordance with OST-162 is

considered a violation: Restoration Lineup of OST-163 Results in BIT

Inlet Valves Being in a Position Other-Than That Established For

Performance of OST-162 (261/89-03-02).

During performance of OST-162,

the A battery charger tripped on

undervoltage as designed and had to be manually restarted.

The

inspectors observed two unsuccessful attempts to restart the battery

charger. On the first attempt, the supply breaker to the battery

charger tripped and the battery charger failed to restart. On the

second attempt, a red ON

lamp illuminated.

Upon indication of a

restart (i.e., the red light) the operator immediately exited the

area to continue to perform other steps of OST-162.

Inspection of

the battery charger revealed that the output ammeter was pegged

downscale.

Furthermore,

the A DC

bus ammeter indicated that the

battery was still carrying the

DC bus and the bus voltage was

observed to be 122 volts (.i.e., the battery terminal voltage).

The

bus voltage is normally 130 volts or more if the battery charger is

functioning correctly. These abnormal indications were reported to

the operator. The battery charger was secured and the backup battery

charger A-1 was placed in service. Subsequent review by the licensee

revealed that the operator had attempted to re-energize the battery

charger with its output breaker closed.

The voltage regulating

circuit was unable to function correctly under these conditions.

Subsequent inspection and testing indicated that operation in a

malfunctioning state for approximately five minutes had not damaged

the battery charger. The licensee also identified that a procedure

revision to OP-601, DC Supply System, issued and effective on January

24,

1989,

provided a section with instructions requiring opening of

the output breaker prior to re-starting the battery charger.

This

section was not previously in the procedure.

Failure to follow

OP-601 is considered a violation:

Failure To

Follow Procedure

OP-601, LIV (261/89-03-03).

This violation meets the criteria

specified in Section V of the NRC Enforcement Policy for not issuing

a Notice of Violation and is not cited.

5

Of greater significance, was that the operator failed to observe the

abnormal battery charger ammeter indication, and walked past the DC

bus voltmeter and ammeter without looking at them.

As described by

the operator, he was in a hurry to complete subsequent steps of the

OST.

Since the operator had experienced trouble restarting the

battery charger, reliance on a singular indication without taking the

time to observe readily available redundant indication is considered

poor operator performance. This was discussed with the Operations

Manager and with plant management during the exit on February 15,

1989.

During the first SI signal simulation of OST-162, both the C SIP and

HVH-3

CV Fan Cooler failed to start.

The inspectors had observed

that the HVH-3 breaker had closed,,but instantaneously tripped open.

Two attempts to manually initiate the C SIP from the RTGB also had

similiar results. Subsequent SI signals resulted in the breakers

successfully closing even though no work had been performed on them.

This was discussed with operations personnel. It was explained that

this is a frequent occurrence after a DB-50 breaker has been racked

out. Sometimes, the breaker is slightly misaligned when it is racked

back in. A closing/tripping action will sometimes reposition the

breaker sufficiently such that it becomes correctly aligned without

having to rack it

out and

back in again.-

Because of this ,

phenomenon, it has been the operations department's practice to cycle

DB-50 breakers twice upon returning them to service.

However, this

testing sequence did not require it.

The licensee is considering

adding appropriate steps to test procedures such as OST-162 to cycle

the breakers prior to the OST performance.

The inspectors verified

that for the SIPs and the CV spray pumps,

GP-002 revision 36, Cold

Solid to Hot Subcritical at No Load TAVG,

contains steps to start

these pumps.after the pump breakers have been racked in.

The inspectors were concerned that if

vibration could align the

breakers, perhaps vibration could unalign them, especially during a

seismic event. The licensee examined the subject compartments for

proper dimensions and clearance. Only normal wear was observed. The

licensee was able to duplicate the condition and determined that once

the alignment corrected itself the breaker would remain in that

configuration.

On January 30,

1989,

the licensee demonstrated for

the inspectors that when racking the breaker in, it

might appear to

be fully in, but the trip tab on the cabinet can still be in contact

with the trip bar. This contact supplies enough pressure on the trip

bar to cause the breaker to immediately trip when an attempt is made

to close it. When the breaker vibrates due to a close/trip pumping

action, it

falls fully down into an engagement slot.

In that

condition, the vendor stated clearance exists between the cabinet

trip tab and the breaker trip bar. The inspectors concurred with the

licensee's determination that once properly aligned a breaker would

remain properly aligned.

6

During the performance of OST-162 step 7.3.28, the operator is

required to manually close B SIP breaker 52/29C.

The licensed

operator performing the test contacted the control room to have

someone explain how to accomplish this task.

Another licensed

operator came and demonstrated how to manually close this particular

style of breaker.

The inspectors discussed with the Operations

Manager that this may indicate a need to supply refresher training to

licensed operators.on certain auxiliary operator tasks which they may

not have performed in several years.

Because the above OST-162 performance was unsuccessful, appropriate

portions were re-performed on January 25,

1989.

The inspectors

reviewed the completed test packages and verified that the acceptance

criteria were met.

d.

OST-163 (revision 9) Safety Injection Test

The inspectors witnessed successful completion of the test from the

control room.

The inspectors verified the equipment responded as

expected to a simulated SI signal.

One violation and one LIV was identified within the areas inspected.

4. Monthly Maintenance Observation (62703)

The inspectors observed several maintenance 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 inspectors determined that these activities

were not violating LCOs and that redundant components were

operable

when applicable.

The inspectors also determined that: activities were

accomplished by qualified personnel using approved procedures; required

administrative approvals

and

tagouts were

obtained prior to work

initiation; appropriate ignition and fire prevention controls were

implemented; and the effected equipment was properly tested before being

returned to service. In particular, the inspectors observed/ reviewed the

following maintenance activities:

o

WR/JO 89-ABQS1 -

Repair purge inlet outboard isolation valve seal

o

WR/JO 89-ABLW1

-

Repair A EDG cooling water high temperature trip

circuit

No violations or deviations were identified within the areas inspected.

5.

ESF System Walkdown (71710)

On February 10,

1989, the inspectors performed a partial walkdown of the

AFW system. In particular, the inspectors examined portions of the SDAFW

discharge line and steam line.- The inspectors discovered valve V2-14B's

motor operating when the valve was closed.

Valve V2-14B is the SDAFW

7

injection valve to B S/G. The condition was reported to the control room

and the valve was cycled successfully opened and closed.

Subsequent to

this report period,

the licensee determined that the problem was an

'

isolated event. Disassembly of the actuator revealed that during the last

overhaul in 1986,

the fork assembly associated with the declutching

mechanism had been installed backwards.

This allowed the drive dogs to

only partially engage.

Due to wear on the dogs and partial engagement,

the drive assembly had degraded to the point that the dogs would not

consistently engage when

being driven in the close direction.

The

licensee verified that the overhaul procedure in 1986,

CM-113,

SMB-000,

SMB-00 and SB-00 Motor Operator Overhaul,

revision 0, contained specific

directions and a diagram

addressing the proper orientation during

reassembly. The licensee inspected V2-14A and C, as well as two other

valves overhauled in 1986.

These four valves had been overhauled under

the same supervision as V2-14B. No other problems were discovered. The

inspectors concur that the V2-14B misassembly was most likely an isolated

error.

No violations or deviations were identified within the areas inspected.

6. Onsite Review Committee (40700)

The inspectors 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 inspectors attended

the refueling outage pre-startup PNSC on January 27, 1989. During this

meeting existing JC~s were reviewed for continual applicability, and two

new JCOs were approved.

It

was ascertained that provisions *of the TS

dealing with membership,

review process,

and qualifications were

satisfied.

The inspectors also followed up

on selected previously

identified PNSC activities to independently confirm that corrective

actions were progressing satisfactorily.

No violations or deviations were identified within the areas inspected.

7.

Licensee Action on Previously Identified Inspection Items (92701)

(Open) URI 88-24-05, Service Water Flow Analysis To Show Adequacy of Flows

to Safety-Related Components

Inspection Report 261/88-38 addressed measured

SW flows to. certain

components being less than recommended by the vendor and/or per design.

The licensee's resolution of these discrepancies is as follows:

Components

Resolution

A and B EDG Hx (maximum 8%

EE-89-019 calculation

low flow)

demonstrated that reduced

heat transfer due to less SW flow

was bound by 10% Hx tube plugging

allowed by the vendor.

8

Components

Resolution

(cont'd)

HVH 1-4 motor cooler

Analysis documented in DCN 858-22

(maximum 20% low flow)

shows coolers remain operable for

up to 24% reduced flow.

EST-102

is being

written

to perform

quarterly

surveillance on

flow

rates.

SDAFW pump lube oil cooler

Cooler cleaned to remove fouling.

(33% low flow)

AO required once per shift to

flush system.

A and B MDAFW pump lube

Coolers cleaned. AO required

oil cooler (maximum 100%

once per shift to flush system.

low flow)

Values still 16% below UFSAR

Values.

SP-808 demonstrated lube

oil temperature limit specified by

vendor

(140

degrees F) is not

exceeded with reduced flow.

The inspectors reviewed EE-89-019

and EE-89-022 which evaluates the

results of the flow test conducted per SP-814. The inspectors agree that

the above described items have been satisfactorily addressed.

No violations or deviations were identified within the areas inspected.

8.

Exit Interview (30703)

The inspection scope and findings were summarized on February 15,

1989,

with those persons indicated in paragraph 1. The inspectors described the

areas inspected and discussed in detail the inspection findings listed

below and those addressed in the report summary. 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 Inspectors during this report period.

Item Number

Status

Description/Reference Paragraph

88-24-05

Open

URI - Service Water Flow Analysis to

Show

Adequacy of

Flows to Safety

Related Components (paragraph 9)

89-03-01

Closed

LIV - Failure To Follow Procedure

OP-001 (paragraph 2)

89-03-02

Open

VIO - Restoration Lineup of OST-163

Results in BIT Inlet Valves Being in a

Position Other Than That Established

For OST-162 (paragraph 3.c)

9

Item Number

Status

Description/Reference Paragraph

(cont'd}

89-03-03

Closed

LIV -

Failure to Follow Procedure

OP-601 (paragraph 3.c)

9.

List of Abbreviations

AFW

Auxiliary Feedwater

AO

Auxiliary Operator

BIT

Boron Injection Tank

CFR

Code of Federal Regulation

CM

Corrective Maintenance

CV

Containment Vessel

DC

Direct Current

DCN

Design Change Notice

EDG

Emergency Diesel Generator.

EE

Engineering Evaluation

ESF

Engineered Safety Feature

EST

Engineering Surveillance Test

GP

General Procedure

Hx

Heat exchanger

HVH

Heating Ventilation Handling

JCO

Justification For Continued Operation

LCO

Limiting Condition for Operation

LIV

Licensee Identified Violation

MDAFW

Motor Driven Auxiliary Feedwater

NRC

Nuclear Regulatory Commission

OP

Operating Procedure

OST

Operations Surveillance Test

PNSC

Plant Nuclear Safety Committee

PORV

Power Operated Relief Valve

PZR

Pressurizer

QC

Quality Control

RTGB

Reactor Turbine Generator Board

SALP

Systematic Assessment of Licensee Performance

SD

System Description

SDAFW

System Driven Auxiliary Feedwater

SI

Safety Injection

SIP

Safety Injection Pump

SP

Special Procedure

SW

Service Water

TAVG

Temperature, Average

TS

Technical Specification

URI

Unresolved Item*

VIO

Violation

WR/JO

Work Request/Job Order

  • Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or deviations.