IR 05000413/1998010
| ML20196B152 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 11/23/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20196B135 | List: |
| References | |
| 50-413-98-10, 50-414-98-10, NUDOCS 9811300280 | |
| Download: ML20196B152 (17) | |
Text
n . - . . . _ . .. .~ - . . . - . . - . - . - - . . . - - . . .
'
!
l l l
i I
l >
!
NUCLEAR REGULATORY COMMISSION l
REGION 11 Docket Nos: '50-413,50-414 .
License Nos: NPF-35, NPF-52 1 l
Report Nos.: 50-413/93-10,50-414/98-10 !
l
'
Licensee: Duke Energy Corporation i
Facility: Catawba Nuclear Station, Units 1 and 2 I l
' Location: 422 South Church Street Charlotte, NC 28242 Dates: September 27 - October 31,1998 j Inspectors: D. Roberts, Senior Resident inspector R. Franovich, Resident inspector M. Giles, Resident inspector J. Coley, Reactor Inspector (Section M7.1)
W. Stansberry, Physical Security Specialist (Sections S1, S2, S6, S7, S8)
Approved by: C. Ogle, Chief Reactor Projects Branch 1 Division of Reactor Projects l
l
,
l Enclosure
"
9811300280 981123 PDR ADOCK 05000413 G PDR
EXECUTIVE SUMMARY {
Catawba Nuclear Station, Units 1 and 2 NRC Inspection Report 50-413/98-10,50-414/98-10 This integrated inspection included aspects of licensee operations, maintenance, engineering, 6 and plant support. The report covers a 5-week period of resident inspection; in addition, it j includes the results of announced and reactive inspections by a regional reactor safety i inspector and a physical security specialist. (Applicable template codes and the assessment for !
items inspected are provided below.]
i Operations !
.
The licensee conducted outage activities safely with appropriate attention to shutdown risk management. Infrequent evolutions affecting operations were thoroughly briefed with control room personnel prior to the jobs being performed. (Section 01.2; [POS-1 A, 2B,3A])
.
The licensee appropriately initiated a manual reactor trip when rod control problems emerged at the end of the Unit 2 end-of-cycle 9 refueling outage. (Section O2.1;[POS-1B])
.
Operators demonstrated appropriate sensitivity to Technical Specification requirements !
during the approach to criticality when a malfunction with the rod control system was I identified. (Section 02.1;[POS-1B])
.
The inspectors also noted that troubleshooting activities were performed with approved procedures. (Section O2.1;[POS-3A]) {
.
In the face of many unexpected challenges during the restart from the Unit 2 refueling !
outage, the licensee performed well. Appropriate actions were taken to troubleshoot !
problems in accordance with a controlled troubleshooting process. The licensee j exhibited sound judgement in resolving the various problems. (Section 07.1; [POS-1 A, 1 48,5B]) ll
.
A non-cited violation was identified for two errors made while implementing clearances on Unit 2 equipment. In the first instance, operators inadvertently closed a Unit 1 valve ),
while attempting to isolate a Unit 2 service water pump. This resulted in a brief interruption of service water flow to both units. In the second instance, operators opened an incorrect fuse drawer which inadvertently deenergized the Train B 4160 volt essential switchgear. (Section 08.1; [NCV- SA, SC; NEG -1 A, 3A])
Maintenance
.
In general, the observed maintenance and surveillance activities were performed well, with proper adherence to equipment calibration, radiation protection, and procedural requirements. (Section M1.1; [POS-2B])
.
During a containment cleanliness walkdown inspection, the inspectors identified only minor housekeeping items, which were promptly resolved by licensee personnel when ;
brought to their attention. (Section M1.1; [POS-2A])
.
The Maintenance Rule periodic assessment performed by the licensee took into account systems, structures, and components performance, condition monitoring, associated
l
goals, and preventive maintenance activities; and met the guidance delineated in Nuclear Management and Resource Council 93-01 Revision 2. (.c9ction M7.1; [STRE ])
Enaineerina
.
A modification to change the control circuit of the Unit 2 main steam isolation valves did not adversely affect the main steam isolation valves' ability to perform their safety function and was performed without incident. (Section E1.1; (POS-4C])
Plant Suocort
.
While no regulatory limits were violated, the licensee's internal goals for radiation exposure during the Unit 2 End-of-Cycle 9 refueling outage were exceeded. However, the licensee devoted attention to this area and identified it as an improvement item for future outage preparation. (Section R1.1;[NEG-1C))
-
The licensee's material, package, and vehicle access controls for items entering the protected and vital areas met the criteria of the current Nuclear Security and Contingency Plan and appropriate security procedures. (Section S1.5; [POS-1C,2A, 3A])
!
.
The licensee's personnel search equipment functioned according to the Physical !
Security Plan and implementing procedures. (Section S2.4; [POS-1C, 2A])
.
The vehicle barrier system was found functional, well maintained, and effective in its intended purpose. The licensee met the Physical Security Plan commitments and regulatory requirements. (Section S2.5; (POS-1C,2A])
.
Site and security management provided strong support to the physical security program and were effective in administrating the security program. This area was considered a strength in the site security program. (Section S6.2; [STREN-10,3C])
.
The licensee reviewed and analyzed documented problems, reached logical conclusions, and prioritized the problems for appropriate corrective action. This problem analysis program was a strength to the security program. (Section S7.2; [STREN-58, 5A])
-
The licensee's corrective actions for safeguards related events were technically sound, {
effective, and performed in a timely manner. (Section S7.3; [POS-5C))
.' The licensee's management controls in and upon the security program were aggressive, effective, and comprehensive. (Section S7.4; [POS-1C,3C])
.
A non-cited violation was identified for two failures to comply with the requirements of the licensee's procedures regarding access control to the protected area. These failures resulted in an involuntarily / unfavorably terminated individual obtaining access to the protected area. Additionally, the individual was terminated within the protected area contrary to the licensee's procedures. (Section S8.1; (NCV- SA, SC; NEG-1C))
{
Reoort Details Summary of Plant Status Unit 1 l Unit 1 began the inspection period in Mode 1 operating at 100 percent power. The unit operated at or near 100 percent power for the duration of the period.
Unit 2 Unit 2 began the period with the reactor core offloaded (No Mode) for the Unit 2 end-of-cycle 9 {
(2EOC9) refueling outage. On October 4,1998, fuel reload began and the unit entered Mode 6. On October 9,1998, with reactor vessel head stud tensioning complete, the unit entered Modo 5. Unit heatup to Mode 4 and Mode 3 occurred on October 15 and October 17, 1 1998, respectively. Reactor startup (Mode 2) began and criticality was achieved on October 19, i 1998. Following problems with a reactivity monitor used for zero power physics testing, the reactor was shutdown to Mode 3 on October 20,1998. Mode 3 conditions were required to calibrate a replacement reactivity monitor obtained from the McGuire plant. After installation of the replacement monitor, the unit restart procedure commenced and Mode 2 was achieved on October 20,1998. During this second approach to reactor criticality, problems with the rod control system were encountered. The reactor was tripped on October 21,1998, and the unit ,
entered Mode 3 to allow troubleshooting. A defective slave cycler card for Control Bank A >
Group 2, was replaced, and unit restart was commenced later that evening. The reactor was taken critical at 10:38 p.m. on October 21,1998. The unit entered Mode 1 on October 23, 1998, and the turbine was placed on line on October 24,1998, ending the 2EOC9 refueling outage. The unit reached 100 percent power 'n October 29,1998, and operated there for the remainder of the perio l. Operations 01 Conduct of Operations 0 General Comments (71707)
The inspectors conducted frequent control room tours to verify proper staffing, operator attentiveness and communications, and adherence to approved procedures. The inspectors attended operations shift turnovers and site direction meetings to maintain awareness of overall plant status and operations. Operator logs were reviewed to verify operational safety and compliance with Technical Specifications (TS). Instrumentation, computer indications, and safety system lineups were periodically reviewed, along with equipment removal and restoration tagouts, to assess system availability. The TS Action Item Log books for both units were reviewed daily for potential entries into limiting conditions for operation (LCO) action statements. The inspectors conducted plant tours to observe material condition and housekeeping. Problem identification Process (PlP)
repolis were routinely reviewed to ensure that potential safety concerns and equipment problems were resolved. The inspectors identified no major problems from the above review .2 Unit 2 Refuelino Outaae Activities Insoection Scope (71707)
The inspectors observed and assessed performance of various Unit 2 outage-related activities to ensure that procedures were followed, shutdown-risk controls were implemented, infrequently performed activities were adequately prepared for and briefed by station personnel, and foreign material exclusion controls were implemented where applicabl Observations and Findinas
,
In general, Unit 2 refueling outage activities were performed without incident and in accordance with governing procedures. Exceptions at the beginning of the outage associated with routine clearance activities were discussed in inspection Report (IR) 50-413,414/98-09 and in Section O8.1 of this report. Activities observed by the inspectors included the unit shutdown, engineered safety feature actuation testing, fuel movement, reactor coolant system reduced inventory and midloop operations, vacuum refill of the RCS, and unit startup activities. Equipment problems incurred during unit startup activities are discussed in Sections O2.1 and O7.1 below. The above evolutions were performed in accordance with governing procedures, and with adequate preparation during pre-job briefs by cognizant !icensee personnel. Licensee controls during the midloop arid vacuum refill operations were adequate to prevent major problem Equipment prescribed by the licensee's procedures was available during the evolution Conclusions The licensee conducted outage activities safely with appropriate attention to shutdown risk management. Infrequent evolutions affecting operations were thoroughly briefed with control room personnel prior to the jobs being performe O2 Operational Status of Facilities and Equipment O2.1 Manual Unit 2 Reactor Trio While in Mode 2 Insoection Scope (93702. 71707)
The inspectors observed a manual reactor trip of Unit 2 on October 21,1998, and reviewed the circumstances requiring the trip. The inspectors reviewed post-trip data, reviewed the licensee's corrective actions addressing why the manual trip was required, and observed the Unit 2 restart following repairs to the rod control system, Observations and Findinas During a reactor startup on October 21,1998, operators raised questions on the performance of Control Bank A. Based on digital rod position indication, during rod withdrawal, Group 2 in Control Bank A had stopped at 138 steps while Group 1 in Control Bank A continued to withdraw to 149 steps until operators stopped the evolutio The step demand counters for Group 2 indicated that its rods were at 150 steps while Group 1 rods were at 149 steps. Technical Specification 3.1.3 requirements for reactivity control systems were not exceeded. The unit was in Mode 2 in preparation for restart from refueling outage 2EOC9 and the reactor was not critica , .~ - - - - - ~ - - . - - - _ . - . -. . - - - . - - _ .
1 After initial troubleshooting attempts by operations, engineering, and maintenance personnel were unsuccessful, control room personnel tripped the reactor (under l management direction) to allow further troubleshooting of the rod control system. The inspectors observed the plant's performance during the trip and verified that systems required to respond to the trip functioned properly. A main feedwater isolation signal
- was generated by the reactor protection system which caused the operating main l
'
feedwater pump turbine to automatically runback to minimum speed. Operators were able to effectively control steam generator water levels above the low-low setpoint to preclude an automatic auxiliary feedwater actuation. The inspectors verified that all of the control and shutdown banks' rod bottom lights were lit, including Control Bank A, Groups 1 and 2. Operators performed well during the event with proper implementation of emergency operating procedures and effective command and control by the senior licensed operator in the control room.
I Further troubleshooting identified a failed slave cycler encoder card in the power tupply cabinet for the affected rod group. This card was providing intermittent pulse signals to lift coils associated with group 2 rod movement. The card was replaced and the rods were successfully withdrawn during the subsequent reactor startup later the same da The inspectors inquired about the number of rod control system problems that have been noted at the Catawba site over the last year. As documented in IR 50-413, 414/9715, operators manually tripped the Unit 1 reactor while in Mode 4 on December 29,1997, due to rod position indication problems. Several times over the ensuing fuel cycle, operators have had to switch the digital rod position indication t.ystem to half accuracy mode for train A or B data failures associated with individual rod
'
position indication. The inspectors were told that the October 21,1998, problem with Control Bank A, Group 2, was the first recent failure involving an actual rod control problem affecting rod movement, while the others involved digital rod position indication problems. The licensee indicated and the inspectors verified that plant performance criteria for the rod control system as tracked per the maintenance rule had not been exceeded as a result of the recent problems.
1 Conclusions The licensee appropriately initiated a manual reactor trip when rod control problems emerged at the end of the 2EOC9 refueling outage. Operators demonstrated l appropriate sensitivity to Technical Specification requirements during the approach to criticality when a malfunction of the rod control system was identified. The inspectors also noted that troubleshooting activities were performed with approved procedures.
l 07 Quality Assurance in Operations i .
0 Problems Encountered Durina Unit 2 Startuo Activities Inspection Scope (40500. 71707. 62706)
The inspectors observed the licensee's actions to address several challenges that arose during the startup from the 2EOC9 refueling outage. The inspectors were present in the l control room for the unit startup activities discussed below, i
h.
!
I
- - , , .- - , _ . - - - , - - - _ . ..- ,.
4 Observations and Findinas The licensee encountered several problems during three successive approaches to criticality and subsequent low power physics testing during the 2EOC9 refueling outage between October 19 and 23,1998. The first problem involved a defective reactivity meter used for control rod worth determination following the initial reactor startup on October 19,1998. One of two pico-ammeters on the computer lost indication during the rod worth measurement and could not be used for further testing. The licensee obtained a replacement reactivity computer from the McGuire plant, but it could not be calibrated with the unit already critical, so operators performed a controlled shutdown to Mode 3 conditions on October 20,1998, to allow calibratio While in Mode 3, the inspectors observed maintenance technicians performing a compensating voltage adjustment for the two redundant intermediate range nuclear instrumentation system channels, N35 and N36. Channel N35, with a new amplifier module that was installed during the just-completed fuel cycle, required a more lengthy adjustment than its counterpart. During the subsequent reactor startup procedure, the inspectors observed that N35 and N36 tracked consistently with increasing power as expecte During the second startup, problems with the rod control system were encountered which ultimately resulted in operators manually tripping the reactor on October 21,1998 (see Section O2.1 above). Following the reactor trip, operators noted that intermediate range channel N35 was tracking higher than N36 by approximately a quarter-decade, but still within Technical Specification channel check requirements. Engineering later determined that the newer amplifier module in N35 had a response at lower flux levels (below scale) that was slower than that of N36, and that the slight discrepancy was to be '
expected. The inspectors verified this by reviewing OAC trend data for N35 and N36 following the October 21,1998, reactor trip and following the unit shutdown to begin the outage on September 5,1998. Licensee personnel indicated that this information would be incorporated into formal guidance to prevent future concerns in this are Once the intermediate range nuclear instrument channel and rod control system problems were resolved, operators commenced a third reactor startup procedure in as many days. During subsequent low power physics testing (dynamic rod worth measurement using the aforementioned reactivity meter), engineers determined that measured control rod worth for the entire core was higher than what had been predicted by core design engineers, with Shutdown Bank B particularly high (18.7 percent more than predicted). The initial data for Shutdown Bank B and the entire core (8.1 percent higher) failed to meet the 8 percent test review criteria specified in the procedur Licensee personnel initiated a failure investigation process team who determined that a test using a higher point of adding heat (POAH) flux value (as indicated on intermediate range nuclear instrument channels) might yield better results. At the higher POAH value (5 x 10-7 amps versus 2 x 10'7 amps), Shutdown Bank B and other rod banks' results were more consistent with predicted values. The second tests' data was corroborated by a Shutdown Bank B measurement using the boron dilution method prescribed in Procedure PT/0/A/4150/11 A. The inspectors reviewed the test data and confirmed that it met procedure review criteria. The Plant Operations Review Committee approved the results of the subsequent tests and, after ruling out other potential causes, recommended continuing with normal power escalation testing. No further problems were encountered with the Unit 2 startup from 2EOC9 refueling outage.
!:
_ _ _ . _
_ . __ _.. _ _ _ _ _ . _ _ ._._ _ _- . _ . _ _ _ ______
5 \
i .Q.gnclusions i in the face of many unexpected challenges during the rests it from the Unit 2 refueling l outage, the licensee performed well. Appropriate actions wre taken to troubleshoot i problems in accordance with a controlled troubleshooting process. The licensee !
exhibited sound judgements in resolving the various prob 1 cm '
,
08 Miscellaneous Operations issues (90712, 92901)
0 (Closed) Anoarent Violation (eel) 50-414/98-09-01: Failure to Follow Procedural i Guidance While implementing Clearances - Two Examples '
+.
'
(Ocen) Licensee Event Reoort (LER) 50-414/98-004-00: Error During Tagout Causes De-Energization of Vital Bus and Actuation of Low Temperature Overpressure Protection
'l This apparent violation involmd two examples of failure to follow procedural guidance while implementing clearances. The first example occered on September 2,1998, wtiile implementing removal and restoration tagout (R&R) 28-1258 to isolate nuclear service water (RN) pump 2A. Operators inadvertently closed valve 1RN-29, the discharge isolation RN valve for RN pump 1 A. This caused the loss of RN flow to both l units. This event was caused by human error and failure to follow R&R tagout
'
procedure 28-1258 The failure to follow the clearance tagout procedure was contrary l to requirements in TS 6.8.1.a and Regulatory Guide 1.33, Revision 2, Appendix A, ;
Section 3.m, which state that written procedures shall be established and implemented covering the operation of the service water system. Proposed corrective actions for this I
'
event included ccanseling of involved personnel and highlighting valves on their !
respective R&R tagout sheets in the future when valves in close proximity, for different units, are being manipulate ,
i l
The second example occurred on September 6,1998, while operators were performing
.OP/2/A/6800/010, Revision 5,2B D/G Block Tagout Procedure, Enclosure 4.1, Isolation and Draining to support outage maintenance on the 2B emergency diesel generator {
(EDG). Operators opened an incorrect fuse drawer which inadvertently deenergized the Train B 4160 volt essential switchgear. Human error was the root cause of the even The failure to follow procedure OP/2/A/6800/010,2B D/G Block Tagout Procedure, was contrary to requirements in TS 6.8.1.A and Regulatory Guide 1.33, Revision 2, Appendix A, Section 3.s.(2)(a), which state that w::tien procedures shall be established and ,
, implemented covering operation of emergency power sources. Completed corrective I actions for this event include counseling of personnelinvolved by the Shift Operations _ ;
Manager and performance of an evaluation which was required due to the TS cooldown
, and heatup limits being exceeded for the pressurizer. This evaluation concluded that the structuralintegrity of the pressurizer was not compremised. Proposed corrective actions include evaluating the training of non-licensed operators on potential transformers, performing stroke time testing and limit switch indication verification for all three pressure operated relief valves, and validating pre-planned tagouts equipment database nomenclature with plant labels and drawings.
These two examples of non-compliance with TS 6.8.1.a and Regulatory Guide 1.33 are
considered two examples of a non-repetitive, licensee-identified, and corrected violation that ic being considere<1 as a Non-Cited Violation (NCV), consistent with Section Vll. I
. . - - . _ _ _ ___ _ _ - _ _ . - - . - - - -.- -. _- .- .- _- - - .. - - - _ .- - -... - -
l l
l i 6 +
l of the NRC Enforcement Policy. They are identified as NCV 50-414/98-10-01: Failure to Follow Procedural Guidance While implementing Clearances - Two Example LER 50-414/98-004-00, Error During Tagout Causes De-Energization of Vital Bus and Actuation of Low Temperature Overpressure Protection, discussed the second example and lists the licensee's subsequent corrective actions. This LER will remain open pending the licensee's completion and the inspectors' review of the corrective actions.
t l 08.2 (Closed) LER 50-414/97-006-00: Manual Reactor Trips Following Main Steam Isolation l Valve (MSIV) Closure
.
This LER documents two failures of digital optical:rolators (Dols) in the control circuitry of the 2D MSIV that caused the MSIV to close on July 26,1997, and August 17,1997, l l both requiring manual reactor trips. The inspectors reviewed the following: station PIPS i
!
2-C97-2422,2-C97-3191, and 2-C97-2684; NRC IR 50-413,414/97-11 and 50-413,414/97-12; work orders; training documentation; and emergency operating .
procedures. Based on review of these documents, the inspectors concluded that corrective actions delineated in the LER were complete. The inspectors noted that an !
l additional corrective action to modify the Unit 1 and 2 MSIV control circuitry to eliminate ,
l a single failure vulnerability for the valves to unnecessarily close was completed for both l l units (refer to Section E1.1 of this inspection report). The inspectors concluded that, ,
l since the second DOI failure occurred within three weeks of the initial failure, the '
l licensee did not have sufficient time to fully develop the root cause determination of the first failure and complete corrective actions to prevent the second failure. This LER is close i 11. Maintenance I l l M1 Conduct of Maintenance M1.1 General Comments on the Conduct of Maintenance and Surveillance Activities (6270 )
The ir,spectors observed portions and/or reviewed completed documentation of the following maintenance and surveillance activities:
=
IP/0/A/3240/015, Revision 21, Intermediate Range Channel Compensating
, Voltage Adjustment and Source Range Channel High Flux at Shutdown l Adjustment (
j
'
-
MP/0/A/7150/017, Revisions 7,8, and 9, Centrifugal Charging Pump High Speed Gear Drive Corrective Maintenance (2A and 2B Charging Pumps)
.
MP/0/A/7400/009, Revision 17, Diesel Engine Cylinder Head Removal and i Replacement, (28 Refueling Outage Mechanical PM, WO980761612-01) i
. MP/0/A/7400/029, Revision 11, Diesel Engine Fuel Injector Removal and Replacement, (2B Refueling Outage Mechanical PM, WO990761612-01)
' .
MP/0/A/7400/013, Revision 11, Diesel Engine Break-in After Major Maintenance i
!
L
- ,_ _ . - .
- _. __ . . -- . _ _
!
l
,
'
PT/2/N4200/09, Revision 133, Engineered Safety Features Actuation Periodic Test
.
IP/0/N3240/004M, Revision 1, NIS Source Range Channel Discriminator Curve
- and High Voltagc Power Supply Plateau Adjustments
.
PT/0/N4150/01, Revision 20, Controlling Procedure for Startup Physics Testing
.
PT/0/N4150/01 A, Revision 0, Zero Power Physics Testing
-
PT/0/N4150/19, Revision 17,1/M Approach to Criticality In general, the referenced maintenance and surveillance activities were performed well, with proper adherence to equipment calibration, radiation protection, and procedural requirements. Additionally, during a containment cleanliness walkdown inspection, the inspectors identified only minor housekeeping items which were prompily resolved by licensee personnel when brought to their attentio M7 Quality Assurance in Maintenance Activities l M Maintenance Rule Periodic Assessment Insoection Scoce (62706)
Paragraph (a)(3) of the Maintenance Rule requires that performance and condition monitoring, associated goals, and preventive maintenance activities for systems, structures, and components (SCCs) be evaluated taking into account, where practical, industry-wide operating experience. This evaluation was required to be performed at least one time during each refueling cycle, not to exceed 24 months between evaluations. Adjustments are required to be made where necessary to ensure that the objective of preventing failures of SSCs through maintenance is appropriately balanced against the objective of minimizing unavailability of SSCs due to monitoring or proventive maintenance. The NRC Maintenance Rule baseline inspection of Catawba was conducted on February 10-14,1997. At that time the licensee had not completed the first periodic assessment since the Maintenance Rule did not take effect until July 10,1996. On June 30,1998, the licensee completed the first period assessment which included both Unit 1 and 2 and covered the period of January 1,1996, to October 1, ,
1997. This inspection was conducted to verify the effectiveness of the periodic !
assessment and of corrective actions take b. Observations and Findinos The licensee had performed the assessment in accordance with the guidance given in .
'
Chapter 12 of Nuclear Management and Resource Council (NUMARC) 93-01, Revision 2 " Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The inspector reviewed the completed periodic assessment, held discussions with the Maintenance Rule Coordinator, and validated / verified documentation used to l
support conclusions reached in each area addressed in the periodic assessment.
'
Specific areas validated by the inspector were: (a)(1) SSCs had been evaluated against l l their goals for continued applicability; (a)(2) SSCs performance criteria had been I assessed to determined maintenance effectiveness; performance monitoring of all 1 systems in the Maintenance Rule was effective; balancing availability and reliability was l l
l l
l
_ - - _ _ _ _ _ _ - _ _ _ _ _ ._ _ _ _ _ .__
appropriate; and industry operating experience was used effectively. During the review, the inspector also observed a number of initiatives had been developed by the licensee to improve the effectiveness of the Maintenance Rule program. Some of the initiatives which added strength to the program were the following: engineering feedback forms were used to address (a)(2) SSCs that were experiencing problems and the preventive maintenance program was enhanced to improve the performance of these SSCs to keep them from becoming (a)(1) candidates; quarterly system health reports for risk significant systems were furnished to management; and an assessment had been performed and corrective actions identified in PIP report 0-C97-3294 for improvement of Maintenance Rule " Working Tools" associated with computer softwar In addition to the above, at the time of the Maintenance Rule team inspection, the licensee had not completed the inspections required for structures. Industry experience with the rule and NUMARC 93-01, during the pilot site visits and the initial period following the effective date of the rule, indicated that specific guidance for monitoring the effectiveness of maintenance for structures was needed. As a result of insufficient guidance, licensees, including Duke Power Company, had generically failed to complete inspections of all structures by the July 10,1996, Maintenance Rule implementation date. In Revision 2 of Regulatory Guide 1.160, dated Match 1997, the NRC provided the guidance needed. During this inspection, the inspector reviewed the completed documentation for structures and concluded that this portion of the Maintenance Rule program had been conducted effectively by the license c. Conclusions The periodic assessment performed by ti'e licensee took into account SSCs perfctmance, condition monitoring, associated goals and preventive maintenance
!
activities; and met the guidance given in NUMARC 93-01. Based on the documentation reviewed and the enhancements validated, this assessment was considered a strength under toe Maintenance Rul Ill. Enaineerina E1 Conduct of Engineering E Outaae Modification - General Comments (37551)
During the refueling outage, the licensee implemented a modification to the Unit 2 main ( steam isolation valve (MSIV) circuitry. The inspectors reviewed documentation associated with the modification and observed portions of the modification in the field to assess the quality of modification preparation and implementation.
j Modification CN-21373 involved changes to the Unit 2 MSIVs' control circuitry to l
preclude an unnecessary MSIV closure and reactor trip resulting from a single failure vulnerability. A similar modification was implemented on Unit 1 during the December
! 1997 refueling outage; that modification was discussed in NRC IR 50-413,414/97-1 The modification did not adversely affect the MSIVs' ability to perform their safety function and was performed without incident.
i
.
l I
t
. .. _ _ _ _ _ _- - - - _ - . - . - - .. -
l
IV. Plant Support R1 Radiological Protection I R Radioloaical Protection - General Comments (71750)
The inspectors reviewed performance indicator data for the recently completed 2EOC9 refueling outage to determine how the licensee performed in the area of radiological l protection. Final data indicated that, based on electronic dosimetry results, the licensee ;
exceeded its station goal of 112 person-rem for the outage by approximately 45 person- !
rem (actual recorded dose was 156.7 rem). While no goals were established for i personnel contamination events,78 were recorded for the outag )
The licensee initiated a root cause investigation into the excessive dose for 2EOC9 and identified several potential causes. These included higher radioactivity and dose rates associated with Cobalt-58, which was more than double the previous Unit 2 refueling i outage. Licensee personnel preliminary attributed the higher activity to core design and !
presumed that the problem will not be immediately resolved over the next few operating i cycles. Another cause included additional man-hours expended during high-dose work i windows, such as those during primary and secondary system drain-down evolution Another contributor was problems incurred during lead shielaing installation at the beginning of the outag Licensee management devoted attention to these issues and identified them as improvement items in preparation for the next refueling outage. The inspectors concluded that the licensee's efforts to initiate a root cause investigation for this item were an effective first step toward that end. The inspectors also verified that no regulatory limits were exceeded during the outag S1 Conduct of Security and Safeguards Activities S Protected Area Access Control of Packaaes. Material. and Vehicles a. Insoection Scooe (81700)
The inspectors evaluated the licensee's package, material, and vehicle access control activities to ensure compliance with Chapters 5,6,7,9,10, and 16 of the Duke Power Company Nuclear Security and Contingency Plan (PSP), Revision 7, and Security Procedures (SP) 206, " Personnel Access Portal Officer," Revision 4; SP 207, " Vehicle Access Portal (VAP)," Revision 4; SP 214, " Cargo Access Officer," Revision 14; and SP 303," Explosive Detector Operability and Testing."
b. Observations and Findinas The inspectors verified by observation that the licensee had positive access control measures in place to properly identify, authorize, and search materials, packages, and vehicles before allowing them to be introduced into the Protected Area (PA). An active
- land vehicle barrier system was utilized to control vehicle access to the PA. The v'ehicle
'
barrier system (VBS) will be discussed in more detail in paragraph S2.5 below, l
i The licensee used explosive detectors and X-ray devices to search and identify hand-
- carried items at the primary access portal (PAP). If any items needed a closer
! inspection to ensure unauthorized contraband did not enter the PA, an officer would conduct a hand search of the article (s).
.. - . . _ . . _ .. _. _ . _ -._ _ _ . _ _ _ . _ _ _ . _ _ _ . . _ _ __
l
1 i Security officers searched vehicles and their contents entering the PA through the l
'
vehicle access portal (VAP). Personnel accompanying the vehicles were processed through PA c. ~ Conclusions -
The licensee's material, package, and vehicle access controls for items entering the 1- protected and vital areas met the criteria of the current Nuclear Security and Contingency Plan and appropriate security procedure S2 Status of Security Facilities and Equipment S2.4 Personnel Search Eouloment I' a.' Insoection Scope (817001 l
h The inspectors evaluated the licensee's personnel search equipment to ensure that personnel equipment performed according to Chapters 5,7, 9, and 16 of the licensee's PSP commitments and SP 303, " Explosive Detector Operability and Testing"; SP 304,
'
"X-ray Equipment Operability and Testing"; and SP 311, " Metal / Weapon Detection Equipment Operability and Testing."
, Observations and Findinas
The inspectors verified that personnel, hand-carried packages or material, and delivered packages or materials were searched before being admitted to the PA. These searches were either by a physical search or by search equipment. Explosive detectors, metal detectors, and X-ray devices with color and black and white monitors, were the search equipment used by the licensee. Security officers were positioned at a station in full l view of the search equipment. The inspectors observed security personnel search individuals using metal and explosive detectors for firearms, explosives, incendiary 4 devices, and other items that could be used for radiological sabotage. Hand-carried packages or materials were searched by X-ray devices or manually searched by security personnel. The inspectors reviewed randomly selected X-ray quarterly,
- explosive detector daily, and metal detector daily operational and performance test l
records to ensure _that an appropriate testing and maintenance program of the ;
personnel search equipment was being conducted and met established criteri Conclusions
' The licensee's personnel search equipment functioned according to the Physical i
Security Plan and implementing procedure S2.5 ' Vehicle Barrier System Insoection Scooe (81700)
i The inspectors reviewed Appendix 2 of the PSP, SP 412, "VBS Operational Procedure,"
L and SP 419," Land Vehicle Bomb Contingency Procedure," to ensure that the licensee was complying with the VBS commitments and 10 CFR 73.55(c)(7).
t~
. , _ ,__ _ -,_
- . .. - _ _ ,- - _ . --
,
l
'
i
- Observations and Findinas
'
The inspectors verified by touring the site perimeter that the VBS was in place and functioning according to the PSP and SPs. The licensee continued to use a ,
combination of surface mounted, anchored jersey barriers, bollards, buildings, backfilled i concrete retaining walls, sewage treatment lagoons, and a sump pit as part of the l barrier system. The licensee used both active and passive gate barriers. The l inspectors reviewed quarterly and annualinspection records of the VBS and found that j the license was complying with various testing and maintenance commitment '
l l
'
c. Conclusions l
The vehicle barrier system was found functional, well maintained, and effective in its intended purpose. The licensee met the Physical Security Pian commitments and regulatory requirement )
S6 Security Organization and Administration S6.2 Manaaement Suocort and Effectiveness Inspection Scoce (81700)
The inspectors evaluated the degree of the licensee's management support and I effectiveness to the security program to determine the level of support for the physical {
security program and effectiveness of licensee management relative to the !
administration of the physical security program, l
- Observations and Findinas h
The inspectors interviewed management and non-management personnel and reviewed I security related documents to determine the support provided and program j effectiveness resulting from that support. The inspectors' interviews with security ;
personnel indicated that in their opinion, the range of support provided by management i
< was from good to excellent. The inspectors determined that licensee management !
l exhibited an awareness and favorable attitude toward physical protection requirement I The following items demonstrated a strong support system for the security progra !
. Two additional security posts are being built at the entrances into the owner l controlled are .
The testing and maintenance program was enhanced by site management's !
assignment of two maintenance personnel to the security program. This has l
resulted in faster turnaround time on work requests. For example, during the month of September 1998,19 work requests were written and complete .
The tracking, trending, analysis of safeguard events, and subsequent corrective actions were strong cornerstones to the success of this security progra ;
.
There were only two security personnel turnovers since the beginning of 1997 j (three retirements with two individuals hired as replacements).
'
. The downward trend of human error events since January 199 l l
l
-.. . - - - _ - . . - . - - - - . - . . - . - . .. - -
.
The downward trend of unsecured door events,84 in 1996,66 in 1997, and 25 to date in 199 .
The downward trend of lost and uncontrolled badge events,32 in 1996,25 in 1997, and 14 to date in 199 .
If a person does not use his badge for five days it is put on hold. Previously,it was 10 day .
The implementation and installation of the new access control modification involving hand geometry units and a new badging system required significant management suppor .
Site management awareness and support was enhanced in monitoring the vendors' and contractors' compliance with company and site security commitments and regulatory requirement Conclusion Site and security management provided strong support to the physical security program and were effective in administrating the security program. This area was considered a strength in the site security program.
.,
S7 Quality Assurance in Security and Safeguards Activities S7.2 Problem Analysis
. Insoection Scoce (81700)
The inspectors evaluated and reviewed a sample of documented problem analysis conducted by the licensee of the logged safeguards events and LER Observations and Findinas During the inspection, a representative sample of the problems identified by inspections, LERs, and safeguards event logs were reviewed to verify that the problems were appropriately assigned for analysis, appropriately analyzed, logically resolved and properly prioritized for corrective action by the licensee. The inspectors identified that the licensee had formed focus groups of security personnel to conduct root-cause analysis of security problems and to improve security force performance through enhanced personnel training. Security management conducted a group assessment report at the end of each calendar quarter that reviewed security events documented during the preceding quarter to identify any trends, either positive or negative, that should be analyze Conclusions The licensee reviewed and analyzed documented problems, reached logical conclusions, and prioritized the problems for appropriate corrective action. This problem analysis program was a strength to the security progra . . - - - .. . . .- - . . - . - . - .
l S7.3 Corrective Actions Inspection Scope (81700)
The inspectors evaluated and reviewed a sample of corrective actions implemented by the license Observations and Findinas l
l The inspectors reviewed a sample of corrective actions that had been implemented to l verify that the actions taken were technically sound and performed in a timely manne The effectiveness of the corrective actions was reflected in the downward trend of i safeguards events noted in paragraph S6.2 above. Also, contributing to the success of l the corrective actions was the fact that they were technically sound, timely, and valid as noted in paragraph S7.2 abov Conclusions
'
The licensee's corrective actions were technically sound, effective, and performed in a timely manne S Effectiveness of Manaaement Controls Inspection Scope (81700)
The inspectors evaluated the overall effectiveness of the licensee's controls for identifying, analyzing, and resolving problems. The inspectors evaluated the adequacy of corrective actions to prevent recurring problems. The inspectors also evaluated whether there were strengths or weaknesses in the controls for issues that could enhance or degrade plant operations or safet Observations and Findinas The inspectors reviewed previous audits, self-assessment program documents, LERs, security event logs, and PIPS to ascertain the licensee's effectiveness of management controls. The licensee's strong problem analysis program was reflected in the aggressive PIP program and documentation. Adverse events, trends, and problems were identified, analyzed, and eventually brought to closure through the PIP progra The absence of recurring major regulatory issues, the downward trend of loggable safeguards events, and the positive testing and maintenance program supporting the security hardware and systems, were indicative of the effectiveness and involvement of the licensee's management. The licensee's continued expansion and refinement of the above discussed management tools and controls were considered to be the driving force and strength of the security program, Conclusions l The licensee's management controls in and upon the security program were aggressive,
- effective, and comprehensive.
l l
i
S8 Miscellaneous Security and Safeguards issues (92904)
,
S (Closed) LER 50-413/98-001S-00: Terminated Vendor Employee Entered the Protected
'
Area Due to a Computer interface Malfunction The inspectors reviewed and evaluated LER 1998-001S-00. This LER was reported to
!
NRC on October 12,1998, and pertained to an event that occurred on September 13, 1998. At 6:10 a.m., on September 13,1998, security was notified by a vendor supervisor to delete the unescorted access of a vendor employee whose employment was to be terminated. At 6:14 a.m., security terminated the vendor employee's badge in the Video Badging Network (VBN) computer. However, security did not terminate the badge in the plant security access computer to prevent future access. This latter action, a workaround, was necessary due to a previously identified malfunction in the interface between the VBN and plant security access computer. At 4:47 p.m., on September 13, 1998, the terminated vendor reported for work as scheduled. He had not yet been informed that he had been terminated. At 5:15 p.m., the supervisor noticed the vendor '
employee at the worksite in the protected area. At 5:21 p.m., the vendor supervisor
' notified security. At that time, within the protected area, the vendor employee was informed by his supervisor that he had been terminated. At 5:32 p.m., security escorted the terminated employee out of the protected area and acquired the individual's badg The required one-hour notification to the NRC Operations Center was made at 6:21 The employee's badge was terminated from the plant access computer at 7:19 Nuclear System Directive 218, Duke Power Company Nuclear Access Authorization Program, Revision 6, Appendix B, Termination of Unescorted Access Authorization, Section B.1 requires that, if termination of employment is involuntary / unfavorable, the lndividual's Security Badge must be restricted before the individual is told that he or she is being terminated and that the notice of termination be given to the individual while the individualis outside of the protected are Once security was aware of the human error of failure to delete the terminated individual's badge from the plant access computer, immediate corrective action was taken by acquiring the badge from the individual, and deleting the badge from the plant access computer. The licensee repaired the computer interface between the VBN and plant access computer on September 15. The vendor's supervisor was counseled on his responsibilities to comply with Nuclear System Directive 218 requiring notification of termination be done outside the protected area. The failure to terminate an individual's access after termination, and to notify him offsite of the termination, is contrary to Nuclear System Directive 218. This non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy, NCV 50-413,414/98-010-02: Licensee Failure to Follow Nuclear System Directive 218 for the Restriction of a Terminated Individual's Security Badge and the Notification of Termination Outside the Protected Are V. Manaaement Meetinas
- X1 Exit Meeting Summary l
The inspector presented the inspection results to members of licensee management at ( the conclusion of the inspection on November 4,1998. The licensee acknowledged the findings presented. No proprietary information was identified.
,
.- _ . _ .__ . . . . _ . . _ _ _ - . . _ . . _ _ . _ . . _ _ ___ _ . . . . . _ __ _
l L PARTIAL LIST OF PERSONS CONTACTED j : Licensee i
R. Beagles, Safety Assurance Manager l M. Birch, Safety Assurance Manager M. Boyle, Radiation Protection Manager e
- S. Bradshaw, Safety Assurance Manager T. Byers, Security Manager f1
'
B. Emmons, Human Resources Manager G. Gilbert,' Regulatory Compliance Manager. .
l R. Glover, Operations Superintendent l
P. Herran, Engineering Manager R. Jones, Station Manager .
J. Minnicks, Security Supervisor G. Peterson, Catawba Site Vice-President D. Rogers, Maintenance Manager
- F. Smith, Chemistry Manager INSPECTION PROCEDURES USED iP 37551: Onsite Engineering ,
, IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726: Surveillance Observations IP 62706: Maintenance Rule IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities <
IP 81700: Physical Security Program for Power Reactors IP 90712: In-Office Review of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901: Followup - Operations -
IP 92904: Followup - Plant Support IP 93702: Prompt Onsite Response to Events at Operating Power Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-414/98-10-01 NCV Failure to Follow Procedural Guidence While implementing Clearances - Two Examples (Section
, 08.1)
50-413,414/98-010-02 NCV Licensee Failed to Follow Nuclear System Directive 218 for the Restriction of a Terminated Individual's Security Badge and the Notification of Termination Outside the Protected Area (Section S8.1)
I i
i g g i.,,, , -- r e s. , --- -~ , - , , ,
Closed 50-414/98-09-01 eel Failure to Follow Procedural Guidance While implementing Clearances - Two Examples (Section 08.1)
50-414/97-06-00 LER Manual Reactor Trips Following Main Steam isolation Valve (MSIV) Closure (Section 08.2)
50-413/98-001S-00 LER Terminated Vendor Employee Entered the Protected Area Due to a Security Computer Interface Malfunction (Section S8.1)
Discussed 50-414/98-004-00 LER Error During Tagout Causes De-Energization of Vital Bus and Actuation of Low Temperature Overpressure Protection (Section O8.1)
LIST OF ACRONYMS USED 2EOC9- Unit 2 End-of-Cycle 9 (Refueling Outage designator)
CFR - Code of Federal Regulations Dols -
Digital Opticalisolators EDG - Emergency Diesel Generator eel -
Escalated Enforcement item FSAR - Final Safety Analysis Report IFl -
Inspector Followup Item IR Inspection Report LCO -
Limiting Condition for Operation LER -
Licensee Event Report MSIV - Main Steam Isolation Valve NCV - Non-cited Violation NRC -
Nuclear Regulatory Commission NUMARC- Nuclear Management and Resource Council PA -
Protected Area PAP - Protected Access Portal PIP -
Problem Investigation Process Report POAH - Point Of Adding Heat PSP -
Duke Power Company Nuclear Security and Contingency Plan RCS -
Nuclear Service Water (licensee's designation)
R&R -
Removal and Restoration Tagout SCCs- Systems, Structures, and Components TS -
Technical Specification -
UFSAR- Updated Final Safety Analysis Report URI -
Unresolved item VAP -
Vehicle Access Portal >
VBN Video Badging Network VI -
Violation WO -
Work Order l