ML20205P269
| ML20205P269 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 04/18/1986 |
| From: | Brownlee V, Skinner P, Vandoorn P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205P249 | List: |
| References | |
| 50-413-85-55, 50-414-85-68, NUDOCS 8605210305 | |
| Download: ML20205P269 (23) | |
See also: IR 05000413/1985055
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UNITED STATES
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NUCLEAR RF.GULATORY COMMISSION
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REGION 11
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101 tV ARIETTA STREET, N.W.
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ATLANTA. GEORGt A 30323
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Report Nos.: 50-413/85-55 and 50-414/85-68
Licensee: Duke Power Company
422 South Church Street
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Charlotte, NC 28242
Docket Nos.:
50-413 and 50-414
License Nos.: NPF-35 and CPPR-117
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Facility Name: Catawba 1 and 2
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Inspection Conducted:
D e ber 26 - February 1, 1986
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Inspectors:
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P.'K. VinDo'or ~~~
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A. companying Pers nnel:e We rders
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Approved by:
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V. L. Mownlee, Branch Chief
'Cfate Signed
Division of Reactor Projects
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SUMMARY
Scope:
This routine, unannounced inspection involved 327 resident inspector-
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hours on site in the areas of followup of licensee and NRC identified items
(Units 1 and 2); followup of 10 CFR 21 reports (Units 1 and 2); followup of an
information notice (Unit 1); plant operations review (Unit 1); preoperational
test program implementation (Unit 2); Technical Specification (TS) review
(Unit 2); surveillance observation (Unit 1); maintenance observation (Unit 1);
and operational staffing (Unit 2).
Results:
Of the nine areas inspected, no violations or deviations were
identified in eight areas; two apparent violations were found in one area
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(Failure to follow procedures associated with operation of diesel generator IB;
and Failure to provide adequate corrective. action to prevent recurrence' of TS
violations of fire watch requirements) and one apparent deviation was found ,in
one area (Failure to meet commitment in FSAR Section 7.4.7.1 for auxiliary
shutdown panels).
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8605210305 860418
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DR
ADOCK 05000413
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REPORT DETAILS
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1.
Persons Contacted
Licensee Employees
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- J. W. Hampton, Station Manager
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- E. M. Couch, Project Manager
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H. L. Atkins, QA Engineering Supervisor
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- H. B. Barron, Operations Superintendent
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- W. F. Beaver, Performance Engineer
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W. H. Bradley, QA Surveillance
"T. B. Bright, Construction Engineering Manager
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B. F. Caldwell, Station Services Superintendent
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- J. W. Cox, Superintendent, Technical Services
T. E. Crawford, Operations Engineer
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J. R. Ferguson, Assistant Operating Engineer
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C. L. Hartzell, Licensing and Projects Engineer
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- R. A. Jones, Test Engineer
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J. Knuti, Operating Engineer
- P. G. LeRoy, Licensing Engineer
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W. R. McCullum, Superintendent, Integrated Scheduling
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C. E. Muse, Operating Engineer
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"D. B. O'Brien, Administrative Methods Supervisor
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G. Robinson, QA Engineer, Operations
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K. W. Schmidt, QA Engineer
- F.
P. Schiffley, II, Licensing Engineer
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- G. T. Smith, Maintenance Superintendent
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0. Tower, Operating Engineer
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- J. W. Willis, Senior QA Engineer, Operations
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Other licensee employees contacted included technicians, operators,
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mechanics, security force members, and office personnel.
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- Attended exit interview
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2.
Exit Interview
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The inspection scope and findings were summarized on January 31, 1986, with
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those persons indicated in paragraph 1 above.
The new items described in
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paragraphs 6 and 15 were discussed in detail. The licensee did not identify
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as proprietary any of the materials provided to or reviewed by the
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inspectors during this inspection.
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3.
Licensee Action on Previous Enforcement Matters
a.
(Closed) Violation 413/84-95-01: Failure To Establish An Adequate Test
Program To Assure All Testing Is Performed On Modifications.
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licensee responded to this violation in correspondence to Region II-
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dated January 17, 1985. In this letter, the licensee took exception to
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the second cited example. Af ter further review of this response, the
NRC withdrew the second example as discussed in NRC letter to Duke
Power Company (DPC) dated December 9, 1985. The inspector reviewed the
corrective actions taken by DPC for this violation a.1d considers this
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item to be closed.
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b.
(Closed) Unresolved Item 413/85-12-02:
Low Pressure Service Water
Mini-Flow Inoperability. Additional information has been provided to
the inspector which indicates that the detection system has been
modified to install more reliable instruments. Prior to completion of
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this modification, sampling was required during radioactive effluent
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discharges to assure compliance with TS. Subsequent to this modifica-
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tion minimum flow interlocks have been functioning properly. Based on
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this information, this item is closed.
c.
(Closed) Unresolved Item 413/85-20-04: Multiple Inadvertent Actuation
of ESF.
During the period of May 9-15, 1985, the site experienced
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nine actuations of Engineering Safety Features (ESF) systems or
portions thereof.
These were subsequently reported in Licensee Event
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Reports (LERs) 413/85-30 and 413/85-31.
The corrective actions taken
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by the LERs has been reviewed by the inspector and this action appears
to be adequate at this time.
Based on this review, this item is
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closed.
d.
(0 pen)
Unresolved
Item 413/85-35-01,
414/85-32-01:
Review of
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Electrical Interfaces Between Units.
The licensee has reviewed
electrical design for both safety-related and non-safety-related
electrical loads for possible interunit problems.
The only safety
related interface found involved control power for valves INV188A,
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2NV188A, INV252A, and 2NV252A being normally supplied by a Unit 1 bus
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and the corresponding Train B valves being normally supplied by a
Unit 2 bus. The licensee plans to perform modifications to delete this
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interface.
Evaluation of the non-safety-related loads disclosed a few
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interfaces, however, these all have an automatic swapover feature.
No
modifications are planned relative to these interfaces.
This item
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remains open pending licensee implementation of the safety-related
modifications.
It should be noted that the affected valves are
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designed to go to their safe position upon loss of power.
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e.
(Closed) Deviation 413/85-05-03: Failure to Have Reactor Vessel Level
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Indicating System (RVLIS) Fully Operational Before Initial Criticality.
This deviation was addressed in licensee correspondence dated April 23,
1985.
The licensee stated in that letter that the Final Safety
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Analysis Report (FSAR) would be revised before November 1,
1985.
Revision 13 addressed RVLIS operation. RVLIS is fully operational for
Unit 1 at this time and for Unit 2, it will be operational as required
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by TS prior to entry into Made 3.
Based on this information, this item
is closed.
No violations or deviations were identified.
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Unresolved Items
New unresolved items are identified in paragraphs 6.b., 6.f., 6.g., and 15.
5.
Licensee Identified Items 50.55(e) (92700) (Unit 2)
a.
(Closed) CDR 414/85-07: Installation Clearances of NCX750 and NCX1200
Batteries.
Reports for this item were submitted on May 23, 1985;
August 30, 1985; October 28, 1985; and December 26,
1985.
The
inspector reviewed the reports and verified completion of the
corrective action identified in the reports and considers licensee
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actions to be acceptable.
b.
(Closed) CDR 414/85-09:
Nameplate Affixing Adhesive Questionable on
600VAC Motor Control Centers. The report for this item was submitted
on July 12, 1985.
The inspector reviewed the report and verified
implementation of corrective action identified in the report. Licensee
actions are acceptable.
c.
(Closed) CDR 414/85-10:
Fan Motor Bearing Failure.
Reports for this
item were submitted on July 26, 1985 and November 22, 1985.
The
inspector reviewed these reports and verified implementation of
corrective actions identified in the report.
Due to extensive damage
to the fans, the licensee was unable to determine the cause of failure.
However, extensive testing appears to have assured that the replacement
fans are operable. Possible causes were over or under lubrication, or
improper installation.
Although these possible causes and licensee
evaluation of these causes do not appear in the licensee response, an
additional response is not requested at this time.
The extensive
testing assures proper installation and acceptable lubrication relative
to the short term, therefore, this item will be closed.
The licensee
is still evaluating long term lubrication requirements for the Hydrogen
Skimmer Fans.
Followup by NRC is necessary and, therefore, this is
Inspector Followup Item 413/85-55-01, 414/85-68-01: Evaluation of Long
Term Lubrication Requirements for Hydrogen Skimmer Fans.
d.
(Closed) CDR 414/85-12:
Missing Spring on Pressurizer PORV.
The
report for this item was submitted on December 26, 1985. The inspector
reviewed the report and verified implementation of corrective actions
and inspections described in the report.
Licensee actions are
considered acceptable.
e.
(0 pen) CDR 414/86-01:
Diesel Generator Main Bearing Failures.
An
interim report was submitted on January 16, 1986.
The inspector
witnessed test runs of the repaired 2B Diesel Generator (D/G) being
accomplished to verify that the 28 D/G was appropriately repaired. The
inspector witnessed runs of one minute, five minutes, and 15 minutes
and a portion of an eight hour run. The licensee plans to reinspect
the number seven bearing after 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> is accumulated on the engine
and submit a final report on this issue.
This item remains open
pending these additional licensee actions.
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No violations or deviations were identified.
6.
Plant Operations Review (71707, 71710, and 71714) (Unit 1)
a.
The inspectors reviewed plant cperations throughout the reporting
period to verify conformance with regulatory requirements, TS, and
administrative controls. Contro) room logs, danger tag logs, TS Action
Item Log, and the removal end restoration log were routinely reviewed.
Shift turnovers were observed to verify that they were conducted in
accordance with approved procedures.
The inspectors 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. Also, reviewed that licensee was taking adequate
protection for cold weather expectations.
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.
On January 3,1986, the licensee identified four damaged hangers in the
Auxiliary Feedwater System. The licensee applied TS 3.7.8 which covers
snubbers to these damaged hangers (relative to seismic consideration,
even though the hangers were not snubbers.
Further, the licensee
performed a " prudent" evaluation period (approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) in
evaluating non-seismic aspects of these hangers relative to system
operability.
In addition, the licensee has interpreted TS 3.7.8 to
allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to fix and evaluate discrepancies prior to entering the
affected systems action statement. NRC guidance is not clear in this
area, therefore, NRC will further evaluate the effects of hanger
discrepancies on system operability.
This is Unresolved Item
413/85-55-02, 414/85-68-02:
Evaluation of Operability Requirements
Relative to Hangers and Supports.
c.
The inspector compared the Auxiliary Shutdown Panel instrumentation and
controls to the Final Safety Analysis Report (FSAR).
FSAR section
7.4.7.1 states that the instrumentation and controls provided on the
auxiliary shutdown panels and auxiliary feedwater pump turbine control
panels are listed on Tables 7.4.7-1,
7.4.7-2,
and
7.4.7-3.
A
comparison of the instrumentation and controls specified in the FSAR to
the installed instrumentation identified that all indications and
controls shown in the FSAR are not installed on these panels. Examples
of these are 1KC51A, 1KC548, and 1NV294.
This is identified as a
deviation 413/85-55-03, 414/85-68-03:
Failure to meet commitment in
FSAR Section 7.4.7.1 for auxiliary shutdown panels.
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d.
On January 19, 1986, Diesel Generator (DG) IB was being tested per
Periodic Test (PT)/1/A/4350/028, DG IB Operability Test.
After 33
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minutes - into the test, the DG shutdown due to lack of fuel.
The
inspector reviewed this failure in detail and events associated with
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this failure from December 2,
1985 through January 23, 1986.
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appears that a lack of sufficient management attention and concern was
apparent during the events associated with this occurrence as evidenced
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by the multiple examples identified below where procedures were not
followed or were not adequate.
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(1) PT/1/A/4350/02B, Section 11.0 Acceptance Criteria Step 11.2 states
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"the fuel oil day tank is > 70 inches with the level being
maintained by IFD-62 (DG Engine Fuel Oil Day Tank 1B Fill)". Step
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12.42 is a sign-off statement to verify during DG operation that
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the valve did function to meet this acceptance criteria.
On
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December 16, 1985, when this procedure was conducted, step 12.42
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was not signed off and a discrepancy record entry was made stating
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that 1FD-62 did not maintain level in the fuel oil day tank
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( F0DT) . The procedure was erroneously signed off stating that the
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test met all acceptance criteria due to the action taken by the
supervisor to open the hypass valve (1FD-63) around IFD-62 to
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assure a continuous source of fuel oil to the day tanks. IFD-63
was tagged in the open position and remained in that condition
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until IFD-62 was returned to service on January 8,1986. During
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this period, PT/1/A/4350/02B was performed on December 23, 1985
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and January 6,
1986, and statement 12.42 was signed as being
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performed, and the procedures were approved by management as
having met the acceptance criteria, whereas in all- three tests,
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valve 1FD-62 was not functioning as specified. TS 4.8.1.1.2.a.3
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requires verifying that the fuel transfer valve (IFD-62) can be
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operated to allow fuel to be transferred from the storage system
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to the day tank. As a result of this action, this TS was not met.
The opening and tagging of IFD-63 as an alternate means to trans-
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fer fuel oil to the day tank appears to.be technically acceptable
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while the repair s are made to IFD-62.
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(2) As part of this investigation, the inspector reviewed 33 completed
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periodic test packages associated with Unit.1 diesel generators.
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These packages were for PT/1/A/4350/02C, Available Power Source
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Operability
Check conducted between December 2, .1985 and
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January 20, 1986.
This review indicated nine of these packages
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with one of the required enclosures not attached, another package
(dated January 19, 1986) had one page of one of the enclosures
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missing, and two packages (dated December 4 and 5) did not have
the enclosures completely signed off as required. Administrative
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Policy Manual (ADM), Chapter 4.2, Administrative Instructions for
Permanent Station Procedures, Section 4.2.7.a, requires that a
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procedure completion package contain all required enclosures. The
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missing enclosures discussed above constitute a violation of ADM
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Chapter 4.2.
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(3) The inspector reviewed the Diesel Generator Logbook for the IB DG
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start attempts number 356 through 386. The requirements of this
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logbook are specified by Operations Management Procedure (0MP)
2-28,
Revision 6,
Diesel Generator Logbook.
Section 3.5 of
OMP 2-28, states that " valid-failure", " invalid' test", or " invalid
failure" shall be documented by this procedure by the person
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responsible for operating the engine and provides a data sheet for
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that purpose. A review of these data sheets (Enclosure 10.2) for
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the above listed starts identified that data sheets for start -
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attempts number 380 and 376 were not proper!y filled out.
In
addition, start attempt number 380 also was not reviewed and
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signed by supervisory personnel.
This failure to complete the
required forms and perform a supervisory review are a violation of
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OMP 2-28,
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The above examples are being combined to form a single violation of a
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failure to follow procedures, Violation 50-413/85-55-04:
Failure to
follow procedures associated with operation of diesel generator 1B.
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e.
The inspector reviewed work request (WR 19373 OPS) associated with the
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failure of IFD-62 as discussed in
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above.
processed to correct the failure of IFD-62 to perform its intended
function.
In the " Action Taken" section of the WR, the technician
performing the work stated that " complete functional retest should be
done by actual diesel run or performance test".
The next entry states -
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that operations said that the retest was not required.
Since the
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original rework involved replacing a fuse and an electrical test was-
accomplished, the initial retest appears to have been an appropriate
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retest.
However, since this valve failed later, a second further
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review
is necessary to verify that an adequate retest was
accomplished.
This is an Unresolved Item 413/85-55-05:
Review of
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adequacy of post maintenance retest for valve 1FD-62.
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f.
Criterion XVI and Topical Report Quality
Assurance Program (DUKE-1-A) section 17.2.16 requires measures be
established to assure that conditions adverse to quality such as
failures, malfunctions, deficiencies, deviations, defective material
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and equipment,
and nonconformances are promptly identified and
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corrected and that the measures shall assure that the cause of the
condition is determined and corrective action taken to preclude
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repetition.
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Contrary to the above, measures did not assure that the cause of the
condition was determined and corrective action taken to. preclude
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repetition in that a failure to perform hourly firewatches as required
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occurred on October 8, 1985 (See LER 85-58).
Corrective action was
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taken to preclude reoccurrence of this problem.
Subsequent to this
corrective action, failures to perform hourly fire watches occurred
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again on November 7,1985 (LER 85-64), December 17 and 26,1985. These
subsequent failures indicate that the corrective actions taken as a
result of the failure on October 8 was inadequate to preclude
repetition.
This is identified as a Violation 413/85-55-06:
Failure
To Provide Adequate Corrective Action To Prevent Recurrence Of TS
Violations Of Fire Watch Requirements.
g.
TS 3.7.10.3 requires the high pressure and low pressure CO2 systems to
be operable. The action statement associated with this item states
"with one or more of the above required CO2 systems inoperable, within
one hour establish a continuous fire watch with backup fire suppression
equipment for those areas in which redundant systems or components
could be damaged; for other areas, establish an hourly fire watch
patrol."
Discussions between the resident and Region II
fire
protection personnel indicate that the intent of this statement is to
assure continuous fire protection is established when normal fire
protection is not available and the redundant safety equipment is not
operable. An example of this is:
if normal fire protection system is
inoperable for 1A DG and IB DG is removed from service, then a
continuous fire watch would be required for IA DG with backup fire
suppression equipment until IB DG is returned to service or the 1A DG
normal fire protection system is returned to service. Discussions with
Catawba personnel ind'cate an agreement with this intent, however, the
TS is not clear. Pending clarification of this action statement, this
is identified as an Unresolved item:
413/85-55-07: Clarification of
Action Statement for TS 3.7.10.3.
h.
TS 3.3.3.6 requires that the accident monitoring instrumentation
channels shown in Table 3.3-10 to be operable. Instrument number 17 in
this table is the Steam Relief Valve Exhaust Radiation Monitor (EMF-26,
27, 28, or 29).
The Minimum Channels Operable column for this
instrument indicates "1".
In discussions with Region II personnel,
other resident inspectors and review of the Standard TS indicate that
the "1" should be "1 per steam generator or steam line". Discussions
with Duke Power Company (DPC) personnel indicate that this was
discussed with TS reviewers prior to initial issue of Catawba TS and
this omission was acceptable. This has been discussed with the present
TS group at NRR and they are reviewing this question.
Pending
resolution of this issue, this item is identified as Unresolved Item
413/85-55-08:
Clarification of TS 3.3.3.6, Table 3.3-10, Item 17.
7.
Evaluation of Part 21 Reports (92700) (Units 1 and 2)
The inspector reviewed licensee's actions relative to evaluation and
implementation of corrective actions relative to 10 CFR 21 reports forwarded
to the NRC which could affect the Catawba station.
Licensee actions were
reviewed for the below listed reports and these items are closed.
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P2184-01: Fuel Control Levers on DG Engine Are Not Pinned.
Licensee
inspection showed that Catawba DGs did not have the problem
identified.
P2184-02: Torque Limiter Failure, Rotork, Inc.
Licensee addressed
through CDR 413, 414/84-10.
P2185-01: American Air Filter Intake Silencer for DG. Unit 2 evaluated
acceptable.
Unit 1 being addressed via Unresolved Item
413/85-43-02.
P2185-02: CK Valves on Diesel Engine Air-Start Piping.
Unit i
evaluation addressed via SER 4.
Unit 2 addressed via CDR
414/85-05.
P2185-03: Failure of a Crankshaf t Oil Plug on TDI Diesel.
Licensee
inspection showed this item was not a problem at Catawba.
P2185-04: Nelson Elec Class 1035 Low Voltage Motor Control Centers.
Unit I long term corrective action has been implemented.
Unit 2 addressed via CDR 414/85-09.
P2185-05: Generator Control Panals Overheat.
Licensee evaluation
showed that this item was not a problem at Catawba.
P2185-08: K-Line Circuit Breakers.
Licensee evaluation showed that
this was not a problem at Catawba.
No violations or deviations were identified.
8.
Review of Licensee Nonroutine Event Reports (92700) (Units 1 and 2)
The below listed Licensee Event Reports (LERs) 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
significance 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.
- LER 413/85-25
Reactor Trip Oue to Steam Generator
Revision 1
Low-Low Level
- LER 413/85-28
Both Trains of Residual Heat Removal Inoperable
- LER 413/85-43
Manual Reactor Trip Following Loss of Main
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- LER 413/85-45
Reactor Trip Due to Isolation of Incorrect
Revision 2
Transmitter
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- LER 413/85-48
Inadvertent Actuation of Control Room
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Ventilation System
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- LER 413/85-51
Inadvertent Blackout During Diesel Generator
Revision 1
Operability Test
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Boron Concentration Not Verified During
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UHI Accumulator Feed and Bleed
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Reactor Building Penetration Radiation
Streaming
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- LER 413/85-61
Unit Shutdown Due to Excess Reactor Coolant
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Certain Fire Detection Zones Not Being
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Scanned by Computer for Unknown Reason
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No violations or deviations were identified.
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9.
Preoperational Test Program Implementation (70302 and 71302) (Unit 2)
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a.
The inspector conducted tours to verify that turned-over equipment was
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adequately protected and controlled. This review included observation
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of construction activities, observation for fire hazards and observa-
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tion of security boundaries.
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b.
The inspector observed conduct of portions of the preoperational test
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program. This included discussions with the test program director and
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test engineers, general observation of testing and operations in the
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control room (e.g., trouble shooting runs of Containment Spray Pumps)
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and observation of specific testing described below. This inspection
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was performed to assess whether the licensee was. conducting a well
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organized program, personnel had a good understanding of responsi-
bilities and conduct of specific tests, control' or organizational
,
interfaces was good, procedures were properly approved, control of test'
i
schedule was adequate and current drawings and manuals were used by the
!
licensee.
.
The test observed was as follows:
l
TP/2/A/1200/03A, Engineered Safeguards Features ' Functional Test,
I
Section 12.3, Train B, B/0 and LOCA ESF Actuation
!
i
!
!
!
!
i
i
i
_.
_-.
-
-
-
_.
-
.
. ..
..
..
..
._.
. -
1
.
'
l
10
-
!
-
1
!
The inspector also reviewed Construction Nonconforming Item Reports to
verify that appropriate documentation and evaluation was accomplished
.
for nonconforming conditions on systems being turned-over to operations
l
and reviewed maintenance of the Hydrogen Skimmer Fans (see para-
i
graph 5.c above).
No violations or deviations were identified.
-
,
j
10.
Fuel inspection, Assembly, and storage (60502C) (Unit 2)
,
d
This module is closed based on many previous inspections conducted under
.
!
module 60501B.
These previous inspections satisfy requirements for both
inspection modules.
!
No violations or deviations were identified.
]
11. Technical Specification Review (71301) (Unit 2)
This was a special inspection to determine if the proposed combined Unit 1
e d Uritt 2 TSS wer e cle4r, wer e erifurceable and matched the as-built plant.
1
It should be noted that this inspection was one of a number of inspections
!
performed on an ongoing basis to verify adequacy of TSs at Catawba.
,
Detailed review has been conducted relative to the Unit 1 TS including a
,
i
special team inspection.
Six inspections base been performed on Unit 2
i
comparing as-built plant to FSAR commitments and TSs including physical
'
walkdowns of systems as well as drawing comparisons (ref. Module 37301). An
NRC/RII inoffice review of the Proof and Review edition of the TS was
j
conducted and comments were forwarded to NRC:NRR (ref. Letter RII Walker to
'
1
NRR Thompson dated November 13, 1985). This inspection consisted primarily
j
of a review of the final draft combined TS against the existing Unit 1 TS
i
j
with selected referencing to the Standard TS, Rev. 5 and the McGuire Nuclear
'
i
Station TS.
Selected changes and inspector comments are documented below.
]
Comments include those relative to already proposed changes as well as
i
comments on changes which should be made. The inspectors consider that
,
j
those comments marked with an asterisk should be considered for incorpora-
t
tion into the combined TS for Catawba. These comments have been forwarded
,
!
to NRC:NRR by separate letter.
Followup on these comments by NRC and the
i
i
licensee is necessary,
therefore, tnis is Inspector Followup Item
i
i
413/85-55-09, 414/85-68-04:
Evaluation of TS Comments.
I
j
page No./TS No.
' Comment
i
!
j
- 1-9
Correct Table 1.2 " greater than" and "less
!
t
than" symbols in this Table.
1
I
2-2
Lower curve on Figure 2.1.1 for pressure has
been changed from "1700 PSIA to 1775 PSIA".
<
t
j
This corrects a typographical error. See NRC
letter to Duke Power Company (DPC) dated
!
j
January 10, 1986.
'
i
!
!
t
I
l
-
-
-
.
11
.
.
2-8
T' has been changed to <590.8 F (Nominal Tavg
allowed by " Safety Analysis") instead of
" Rated Thermal Power".
This is for clarification of a parenthetical
statement.
See 2-2 above letter.
- Pages B.2-1 - B.2-8
Unit 2 designation should be added to the
bottom of all pages.
3/4 0-1
Section 3.0.5 was added required for two unit
operation.
3/4 2-11
Curve 3.2-3 has been revised.
This was submitted by DPC to NRR in letter
dated 7/31/85.
Appears to be acceptable.
3/4 3-2 & 3-3
In Table 3.3-1, a double asterisk has been
added in the ACTION column at items 9. 10, and
13.
This cross-references instruments used in
Appears to be acceptable.
See DPC
submittals dated 7/22/85 and 9/11/85.
3/4 3-3
The ACTION statement in Table 3.3-1 has been
changed from statement 7 to statement 6 for
items 11, 12, and 16.a.
Statement 7 has been
deleted.
This appears to be acceptable.
See DPC
submittal dated 7/22/85.
3/4 3-3
Unit 2 turbine trip instrumentation in
Table 3.3-1 has been added at item 16.a.
Unit 2 uses stop valve EH pressure which
differs from Unit 1.
This appears to be acceptable - Unit I will be
changed
at
refueling
outage.
See
submittal dated 11/7/85.
3/4 3-3
In Table 3.3-1, the ACTION statement for item
16.b has been changed from 11 to 6.
State-
ment 11 has been deleted.
This does not appear to be a problem.
Reference DPC letter dated 7/22/85.
-
-
-
-
.- -
-
. -.
-
-. - ..
..
.-. -
..
f
i
,
l
12
.
,
4
.
.
3/4 3-5 & 3-6
In Table 3.3-1 ACTION STATEMENTS.for Items 2
,
and 6, the hours have been changed.
This does not appear to be a problem.
Reference DPC letters dated 7/22/85 and
9/11/85.
3
3/4 3-8 & 3-10
Unit 2 information has been added to
Tables 3.3-2 and 4.3-1.
r
3/4 3-15
The word " VENTILATION" has been removed from
i
'
the phrase
" Auxiliary Building
Filtered
Ventilation Exhaust Operation" in item 1.
This also applies to other areas where this-
title is used.
!
l
This appears to be acceptable since it is for
'
l
clarification and does not alter function of
i
system.
3/4 3-18 & 3-19
In Table 3.3-3, changed word " loop" to " steam
generator" in item 5.b and 6.c.
i
No change in intent.
3/4 3-21
In Table 3.3-3, deleted "6
" from items
8.g.1) and 2), and changed "5231" to "5232".
!
Clarification and correction of typographical
error.
i
3/4 3-26
In Table 3.3-3 ACTION STATEMENTS, item 24
!
has "with flow through HEPA filters and carbon
!
absorbers" added to the statement.
This appears to be acceptable. See NRC letter
dated January 10, 1986.
i
3/4 3-29, 30, 31
In Table 3.3-4, added Unit 2 information to
items 5.b, 6.c, 8.c, and 8.g.
'
3/4 3-32
In Table 3.3-4, Item 12.c, the symbol "<" was
i
changed to "<" in the Allowable Valve column.
Changed to meet STS, Revision 5.
}
3/4 3-40
In Table 3.3-5, deleted "NA" from item 13.
!
)
Typographical correction.
l
)
!
I
!
l,
-
-
-
-
-
-
- -
..
__
. -
-
-. ..
. . , ..
'
13
-
,
.
3/4 3-52
Unit 2 information added to item 2.b in
Table 3.3-6.
3/4 3-52
In Table 3.3-6, changed item 3 and 4 Alarm /
Trip Setpoint column from "<"_to "<".
See DPC correspondence dated August 17, 1984.
- 3/4 3-52
In Table 3.3-6, for item 4, the Applicable
'
Modes column has- been changed from "ALL" to
"I,2,3,4".
In addition, the action item 36
has been deleted.
Reinstate action item 36 for this item.
Change to applicable mode -discussed in DPC
'
correspondence dated November 8, 1985.
- 3/4 3-53
In Table 3.3-6, Table Notation "***" should
be changed to reflect a realistic submission
,
dose rato in containment for an operating
'
plant.
3/4 3-53
In various action statements, the term
.
" charcoal" has-been changed to " carbon". This
i
also appears to have been done in all
i
ventilation system discussions.
This appears to be acceptable. See DPC letter
dated November 8, 1985.
i
3/4 3-54
In Table 4.3-3, Unit 2 information was added
to item 2.b.
<
l
3/4 3-54
In Table 4.3-3 under " Modes for Which
'
Surveillance is Required", the word "ALL" was
!
changed to "1,2,3,4".
i
l
This appears to be acceptable. See DPC letter
'
dated November'8, 1985.
!
3/4 3-62
ACTION statement a. was changed from " Hot
!
Shutdown" to " Hot Standby" and "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />" was
changed to "6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Hot Shutdown within
i
j
the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />".
!
This was covered in ~ Federal Register dated
4
December 18,
1985 and NRR
letter dated
January 10, 1986.
l
4
!
j
!
-
- -
-
. .
-
-
.
.
-
.
.-.
.
.
.
-
-
_
.
1
14
.
'
- 3/4 3-63
In Table 3.3-9, the " READ 0UT LOCATION" for
items -6,
7,
& 8 should be changed to
" Auxiliary Shutdown Control Panel".
.;
i
,
i
To clarify correct location of these readouts.
t
3/4 3-65
See comments on page 3/4 3-62 for Action
Item a. and b.
j
3/4 3-67
Added Unit 2 to Instrument number 17.
1
.
-
- 3/4 3-67
For item number 17 under "Mirimum Channels
.
Operable" change "1" to "1/ steam line." Add
'
f
"and" in place of "or".
, ,
i
This is required to eliminate confusion that
action is required to be taken if the monitor
"
is lost since the monitors are for individual
!
steam lines and can not be used for other
i
steam lines.
.e
'
- 3/4 3-69
For item 17, change "or" to "and".
i-
!'
This is for clarification.
i'
d
- 3/4 3-70
Under action item a. and b.,
change " Charcoal"
1
to " Carbon".
1
i
To be consistent with other similar changes,
j
3/4 3-71
Changed " fire detection instruments" to
j
" smoke detection or flame detection instru-
,
ments"
in
4.3.3.8.1,
and changed " fixed
'
temperature / rate of rise" detection to " heat"
detection in 4.3.3.8.2.
Submitted by DPC.
See ' 0PC letter dated
December 20, 1985.
j
3/4 3.73, 3.74,
Changes made to include Unit 2, and changes
!
3.75, 3.76, 3.78
proposed in DPC letter dated December 20,
i
1985.
l
3/4 3-81 & 3/4 3-86
On Table 3.3-12 and 3.3-13 for items 1.a, 2,
'
TS 3.3.3.10
and 3 added "per station" to " Minimum
l
TS 3.3.3.11
Channels Operable" column.
)
Clarification.
.
- .
.
.
.
. .
.
.
-
.
15
.
~
e
~
.~
,
3/4 3-93
This TS change is as submitted by DPC in
correspondence dated April 29, 1985.
3/4 4-10
In action item c., "both" has been changed
to "more than one PORV".
This corrects the TS sfor having more than two
,
- 3/4 4-11
This TS should be revised to add surveillance
of the Nitrogen supply system to relief valves
'
as discussed in Bases 3/4.4.4.
s
3/4 4-17
In Table 4.4-1, two and three loop informa-
tion was deleted.
-
Deletion of unapplicable informption.
' -
- 3/4 4-20
Delete footnote at bottom.of page.
~
'
-
Eliminate confusion.
/
3/4 4-22 & 4-23
In Table 3.4-1, the "1"s.were deletedr
drawing numbers deleted and "RHR" wa.s changed
to " Residual Heat. Removal".
'
reference DPC letter
Editorial changes
-
December 20, 1985. ,
~
3/4 4-40
This TS was added.
Since reactor coolant vents are installed on
Unit 1, this is not a problem.
3/4 5-4
Added specific Unit 2 cold leg accumulator
water
level.
Prev,iously
submitted
and
reviewed and appears acceptable.
Ref. NRR/ Duke Letter of Jan. 10,-1986.
- 3/4 5-9 & 5-10
Footnote # appears inconsistent with surveil-
TS 3.5.3/4.5.3.2
lance in that it allows a charging pump and SI
pump to be operable but the surveillance only
allows a charging pump to be operable.
STS 4.5.3.2 states "0PERABLE pumps" in lieu"of.
'
s
"0PERABLE centrifugal charging pump". Comment
is applicable to exhisting' Unit 1 TS also.
This was discussed verbally 'previously with
NRR (Anderson) but 4.5.3.2 was never changed.
'
'
+-
-
. _ ,
.
.
_
.-
.-.
- .
-
-.
>
2
'
16
.
.
t
[
3/4 6-7
Penetration M328 added.
Previously submitted
'
',
TS 3.6-1
and appears acceptable.
Ref. NRR/ Duke Letter J
{
of Jan.10,1986.
!
3/4 6-14 & 6-15
" Charcoal" replaced with " carbon".
}
TS 4.6.1.8.a, b, c, f
Revised for consistency. Previously submitted
and reviewed.
Ref.
NRR/ Duke
Letter of
Jan. 10, 1986.
i
3/4 6-15
Deleted reference to ANSI N510-1980.
,
a.
Apparent inapplicable reference.
Previously
,
'
submitted and reviewed.
Ref. NRR/ Duke Letter
l
of Jan. 10, 1986.
l
3/4 6-17
Added " valves". Clarification.
Previously
j
submitted and reviewed.
Ref. NRR/ Duke Letter
,
'
of Jan. 10, 1986.
-
'
3/4 6-22 thru 6-29
Need to delete references to Unit 1 equipment
'
Table 3.6-2
in the Function columns.
Licensee should
verify valve numbers are the same for both
'
'
units.
Previous comment of RII.
3/4 6-36
Two separate action statements incorporated
for ice condenser doors capable of opening
automatically or not capable of opening
'
automatically. Previously submitted by Duke
and also a NRC:RII
request.
Acceptable
-
l
change.
,
!
3/4 6-36
Added "and".
Previously submitted by Duke
TS 4.6.5.3.1.b.2)
and also NRC:RII request.
Acceptable change.
,
3/4 .7-1
The action statement ultimately requires that
-
the unit be placed in " HOT SHUTDOWN".
This
made is less conservative than is required in
!
the Westinghouse STS Rev. 5, McGuire TS and
Catawba 1
TS
which
all
require
" COLD
SHUTDOWN". It is noted that in an NRR to Duke
,
letter of Jan. 10, 1986, this specific change
has been considered as
representing 'no
i
significant hazard.
.
i
- 3/4 7-11
This specification does not require that the
'
component cooling water system be tested to
'
verify automatic system start on a Blackout
I
signal.
FSAR Section 7.4.3 and other avail-
.
able information delineates that the system
"
receives a start signal on a Blackout.
It
F
9
-
p
.
.- -.
..
-_=
--
.
_ _ - .
.
.-
_
-
.
-
. - .
.
.
17
.
i
should be noted that McGuire TS do require
i
this test.
This comment applies to Unit I
also.
- 3/4 7-15
This specification requires in place testing
incorporating
the
guidance
afforded
by
Regulatory Position C.5.d of Reg. Guide 1.52,
Rev. 2, March 1978. The asterisk associated
with C.5.d should be made specific in that the
,
footnote refers to a technique employed to
achieve the result. It does not mean if that
technique is employed that it does not have to
be verified that the concentration is indeed
less than 0.01 ppm. This comment applies to
-
Unit 1 also.
- 3/4 7-31
Action statement "a" is ambiguous in that if
j
an hourly fire watch were established, then
the redundant protected equipment became
]
there
is
no requirement to
escalate the action statement.
This comment
applies to Unit I also.
- 3/4 8-6
There is no requirement to perform a surveil-
TS 4.8.1.1.2.g
lance
test
to verify that the diesel
,
generators can start two times off the air
bank with the compressors secured.
This
,
requirement is detailed in both the Westing-
'
house STS and McGuire TS.
This comment
applies to Unit 1 also.
l
- 3/4 9-3
The Westinghouse STS and McGuire TS require
100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of subtriticality prior to movement
!
of irradiated fuel. No justification could be
found to warrant reducing the margin of safety
associated with this longer decay time. This
comment applies to Unit 1 also.
t
- 3/4 9-9
There is no requirement to limit the travel
'
of a truck cask in the fuel pit and fuel pool
area.
Reference McGuire TS 3.9.7.
Duke
indicated
that
these
requirements
were
l
implemented by plant procedures.
,
t
5-3
Figure 5.1-2 has been changed to a smaller
covered area.
FSAR has been changed per Rev.11 to reflect
this change.
e
f
-
- . . - - -
-
-
.
-
- - -
- .
- - - - - .
.
-
.
-
-
. - -
-
-
.
- -
- - -
.
.
-
.
18
.
.
6-1
In section 6.2.2.b. and c. , the word "either"
has been inserted.
This appears to be a clarification.
This is
acceptable.
6-3
Figure 6.2-1 has been revised to depict
present offsite organization.
This appears to be acceptable.
- 6-4
Figure "6.6-2" should be 6.2-2 shows retitle
of
Administration . Superintendent,
Unit
Schedule Engineer and Licensing and Project
Engineer.
Also,
the
asterisk
for
the
Superintendent of Operations has been deleted.
Reinstate the asterisk for the Superintendent
of Operations, other changes are acceptable.
- 6-5
Table 6.2-1 has been changed to reflect two
unit operation. In footnote "*" at bottom of
page "8-hour" should be changed to "12-hour"
or deleted.
The change in the Table-is acceptable but-the
reference to 8-hour should be changed.
6-6
The double asterisk at the bottom of the page
has been added.
This was proposed by DPC letter dated
August 28, 1985.
6-7
In Section 6.5.1.3 and 6.5.1.5, the reference
to the Superintendent of Integrated Scheduling
has been added.
This proposal was submitted by DPC correspon-
dence dated July 31,-1985.
6-12
Section
6.6.1.b,
added Superintendent of
Integrated Scheduling.
See comment on item 6-7 above.
6-13
Section 6.8.2 and 6.8.3.c, added Superinten-
dent of Integrated. Scheduling.
See comment on item 6-7 above.
..
._
__
,
. . _ . , , _
_-
-
. . .
.
, _ _ _ . _ , . _
, . _ . . . , _
.
19
,
i
I
6-17 & 6-18
Section 6.9.1.7 - The last sentence in the
second paragraph has been deleted and replaced
j
with specific details as to what information
is required to ship solid waste offsite.
,
No justification or explanation available for
4
this change.
6-21
Item 1. of Section 6.10.2 for Unit 1 TS has
been deleted.
Section 6.10.3 has been added.
1
l
The word "Research" in 6.10.3 should be
changed to " Records".
This change subnitted by DPC letter dated
July 31, 1985.
No violations or deviations were identified.
12.
Surveillance Observation (61726) (Unit 1)
During the inspection period, the inspector verified plant operations were
in compliance with various TS requirements.
Typical of these requirements
were confirmation of compliance with the TS for reactor coolant chemistry,
refueling water tank, emergency power systems, safety injection, emergency
safeguards systems, control room ventilation, and direct current electrical
i
i
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 3nd 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 the nuclear instrumentation radiation
monitoring systems instrumentation, auxiliary feedwater system testing,
turbine stop valve, testing, containment spray pump testing, and diesel
generator testing.
No violations or deviations were identified.
13. Maintenance Observations (62703) (Unit 1)
Station maintenance activities of selected systems and components were
observed / reviewed to ascertain that they were conducted in accordance with
j
the requirements.
The inspector verified licensee conformance to the
requirements in the following areas of inspection:
the activities were
accomplished using approved procedures, and functional testing and/or
i
i
. - - . -
, - - -
-
--
.-
.
, - ,
. - .,- -
.-
,
_
_
_
.
_ ___
_ _ _ _ _ _ _ _ _ _ _ _ ,
,
20
.
.
calibrations were performed prior to returning components or systems to
service; quality control records were maintained; activities performed were
accomplished by qualified personnel; and, parts ar.d materials used were
properly certified.
Work requests were reviewed to determine status of
outstanding jobs and to assure that priority is assigned to safety-related
equipment maintenance which may effect system performance.
No violations or deviations were identified.
14.
Followup of IE Information Notices (92701) (Units 1 and 2)
The inspector held discussions with licensee operations engineering
personnel to determine if Catawba was affected by the potential problem
identified in IE Information Notice 85-94:
Potential fc- Loss of Minimum
Flow Paths Leading to ECCS Pump Damage During a LOCA. 'These discussions
indicate that the problem identified in this Notice does not exist at
Catawba.
The valves in the mini-flow lines are fail "as is" on loss of
power and procedural steps in emergency procedures provide a backup method
3
to check the operation of ECCS pumps. Based on this review and discussian,I"
this item is closed.
No violations or deviations were identified.
15. Operational Staffing (36301) (Unit 2)
j
The inspector reviewed the licensee's operational staffing to ascertain that
i
all staff positions were filled and that the personnel were qualified and
trained for their designated assignments. The licensee is committed to ANSI
N18.1-1971Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.1-1971" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Selection and Training of Nuclear Power Plant Personnel by
TS 6.3, and to Regulatory Guide 1.58, Revision 1, Qualification of Nuclear
Power Plant Inspection, Examination and Testing Personnel and SNT-TC-1A-1975
'
and 198 in Table 17.0-1 of the Duke Topical Report.
This review consisted
of 25 personnel in the following positions:
Shift Supervisors (licented)
Supervisors (unlicensed)
Reactor Engineers
Instrument and Control Supervisors
Radiation Protection Engineers
Radiochemist
Operators (licensed)
Nuclear Equipment Operators
Electrical Technicians
Mechanical Technicians
All personnel qualifications reviewed or exceeded the required training and
experience.
The Technical Support organization was compared to the
commitments contained in the FSAR and met these requirements.
9
l
i
t
.
-
__
_ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _
=
21
~
.
.
In addition, a review of procedure NDE-B, Training, Qualification, and
Certification of NDE Personnel, Revision 10 was performed to determine
compliance with SNT-TC-1A-1975 and 1980, American Society for Nondestructive
Testing Recommended Practice. The following comments were identified:
a.
Paragraph 5.1.1 - A statement should be made to require that a trainee
shall
work along with a certified individual.
Required by
SNT-TC-1A-1975, paragraph 4.2.
b.
Paragraph 5.1.1 - Include a requirement that a trainee can not report
or write a report of examinations - Required by SNT-TC-1A-1975 and
j
1980, paragraph 4.2.
c.
Paragraph 6 :2 and 7.2, second sentence - This sentence should be
'
,
clarified to include the specifics of SNT-TC-1A-1975 and 1980,
l
paragraph 6.2, which stipulates " prior to employer's written practice".
l
d.
Paragraph 6.2.3(3) - Change "in an assignment at least comparable to
l
that of an" to "as a certified". Required by SNT-TC-1A-1975, paragraph
6.3.1.c.
e.
Paragraph
8.2.3,
second sentence - Change "should" to "shall".
!
Required by SNT-TC-1A-1975, paragraph 8.2.c.2.
The above items collectively are identified as Unresolved Item 413/85-55-10,
414/85-68-05: Apparent inadequacies in NDE-B, Nondestructive Examination
Program, pending review and resolution of these comments by DPC QA
organization.
16.
Followup on Previously Identified Inspector Findings (92701)
(Units 1 and 2)
a.
(Closed) Inspector Followup Item 413/84-100-02:
Revision to 10 CFR 50.59, Review Form. The form used to perform 10 CFR 50.59 reviews has
been modified to require descriptive responses. The inspector reviewed
the form.
Based on this review, this item is closed.
b.
(Closed) Inspector Followup Item 413/85-46-02:
Cross-reference the
Incore Nuclear Instrumentation Calibration to the Flux Map Used to
Support Calibration. Change No. 8 to PT/1/A/4600/06A Incore Instrument
Detector Calibration was processed on January 9,1986, to -incorporate
this cross-reference as committed. Based on this review, this item is
closed.
c.
(0 pen) Inspector Followup Item 414/85-63-01:
Quality Release for
Reactor Vessel Internals.
The inspector reviewed a memorandum from
Westinghouse to the licensee stating that internals are acceptable.
Some minor work remains before the final Quality Release is forwarded.
This item remains open pending receipt of final paperwork but is not
considered a requirement for fuel load.
'
r-
.
22
,
e
d.
(Closed) Inspector Followup Item 414/85-63-02:
Filter Records.
The
inspector reviewed HVAC filter material records and these appear to be
acceptable.
No violations or deviations were identified.