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Insp Repts 50-413/85-26 & 50-414/85-21 on 850526-0625. Violation Noted:Failure to Follow Procedures While Performing Operating Evolutions
	ML20133F324
Person / Time
Site:	Catawba
Issue date:	07/16/1985
From:	Dance H, Skinner P, Van Doorn P; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20133F284	List: IR 05000526/2006025; ML20133F281; ML20133F324;
References
	50-413-85-26, 50-414-85-21, NUDOCS 8508080238
	Download: ML20133F324 (9)
	v • d • e

. p CEGO UNITED STATES

/ 'o NUCLEAR REGULATORY COMMISSION

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n REGION ll

r , j 101 MARIETTA STREET, N.W.

, ATLANTA, GEORGI A 30323

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Report Nos.: 50-413/85-26 and 50-414/85-21

Licensee: Duke Power Company

422 South Church Street

Charlotte, NC 28242

Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and CPPR-117

Facility Name: Catawba

Inspection Conducted: M 26 - June 25, 1985

Inspectors: _,_ r '

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P. K. V n Doo

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Approved by: -

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H. C. Dance, Section Chief

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Dite 91gned

Division of Reactor Projects

SUMMARY

Scope: This routine, unannounced inspection entailed 161 inspector-hours on site

in the areas of site tours (Units 1 and 2); followup of licensee identified items

(Units 1 and 2); safety-related pipe support and restraint systems (Unit 2);

maintenance observations (Unit 1); surveillance observations (Unit 1), review of

nonroutine events (Unit 1); plant operations review (Unit 1); and followup of

previous identified inspection findings (Unit 1).

Results: Of the eight areas inspected, no violations or deviations were

identified in seven areas; one apparent violation was found in one area (failure

to follow procedures while performing operating evolutions, paragraphs 9 and 10.

8508000238 85071s

PDR ADOCK 05000413

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REPORT DETAILS

1. Licensee Employees Contacted

J. W. Hampton, Station Manager

E. M. Couch, Project Manager

W. Allgood, Completion Engineer Electrical

H. L. Atkins, QA Engineering Supervisor

H. B. Barron, Operations Superintendent

S. G. Benesole, QA Engineer Hangers

B. F. Caldwell, Station Services Superintendent

J. W. Cox, Superintendent Technical Services

T. E. Crawford, Operations Engineer

L. R. Davison, Project QA Manager

J. R. Ferguson, Asst. Operating Engineer

C. L. Hartzell, Licensing and Projects Engineer

'G. D. Houser, QA Hangers Supervisor

C. S. Kelly, Instrumentation / Electrical Technical Support

J. A. Kinard, Technical Support Hangers

P. G. LeRoy, Licensing Engineer

C. E. Muse, Operating Engineer

G. T. Smith, Maintenance Superintendent

D. Tower, Operating Engineer

J. E. Whichard, Supervisor Electrical Technical Support

E. G. Williams, Project QA Technician

Other licensee employees contacted included construction craftsmen,

technicians, operators, mechanics, security force members, and office

personnel.

, * Attended exit interview.

2. Exit Interview

The inspection scope and findings were summar'ized on June 25, 1985, with

those persons indicated in paragraph 1 above. The violation and unresolved

item described in paragraphs 9 and 10 were discussed in detail. The

licensee acknowledged the findings and had no dissenting comments. The

licensee did not identify as proprietary any of the materials provided to or

reviewed by the inspectors during this inspection.

3. Licensee Action on Previous Enforcement Matters .

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a. (Closed) Unresolved Item 414/84-45-01: Separation between 600 Vac

Transformer 2ETXD and Safety-Related Raceway. The licensee has

thoroughly reviewed areas for situations where the general design

criteria of 1-inch separation has not been met. All instances found

including the one identified in the unresolved item were evaluated to

be not safety significant. The general clearance criteria has been

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added to the appropriate site specifications. Licensee actions are

considered satisfactory.

b. (Closed) Violation 414/84-46-01: Failure to Control Use of Teflon

Tape. Responses for this item were submitted on January 24, 1985 and

March 14, 1985. The inspector reviewed these responses and verified

implementation of corrective actions described in the responses- and

considers licensee actions to be acceptable.

c. (0 pen) Unresolved Item 413/85-20-01, 414/85-16-01: Verification of

Adequate Installation of Instrumentation. The inspector held i

discussions with appropriate site and design licensee personnel l

relative to whether operability of the instrument loops in question was l

attached. The opinion expressed was that operability was not .

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immediately affected. Further evaluation of this item is required.

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4. Unresolved Items *

New unresolved items are identified in paragraphs 6 and 10.d !

5. Independent Inspection Effort (92706) (Units 1 and 2)

The inspectors conducted tours of various plant areas. During these tours,

various plant. conditions and activities were observed to determine that they

were being performed in accordance with applicable requirements and

procedures. No significant problems were identified during these tours and

the various evolutions observed were being performed in accordance with

applicable procedures.

6. Safety-Related Pipe Support and Restraint Systems (50090)(Unit 2)

Supports and ' restraints were observed / reviewed to verify they were being

installed in accordance with various site QA and construction procedures.

The inspector verified that these procedures are being followed for

installation of supports / restraints in the areas of, as applicable,

conformance to applicable drawings, location, welds (size and location),

general physical condition, use of specified materials (size, type, etc.), ,

use of appropriate locking devices such as double nuts, concrete anchor '

bolts, cold setting, and inspections. The following completed supports were

observed:

c 2-R-SM-1582 (snubber, saddle), 2-A-NV-3406 (spring can),

l 2-E-NW-0001 (equipment support), 2-R-NI-1608 (snubber),

l 2-R-NC-0005 (snubber), 2-R-NC-1063 (spring can), 2-R-ND-0075

l -(fixed), 2-R-ND-0450 (spring can), 2-R-ND-473 (valve, fixed),

2-R-ND-0301 (snubber), 2-R-ND-0410 (sway strut, fixed),

2-R-ND-0017 (spring can) and 2-R-NI-1527 (fixed).

y * An Unresolved Item is a matter about which more information is required to

determine whether it is acceptable or may involve a violation or deviation.

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During this inspection, several apparent discrepancies were noted. These

involve two of the hangers inspected and two additional hangers observed

during the inspection. These discrepancies are as follows:

a. Angle between sway strut and clamp greater than 4 - support nos.

2-R-NI-1527, 2-A-KC-3351 and 2-A-KC-3898.

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b. Rod not supporting load - support no. 2-R-ND-473

c. Misorientation of end bracket support no. 2-R-ND-473

These discrepancies were documented on nonconforming Item Report Nos. 19732,

19742, and 19743. Design evaluation has shown these discrepancies to be

non-significant. The inspector reviewed these evaluations and considers

them acceptable. However, since the cause of the angle problems identified

! in a. above appears to be damage done after final inspection is completed,

further review of the controls in this area is needed. This review is

'necessary to determine if appropriate area walkdowns are planned to detect

these problems and if Nuclear Production Department personnel are appro-

priately trained to recognize these problems and take appropriate corrective

action. This is Unresolved Item 413/85-26-01, 414/85-21-01: Verification

of Adequate Control of Hanger Installation.

No violations or deviations were identified.

l 7. Maintenance Observation (62703)(Unit 1)

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t Station maintenance activities of selected systems and components were

, observed / reviewed to ascertain that they were conducted in accordance with

the requirements. The inspector verified licensee conformance to the

requirements in the following areas of inspection: (1) that the activities

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were accomplished using approved procedures, and functional testing and/or

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calibrations were performed prior to returning components or systems to

service; (2) quality control records were maintained; (3) that the

activities performed were accomplished by qualified personnel; and (4) parts

and materials used were properly certified. Work requests were reviewed to

determined status of outstanding jobs and to assure that priority is

assigned to safety-related equipment maintenance which may effect system

performance. Examples of these observations were work performed to clean

coolers for the safety injection (NI) and coolant charging (NV) pump motors,

safety-related batteries, and various minor maintenance to the safety-

related diesels.

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No violations or deviations were identified.

8. Surveillance Observation (61726)(Unit 1)

During the inspection period, the inspector verified plant operations were

in compliance with various Technical Specifications (TS) requirements.

Typical of these requirements were confirmation of compliance with the TS

for reactor coolant chemistry, refueling water tank, residual heat removal,

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control room ventilation, and direct current (DC) electrical power sources.

The inspector verified that surveillance testing was performed in accordance

with the approved written procedures, test instrumentation was calibrated,

limiting conditions for operation were met, appropriate removal and

restoration of the affected equipment was accomplished, test results met

requirements and were reviewed by personnel other than the individual

directing the test, and that any deficiencies identified during the testing

were properly reviewed and resolved by appropriate management personnel.

Typical of the surveillance items that were witnessed in part or in full

were various calibrations of portions of the nuclear instrumentation and

radiation monitoring systems, diesel generator operation, and in service

testing of various safety-related valves.

No violations or deviations were identified.

9. Review Of Licensee Nonroutine Event Reports (92700)(Unit 1)

The below listed Licensee Event Reports (LER) were reviewed to determine if

the information provided met NRC requirements. The determination included:

adequacy of description, verification of compliance with TS and regulatory

requirements, corrective action taken, existence of potential generic

problems, reporting requirements satisfied, and the relative safety signi-

ficance of each event. Additional inplant reviews and discussion with plant

personnel, as appropriate, were conducted for those reports indicated by an

asterisk (*). The following LERs are closed.

84-31 12/16/84 Diesel Generator 1B Automatic

Start During 6.9 kV Transfer Test

84-32, R1 12/19/84 Inoperable Fire Barrier Penetrations

85-3 01/09/85 Inadvertent Reactor Trip Breaker

Actuation During Testing

85-11 02/07/85 Both Trains of Safety Injection

Inoperable

85-15 03/02/85 Several Valve Motor Breakers Not

Locked Off

85-26 04/22/85 RN Swapover to Standby Pond

85-29 04/23/85 Installation Clearance Requirements

for the Vital Batteries

During the inspectors' review of LER 413/85-22, a violation of 10 CFR 50

Appendix B was identified. This LER remains open. LER 85-22 details the

inoperability of diesel generator (D/G) IB from 2200 hours0.0255 days 0.611 hours 0.00364 weeks 8.371e-4 months on March 7,1985

to 1930 hours0.0223 days 0.536 hours 0.00319 weeks 7.34365e-4 months on March 14, 1985; and the failure of DG 1A from 1330 hours0.0154 days 0.369 hours 0.0022 weeks 5.06065e-4 months to

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1700 hours0.0197 days 0.472 hours 0.00281 weeks 6.4685e-4 months on March 14, 1985. TS 6.8.1 and 10 CFR 50, Appendix B

Criterion V, as implemented by the Duke Power Company Quality Assurance

Program Topical Report (Duke-1-A) Section 17.2.5, requires activities

affecting quality to be prescribed by documented instructions procedures, or

drawings and to be accomplished in accordance with these instructions,

procedures, or drawings. The inspector identified several examples of

activities where procedures were inadequate or were not followed. This

violation is combined with the additional example discussed in paragraph

10.e and identified as Violation 413/85-26-02: Failure to Follow Procedures

Associated with LER 85-22 and Safety Injection pump operation. The

following is a listing of examples where the activities associated with this

LER are violations:

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a. On March 7, 1985, while performing PT/1/A/4350/02C, Available Power

Source Operability Check, although the PT allows verification by review

of the operating procedure, the operator noted the "DC Control Power

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On" light was not lit which is required by the initial conditions for

this PT. He assumed it was due to a faulty light bulb and continued

with the test without notifying the Shif t Supervisor of this problem.

This is a violation of: PT/1/A/4350/02C Step 8.1 which requires the DG

to be aligned for EC ictuation per OP/1/A/6350/02 (Diesel Generator

Operation) and specifies the "DC Control Power On" light is energized;

Station Directive (SD) 4.2.1, Development, Approval and Use of Station

Procedures, Revision 16, Section 10.0 which requires personnel to

adhere to procedures; and Operations Management Procedure (OMP) 1-4,

Use of Procedures, Section 8.1.D, which states that if the desired or

anticipated results are not achieved, the individual should not

proceed.

The operator's assumption was correct and he completed operation of

DG 18. However, subsequent to this operation, he attempted to replace

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the lights. The lights immediately went out upon insertion of the

bulbs into the sockets. He then notified the Unit Supervisors of this

problem. During post test ES lineup verification, the Unit Supervisor

instructed the operator to use an alternate means to verify DC control

power, a method which did not verify DC Control Power at the correct

location, and he did not change the procedure. This is a second

violaticn of OMP 1-4, Section 8.1.0. The operator then signed off step

15 of Enclosure 13.3 in PT/1/A/4350/02C which states DG 1B is aligned

for ES Actuation per OP/1/A/6350/02. This was a violation of this step

since the "DC Control Power On" light was not on as the procedure

specified. A second operator then performed an independent verifi-

cation that DG IB was aligned for ES Actuation per OP/1/A/6350/02.

This was a violation of SD 4.2.2, Independent Verification Require-

ments, Section 9.4.1, which requires personnel signing the documenta-

tion either perform or observe the action required by the procedure

step.

As a result of the action taken by the operator to replace the bulbs,

two circuit breakers supplying DC control power had tripped which

caused the DG to be inoperable at this time without the licensee being

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aware of its condition. It appears that had the appropriate procedtres

been followed, this condition would have been identified earlier,

b. During the inspector's review of documentation for this LER, several

documents could not be retrieved. These documents were copies of

operating procedures that were used to determine operability of DGs.

Only the latest copy was retained. Discussions with operations

personnel stated that OP/1/A/6350/02, Diesel Generator Operation, is

used in some instances to determine that the DG is operable following

work which must be tested but not to the extent that a complete

surveillance test is required by PT/1/A/4350/02. Since this OP is

being used to determine that the DG meets implied acceptance criteria,

even though no acceptance criteria is identified or recorded in the

operating procedure, the OP is required to be retained as a completed

record when used for this purpose. The Administrative Policy Manual

(APM) Section 4.2.7 provides the process for completed procedures which

involve documentation of compliance with procedure acceptance criteria.

The failure to maintain records of Operating Procedures that are used

to determine that a system / component is in compliance with acceptance

criteria is an example of a failure to follow procedures specified in

APM Section 4.2.7.

10. Plant Operations Review (Unit 1) (71707 and 71710)

a. The inspectors reviewed plant operations throughout the reporting

period to verify conformance with regulatory requirements, TS and

administrative controls. Control room logs, danger tag logs, TS Action

Item Log, and the removal and restoration log were routinely reviewed.

Shift turnovers were observed to verify that they were conducted in

accordance with approved procedures. The inspectors also verified by

observation and interviews, that measures taken to assure physical

protection of the facility met current requirements. Areas inspected

included the security organization, the establishment and maintenance

of gates, doors, and isolation zones in the proper condition, that

access control and badging were proper, and procedures followed. In

addition to the areas discussed above, the areas toured were observed

for fire prevention and protection activities. These included such

things as combustible material control, fire protection systems and

materials, and fire protection associated with maintenance and

construction activities.

b. USNRC Inspection and Enforcement Manual Temporary Instruction 2500/14

was issued May 8,1985, specifying required inspection of the location

of the manual trip circuit in Westinghouse designed plants with a Solid

State Protection System (SSPS). The temporary instruction (TI) was

issued to determine if the licensees are using controlled drawings that

depict correctly the actual location of the manual trip circuit and to

confirm that the manual' trip circuits are located downstream of output

transistors Q3 and Q4 in the undervoltage output circuit. The

inspector reviewed this area for Catawba Unit I and identified that the

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controlled drawings do correctly depict the location of the manual trip

circuit and that the manual trip circuits are located as discussed

above. Based on this review, the TI requirements have been met and are

considered acceptable. In addition, since Catawba Unit 2 has the same

system, this item is closed for Unit 2 also,

c. During this reporting period, a situation occurred that caused a

violation of the Action Statement for TS 3.6.5.5. This Action

Statement is for an equipment hatch between the containment's upper and

lower compartments and allows the hatch to be open for a maximum of 30

hours if in Modes 1, 2, 3, or 4. The utility was in the process of

attempting to locate a leak around the pressurizer impulse lines

utilizing a TV camera while in Mode 4. It was required to have the

leak pressurized to aid in the leak detection. When the utility

identified that the hatch would be opened in excess of 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , they

contacted the NRC to discuss leaving this hatch open rather than

closing it and reopening it for additional inspection. The plant had

been shutdown from the 111tial startup test program for maintenance

since April 19, 1985, so decay heat and fission inventory were of

minimum concern. After consultation with Region II management, a

decision was made to exercise discretionary enforcement authority and

not pursue enforcement action regarding the exceeding of TS 3.6.5.5 in

this specific case. Subsequently, the licensee's inspection detected

and corrected a leaking fitting on a pressurizer instrument line and

the equipment hatch was replaced at 4:45 a.m. on June 4, 1985,

d. While touring the auxiliary shutdown panel (ASP) room IB, the inspector

noted that ventilation to this room was secured. This ventilation

system is a required support system for the ASP and must be in

operation to assure that the ASP remains functional. The inspector

notified the Shift Supervisor (SS) of this problem. After investiga-

. tion the SS declared the ASP IB inoperable and took action to restore

the ventilation system to an operable status. Further review of this

area identified that there does not appear to be a mechanism to

identify what support systems are required to be functional or in

operation to insure that the main system will perform its intended

function. This area was discussed with the utility management and they

are reviewing this area. This will be identified as an Unresolved Item

(413/85-26-03: Identification of Support System Requirements), pending

completion and review by the inspector of the utility review of this

area,

e. On June 1,1985, Safety Injection (NI) Pump 1A was operated to fill

cold leg accumulators in accordance with operating procedures. This

pump should have been tagged out-of-service since maintenance was being

performed on the pump motor cooler and the pump oil cooler. This

resulted in the isolation of cooling water to this component. The

tagging process that was performed did not adequately tag the pump

switch or breaker. Station Directive 3.1.1, Safety Tags and Delinea-

tion Tags, Revision 11 Section 4.2.2 states that white safety tags

shall be attached to any component, the operation of which could cause

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material or equipment damage. The running of this pump without

adequate cooling water caused damage which required extensive repairs.

The failure to properly tag out NI pump 1A is an example of failure to

follow procedures as identified in paragraph 9, Violation 413/85-26-02.

11. Previously Identified Inspector Findings (92701)(Unit 1)

(Closed) Inspector Followup Item 413/85-05-01: Followup of Licensee Action

for Nonroutine Report No. C85-17. The corrective action taken as a result

of this event appears at this time to be sufficient to prevent a repeat of

this problem.

12. Licensee Identified Items 50.55(e) (99020)(Unit 2)

(Closed) CDP 414/84-22: Valve Operator Wiring Incompatible With External

Wiring. Reports for this item were submitted on November 21, 1984;

December 31, 1984; February 1, 1985; and March 1, 1985. The inspector

' reviewed these reports and verified implementation of corrective actions

identified in the reports and considers licensee actions to be acceptable.

(Closed) CDR 413/414/84-15: T-Drains Not Installed On Limitorque Motor

Operators. This item was previously closed in Report 50-413/84-04,

414/84-41. The licensee submitted an additional response on December 27,

1984, indicating that two additional valves were identified which required

modification. The inspector verified that the Unit i valve was corrected

and adequate controls are in place to assure that the Unit 2 valve is

corrected. Therefore, this item remains closed. 4

(0 pen) CDR 414/85-08: Overpressurization of the Residual Heat Removal (ND)

System. The inspector observed a portion of the liquid penetrant inspection ,

of the 28 ND heat exchanger and held discursions with licensee personnel

, relative to the status of the heat exchanger evaluations. No significant

problems appear to have been identified to date on 28. The 2A heat

exchanger remains to be inspected.

No violations or deviations were identified.

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ML20133F324

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