ML20153C545
| ML20153C545 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/19/1988 |
| From: | Lesser M, Peebles T, Van Doorn P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20153C521 | List: |
| References | |
| 50-413-88-25, 50-414-88-25, NUDOCS 8809010174 | |
| Download: ML20153C545 (11) | |
See also: IR 05000413/1988025
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UNITED STATES
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NUCLEAR REGULATORY COMMIS210N
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REGION ll
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101 MARf ETTA STREET, N.W.
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ATL ANTA, GEORGI A 30323
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Report Nos. 50-413/88-25 and 50-414/88-25
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Licensee: Duke Power Cc:npany
422 South Church Street
Charlotte, N.C.
28242
Docket Nos.: 50-413 and 50-414
License Nos.: NPF-35 and NPF-52
Facility Name: Catawba 1 and 2
Inspection Conducted: June 26, 1988 - July 25, 1988
Inspectors:,
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'P. K. Van 00 rn
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Date/ Signed
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Approved by:
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T % Pebbles, Section Chief
D' ate Signed
Projects Branch 3
Division of Reactor Projects
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SUMMARY
Scope:
This routine, resident inspection was conducted on site inspecting in
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the areas of review of plant operations; surveillance observation;
maintenance observation; review of licensee nonroutine event reports;
followup of previously identified items; and followup of NRC
Bulletins.
Results: The inspection findings indicate a weakness in the management of
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Technical Specification compliance.
A strength was noted in the
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establishment and use of an on-site design engineering staff.
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second strength was noted in the establishment of station specific
performance indicators with specified goals.
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In the areas inspected, the following violations were identified:
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Failure to maintain two operable channels of valve position
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indication for PORY F: lock Valves (para. 7.c)
Inoperability of containment purge valves due to use of fused
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jumperr (para. 6.b).
This violation is classified as a Licensee
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IdentifiedViolation(L!V).
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
H. B. Barror,, Operations Superintendent
W. F. Beaver, Performance Engineer
W. H. Bradley, QA Surveillance
- R. N. Casler, Unit 1 Coordinator
R. H. Charest, Station Chemistry Supervisor
T. E. Crawford, Integrated Schedultng Superintendent
W. P. Deal, Health Physics Supervisor
R. M. Glover, Compliance Engineer
- T. P. Harrall, Design Engineering-
F. N. Mack, Project Services Engineer
W. W. McCollough, Mechanical Maintenance Supervisor
- W. R. McCollum, Staticn Services Superintendent
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C. E. Muse, Unit 2 Coordinator
- T. B. Owen, Station Manager
- C. T. Smith, Maintenance Superintendent
J. M. Stackley, 1, & E. Envineer
D. Tower, Shift Operating Engineer
R. /. Wardell, Technical Services Superintendent
- R. Whit 6, CSRG Chairman
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J. W. Willis, Senicr QA Engineer, Operations
Other licensee employees contacted included technicians, operators,
mechanics, security force members, and office personnel.
NRC Resident inspectors
- P. K. Van Doorn
- M. S. Lerser
- Attended exit interview.
2.
Unresolved Items
An Unresolved Item is a matter about which more information is required to
determine whether it is acceptable or may involve a violation. There were
no unresolved items identified in this report.
3.
Plant Operations Review (71707 cnd 71710)
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a.
The inspectors reviewed plant operations throughout the reporting
period to verify conformance with regulatory requirements. Technical
Specifications (TS), and administrative controls. Control room logs,
danger tag logs, Technical Specification Action Item t.og, and the
removal and restoration log were routinely reviewed.
Shift turnovers
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were observed to verify that they were conducted in accordance with
approved procedures.
The inspectors verified by observation and interviews, that the
measures taken to assure physical protection of the facility met
current requirements.
Areas inspected included the security
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organization; the establishment and maintenance of gates, doors, and
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isolation zones in the proper conditions; and that access control and
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badging were proper and procedures followed.
In addition to the areas discussed above, the areas toured were
observed for fire prevention and protection activities.
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included such things as combustible material control, fire protection
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systems and materials, and fire protection associated with
maintenance activities.
The inspectors reviewed Problein
Investigation Reports to determine if the licensee was appropriately
documenting problems and implementing appropriate corrective actions.
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b.
Unit 1 Summary
The Unit continued its current run of 133 days of continuous
operation and achieved one year without an automatic trip above 15%
power.
On July 19, sulfate contamination of the steam generators
occurred when a valve isolating the demineralized makeup water system
from a regenerating demineralizer leaked by, causing sulfuric acid to
be injected into the condensate system. The unit was reduced to 30%
power, although not expeditiously due to misunderstanding of written
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procedures.
The sulfates were cleaned up within a day and the unit
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returned to full power,
c.
Unit 2 Suninary
The Unit started the reporting period at 100% power and tripped on
June 26 when an operator misinterpreted a test procedure step and
shut one Main Steam Isolation Valve.
The unit later restarted,
however, it was forced to shutdown on July 16 when an action
statement expired on the 2A centrifugal charging pump (see paragraph
5.c.).
The unit started up on July 21.
Power escalation was
hampered by problems with the steam dumps and turbine control valves
hydraulics.
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d.
Based upon an event at another facility where unexpectedly high
radiation levels in the reactor building forced evacuation of site
personnel, the inspector asked the licensee whether reportability
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procedures adequately covered events which significantly hamper site
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personnel in the performance of duties necessary for the safe
operation of the plant.
Although this type of event was covered by
procedure RP/0/B/5000/13 the licensee agreed that the procedure could
be improved and has initiated a change to affect this improvement.
No violations or deviations were identified.
4.
SurveillanceObservation(61726)
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a.
During che inspection period, the inspector verified plant operations
were in compliance with various TS requirements.
Typica; of these
requir2ments were confirmation of compliance with the TS for reactor
coolart chemistry, refueling water tank, emergency power systems,
safety injection, emergency ' safeguards systems, control room
vent 116 tion, and direct current electrical power sources.
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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
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personnel other than the individual directing the test, and that any
deficiencies identified during the testing were properly reviewed and
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resolved by appropriate management personnel.
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b.
The inspectors witnessed or reviewed the following surveillances:
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IP/1/A/3222/000
Channel IV Analog Channel Operations Test
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PT/1/A/4200/09A
Auxiliary Safeguards Test Cabinet Pericdic
Test'
PT/2/A/4200/14/A
Ice Condenser Intermediate Deck Door and
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Inlet Door Position Monitor
PT/2/B/4150/29
Containment Floor and Equipment Drain Sumps
Increase Test
No violations or deviations were identified.
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5.
MaintenanceObservations(62703)
a.
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:
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the activities were accomplished using approved procedures, and
functional testing and/or calibrations were performed prior to
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returning components or systems to service; quality control records
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were maintained; activities performed were accomplished by qualified
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personnel; and materials used were properly certified. Work requests
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were reviewed to determine status of outstanding jobs and to assure
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that priority is assigned to safety-related equipment maintenance
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which may effect system perfonnance.
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b.
The inspectors witnessed or reviewed the following maintenance
activities:
MP/0/A/150/81
Nuclear Service Water Lube Injection
Strainer Corrective Maintenance
89725WR
Replace KF Filter 2B
MP/0/A/7150/16
Repair 2A NV Pump
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c.
On July 13 operators observed decreasing pressurizer level, charging
flow decreasing from 87 to 50 gpm and increasing VCT level on Catawba-
Unit 2.
The problem was quickly diagnosed to the operating 2A
Centrifugal Charging Pump (NV) and operators recovered from the
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transient by starting the other pump. The licensee initially assumed
gas binding and initiated actions to vent the pump after declaring it
A later attempt to operate the pump resulted in
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significantly reduced flow (25 gpm) and smoke was observed in the
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vicinity of the inboard bearing.
The licensee determined that
disassembly of the pump and replacement of the rotating element was
necessary.
The rotating element was replaced under work request 41005 OPS with a spare rotating element with a similar shop head
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curve.
The new element was retested after installation.
At the
reference operating point of 88 gpm the pump exhibited a head of
approximately 85 psig lower than the head of the old pump.
The
licensee obtained an evaluation by Westinghouse with results
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documented in letters dated July 15, 1988 to T. F
Wyke from
S. S. Kilburn and July 19, 1988 to R. Puryear from Dan Dudek and
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Steve Swanther.
The evaluation concluded that the' flow
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characteristics of the system were not materially altered and the
pump will operate adequately under runout conditions. The inspectors
performed independent calculations to verify the results.
The root
cause for failure of the pump has not been determined.
Disassembly
of the old rotating element has revealed indications of excessive
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internal pump recirculation.
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No violations or deviations were identified.
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6.
Review of Licensee Non Routine Event Reports (92700)
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a.
The below listed Licensee Event Reports (LER) were reviewed to
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determine if the information provided met NRC requirements.
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determination included: adequacy of description, verification of
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compliance with Technical Specifications and regulatory requirements,
corrective action taken, existence of potential generic problems,
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reporting requirements satisfied, and the relative safety
significance of each event.
Additional inplant reviews and
discussion with plant personnel, as appropriate, were conducted for
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those reports indicated by an (*).
The following LERs are closed:
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413/87-45
Technical Specification Violation due to
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inadequate procedural
guidance and a
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personnel error.
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413/88-03 Rev. 1
Technical Specification Violations on Wide
Range Temperature Monitoring Instrumentation
due to Installation and Design'0eficiencies.
413/88-20
Technical Specification Violation involving
Pressurizer PORV's and Associated Block
Valves Position Indication.
b.
On December 8.1987, the licensee determined that the Containment
Purge (VP) system had been inoperable in September 1986 during core
alterations in that Train B would not have isolated on a high
relative humidity condition as required by TS 4.9,4.1.b.
The reason
for the inoperability was that a set of fused jumpers used for
troubleshooting were never removed.
The jumpers were used without
declaring the system inoperable or without performing a 10CFR50.59
evaluation.
The licensec reported the inoperability in LER
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413/87-45. Corrective action included requirements in IP/0/A/3890/01
Controlling Procedure for Troubleshooting and Corrective Maintenance,
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for technicians to consult with engineers prior to using fused
Jumpers and precautions of instrument loop inoperability when using
fused jumpers to troubleshoot intermittent electrical faults.
Appropriately a Notice of Violation is not proposed as permitted by
Appendix C of 10CFR2 and this event is classified as a Licensee
Identified Violation 413/88-25-02.
Inoperability of Containment
Purge Valves due to use of fused jumpers.
One licensee identified violation as described above was identified.
7.
Follow-uponPreviousInspectionFindings(92701and92702)
a.
(Closed)
Violation 413/87-30-01:
Unauthorized Isolation of an
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Auxiliary Feedwater Pressure Switch rendering the Auxiliary Feedwater
System unable to function as designed under certain conditions. The
licensee responded to the violation in correspondence dated
December 31, 1987.
Corrective action included review, revision and
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implementation of safety related instrumentation valve lineups done
after extended outages, increased guidance upon identifying
instrument valves out of position and training.
Based upon these
corrective actions this item is closed.
b.
(Closed)
Violation 413,414/87-30-02:
Failure to establish adequate
measures to periodically calibrate all safety related instruments.
The licensee responded to the violation in correspondence dated
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November 13, 1987 and December 28, 1988.
Correc'tive action included
identification and completion of instrument calibrations that had not
yet been done, evaluation of those instruments discovered to be out
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of tolerance, and development of administrative guidance to ensure
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instrumentation added by modifications is identified in the periodic
calibration program.
Based upon these corrective actions this item
is closed.
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c.
(Closed)
Unresolved Item 413, 414/87-33-01:
Two channels of valve
position indication for PORV's and PORV block valves not installed as
required by TS 3.3.3.6.
TS 3.3,3.6 requires 2 channels of . valve
position indication for each pressurizer PORV and PORY block valve.
The licensee's use of- a non-safety related strap on resistance
temperature defector (RTO) as the second channel for the PORV
position indication was deemed acceptable by the NRC:
The licensee
Fowever failed to maintain 2 channels per PORY block valve operable
from initial licensing until May 20, 1988 at which time the channels
were declared inoperable and a seven day action s?,atement was
entered.
At this time the licensee determined that an independent
position indication for each block valve was available at the test
patch panel and initiated action to verify operability. .The licensee
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was unable to obtain operable channels on Unit 2 without entering .
containment.
To avoid an unnecessary shutdown, the licensee
requested an uergency TS change for Unit 2 to require only one
operable channel. The request was granted and issued as amendment 39
for Unit 2, effective May 27, 1988.
This is identified as a
violation of TS 3.3.3.6, violation 413,414/88-25-01:
Failure to
maintain two operable channels of valve position indication for PORY
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block valves.
This violation has minor safety significance as the
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basis f6r the Technical Specification (Regulatory 1.97 and TM1-2
Action Plan Item II. D.3) indicates that one channel per. valve may be
acceptable.
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(0 pen) Unresolved Item 413.414/88-22-03:
Potential Inadequate
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Venting of ECCS Systems.
The inspectors reviewed change 7 ~ to
PT/2/A/4200/06 and change 11 to PT/1/A/4200/06, (implemented June 30,
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1988) ECCS Valve Lineup Verification which includes actions to meet
monthly T.S. requirements to vent discharge piping of ECCS systems.
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As a result of the inspector's questions concerning adequacy of
vanting, one vent valve in each train was identified to be,at a
higher elevation and~therefore a better valve to ensure the systen is
water solid.
The licensee was previously using the highest vent
valve in the flowpath but not the system high point.
The inspectors reviewed PT/2/A/4200/10A, ND Pump 2A Performance Test
conducted on Febrcury 1, 1988.
Horizontal vibration readings of the
pump were noted to fall into the alert range as defined by Table
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IWP-3100-2 of section XI of the ASME ?ailer and Pressure Vessel Code.
The problem was corrected when the pump was adequately vented. The
Nnspectors determined the the licensee does not have written
procedures for fill and vent of safety related systems. The licensee
stated that typically a system or component would be isolated with a
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RemovalandRestoration(R&R). The R&R defines the boundaries and is
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also used to fill and vent the system.
This item remains open
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pending continued review of ECCS venting and apparent requirements by
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T.S. 6.8.1 and Regulatory Guide 1.33 to have and maintain written
procedures for system fill and vent.
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(Closed) Unresolved Item 414/86-38-01:
No Criteria Established for
Documentation of Reverification of Reperformance of Station Status
and Prerequisites of Interrupted Tests.
The licensee has addressed
this issue via Revision 9-to Station Directive 3.2.2, Development and
Conduct of the Periodic Testing Program.
This change adequately
addresses this concern and no significant problems were identified as
a result of the weakness. Therefore, this item is closed.
f.
(Closed) Inspector Followup Item 413/86-05-01:
Revise Station
Directive 3.2.2.
Revision 9 to the Station Directive (SD) has been
issued which addresses notification of the Shift Supervisor when a
test is not completed within the allowed TS interval.
This
adequately addresses the NRC concern.
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(Closed) Inspector Followup Item 413/86-36-01, 414/86-39-01:
Revision of SD 3.2.2 to clarify administrative controls for test
interruption.
SD 3.2.2 has been appropriately revised,
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(Closed) Inspector Followup Item 413/87-30-04:
Evaluation of
Subcooling Nuisance Alarm.
The licensee has evaluated the setpoint
for the alarm and has raised the setpoint by 3'F thereby elimincting
the nuisance alarm,
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(Closed) Inspector Followup Item 413,414/88-08-03;
Upgrade Program
For Use of Jumpers to Operate M0V's. Tha licensee added centrols to
troubleshoot motor operated valves to IP/0/A/3890/01, Controlling
Procedure for Troubleshooting and Corrective Meintenance.
The
procedure requires
troubleshooting to be conducted under
IP/0/A/3820/04, Operating Checkout of Limitorque and Rotork Valve
Actuators or IP/0/A/3820/07
Troubleshooting and Maintenance of
Rotork Actuators.
Procedures now require consultation with
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operations and/or Technical Support pe sonnel when bypassing
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interlocks, permissives, automatic functions, and torque / limit
switcher during troubleshooting.
Additional precautions must be
taken to ensure a moto: does not reach stall torque situations.
A specialized training package, Basic Troubleshooting and Corrective
Muintenance Guidelines for Motor Operated Valve Actuators has been
genermd and is to be incorporated into the station personnel
training program.
Based on this the item is closed.
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(Closed) Inspector Followup Item 413,414/88-15-01:
Inoperable RN Pit
Level Transmicters Interpretation Implementation.
The licensee
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comitted to writing a procedure to implement an interpretation of TS 3.3.2 item 149 concerning operability of RN pit level transmitters,
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The procedure has been implemented as enclosure 4.15 of
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OP/0/A/6400/06C, Nuclear Service Water System.
The enclosure
specifies actions to be taken in the event of an inoperable
transnitter to ensure that the actions are at leut as conservative
as the instrument's automatic actions.
Sased upon the inspectors
review of the enclosure this item is closed.
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(0 pen) Inspector Followp Item 413,414/88-15-03:
Changes in RHR
Operation with Low Flow Annunciators.
The inspector reviewed
enclosure 4.1 of Revision 9 of OP/1(2)/A/6200/04, Residual Heat
Removal System (ND).
The change requires that the ND cross connect
valves be isolated when the system is used for routine decay heat
removal.
This ensures that with the reactor coolant system filled,
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normal ND flow rates will not result in a low flow alarm.
The
licensee has also initiated a Station Problem Report (SPR CNPR03449)
to reduce the setpoint of the low flow annunciator, such that it will
not be in alarm when a lower flow is required during reactor coolant
draining operations,
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While reviewing the change, the inspector noted that NI-173 and
NI-178 (ND pump discharge isolation valves to the cold legs) are
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simultaneously shut in order to recirculate flow and obtain boron
concentration samples.
This makes both trains of ND isrperable, as
TS 3.5.3 requires at least one train's valve to be open.
In the past
the unit has unknowingly been placed S ou action statement, however,
there is no evidence that the licensee had ever violated the action
statement.
The licensee has stated it would be prudent to isolate
one train at a time for sampling and has agreed to revise the
procedure.
8.
Followup of NRC Bulletin 88-05(92701)
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As a result of inspections directed by NRC Bu11etin 88-05, Non Conforming
Materials Suppled by Piping Supplies. Inc. u Folsom, New Jersey and West
Jersey Manufacturing Company at Williamstcwn, New New Jersey.
The
licensee was to date identified 10 non conforming socket weld flanges.
The systems involved include Steam Supply to the Auxiliary Feedwater Pump
Turbine, Diesel Generator Air Start, Auxiliary Feedwater and Main
Proper notification to the NRC have been made in'each case.
The licensee is performing an analysis in each case to justify continued
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operation.
No violations or deviations were identified.
9.
Licensee Weakness Regarding Management of Technical Specification
Compliance
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The licensee has had a history of difficulties in complyirg with Technical
Specifications (TSs) at Catawba Nuclear Station.
The cause of this
problem is, in part, weaknesees in the original TS review which resulted
in some TSs which were unclear, some which did not meet plant design, and
some where ;ompliance with the letter of TSs goes beyond the intent of or
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the basis for the TS. Licensee personnel, on occasion, have chosen not to
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follow the letter of TSs while meeting intent or safety aspects.
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Confusing TSs have led to personnel errors.
The number of TS changes that
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are able to be processed in a given time period by NRC due to Federal law
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and the licensee due to manpower makes it difficult to affect all changes
necessary in a timely manner.
For example 41 amendments were processed in
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1987 and to date, 28 amendments have been proce: sed in 1988.
Changes
which suppart clarifications and improvements in complying with intent
appear to have a low priority since these are in competition with the
necessary changes such as those which support upcoming modifications.
This typically leads to delays between when the need for _the changes is
identified and submittal to NRC of 7 months and greater, up to 2 years.
The licensee uses a TS Interpretation Manual to provide guidance and also
has procedure guidance relative to support systems required for
operability of TS systems.
Use of the manual has typically been reactive
rather than proactive and some interpretations have been made without use
of the manual.
Issuance of guidance has not always been timely.
Issues
which illustrate this weakness are as follows:
Control Room Ventilation - instrumentation in TS did not meet plant
design. TS has been changed.
original TS was excessively
Auxiliary Building Ventilation
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restrictive, i.e. 24-hour action in lieu of 7 days.
Caused by poor
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review and resulted in several discretionary enforcement actions
before TS was finally changed.
D.C. Power Sources (TS 3.8.2.1) - action e, is poorly worded. This
has lead to confusion surrounding entering TS 3.0.3 (see LER 413/87-32 and NRC Report 413,414/87-33).
An interpretation has been
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issued but the poor wording remains.
Violation 414/87-05-05(LER414/87-05)- corporate personnel issued a
TS interpretation allowing site personnel 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to isolate a
containment isolation valve in lieu of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> required by TS 3.6.3.
Violation 414/87-25-01 - licensee inappropriately took credit for
pegged high gauges for channel checks of Auxiliary Feedwater System
flow instruments.
Unit 2 design results in normally pegged high
gauges requiring special methodology to meet standard TS.
Violation 414/87-30-01 - power range neutron flux trip setpoint was
not evaluated by corporate personnel in accordance with the equation
required by TS 2.2.1.
Auxiliary Feedwater valves were
Violation 413/414/87 44-01
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throttled when TS requires the valves to be fully open.
No TS
interpretation was issued although operations personnel had
interpreted the intent of the TS to allow this operations mode. The
need for this TS to be changed was recognized by the licensee in
November 1986, and was not submitted to NRC until February 1988.
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Violation 414/87-44-03 - a confusing TS for the shared Control Room
Ventilation contributed to both trains being inoperable from
emergency power for a period of time.
The licensee recognized the
need for changing this TS in December 1987 and the request has not
yet been submitted to NRC.
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Violation 414/87-88-07 - licensee used unqualified instrumentation to
compensate for inoperable acoustic monitors for pressurizer safety
valves.
TS uses the term valve position indication with no
amplifying information.
Violation 413,414/88-25-01 - two channels of pressurizer PORV block
valve position indications were not available per TS which were also
a standard TS.
Corporate personnel indicated to site personnel that
two indications rather than two separate channels were acceptable and-
met basis for TS rather than requiring compliance with the letter of
the TS. This issue was raised in late 1987. An emergency change was
granted for Unit 2 in May 1988 and additional changes for Unit 1
block valves and PORV position indicators are yet to be submitted to
NRC.
LER 413/88-13 - both trains of Containment Spray were made legally
A poorly written TS contributec to this problem.
The
need for a TS change was recognized in December 1987 and is yet to be
submitted to NRC.
Unresolved Item 413/86-17-01 - licensee chose not to follow letter of
TS and does not vent pump casings of running pumps while taking
credit for the surveillance which requires venting.
Although the
exemption appears to be technically reasonable, the licensee has yet
to submit a TS change request to NRC.
While these situations are not individually significant, TS non-compliance
can lead to significant problems,
Licensee management has recognized the
need for inprovement in this area and reformatting of operator guidance
information is in progress.
The licensee indicated that this issue will
be further reviewed to determine the need for additional corrective
actions.
Further followup will be conducted in this area by the RI. This
is Inspector Followup Item 413/88-25-03: Weakness Regarding Management of
Technical Specification Compliance.
10. Licensee Strengths
a.
The licensee has completed staffing of an on-site Design Engineering
(D/E) group.
This group is providing more timely response to issues
involving D/E and providing a more thorough understanding of the
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issue. Several interfaces with this group by the inspectors has been
beneficial.
The presence of this group is considered to be a
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strength.
b.
The licensee had recently established a site Performance Indicator
,
Program.
Indicators have been established for material conditions,
modification backlog, comitment index, personnel exposure, people
performance (errors), cost per kilowatt-hour, safety system
unavailability, gross equivalent availability factor, preventive to
corrective maintenance ratio and work request backlog.
Challenging
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