ML20127M007: Difference between revisions

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{{Adams
#REDIRECT [[IR 05000326/2004025]]
| number = ML20127M007
| issue date = 05/30/1985
| title = Insp Repts 50-413/85-14 & 50-414/85-11 on 850326-0425. Violations Noted:Failure to Adequately Evaluate Results of Procedures & Failure to Meet Tech Spec Requirements for RHR Sys
| author name = Dance H, Skinner P, Van Doorn P
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| addressee name =
| addressee affiliation =
| docket = 05000413, 05000414
| license number =
| contact person =
| case reference number = TASK-2.K.3.10, TASK-TM
| document report number = 50-413-85-14, 50-414-85-11, IEB-84-03, IEB-84-3, IEIN-85-21, NUDOCS 8507010041
| package number = ML20127L940
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 10
}}
See also: [[see also::IR 05000413/1985014]]
 
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    .
      i
                                                  UNITED STATES
          /p KrigDo #
                                        NUCLEAR REGULATORY COMMISSION
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                      2
                                              101 MARIETTA STREET, N.W.
                                              ATLANTA, GEORGI A 30323
        \  *****
                    /
        Report Nos.: 50-413/85-14 and 50-414/85-11
        Licensee: ~ Duke Power Company
                      422 South Church Street
                      Charlotte, NC 28242
        Docket Nos.: 50-413 and 50-414                        License Nos.: NPF-35 and CPPR-117
i        Facility Name: Catawba 1 and 2
        Inspection Conducted: Ma h 26 - April 25, 1985
        Inspectors:            ,  ,    suo,              M                    O    ,:fo    ~~
                      P. K. Vah Door                //- -
                                          [                                      Dafte Siped
                              .    >    14A/D -            w                3      A Ef
                      P. 70. Skidner                // ~                      pt[te S#jned'
        Approved by:              (  (L'*
                        17. C. Dance,3 Section Chief
                                                                                Y Jo!P[
                                                                                Date Signed
                        Division of Reactor Projects
                                                    SUMMARY
        Scope:    This routine, unannounced inspection entailed 238 resident inspector-
        hours on site in the areas of site tours (Units 1 and 2); review of 10 CFR 21
        implementation (Unit 1); maintenance observation (Unit 1); surveillance observa-
        tion (Unit 1); plant operations review (Unit 1); power ascension test witnessing
        (Unit 1); review of licensee conditions (Unit 1); Instrumentation - observation
        of work and work activities (Unit 2); preoperational test program (Unit 2);
        review of IE Notices (Unit 1 and 2); review of IE Bulletins (Unit 1); followup
        of licensee identified items (Unit 2); and followup of previously identified
        inspector findings (Unit 1 and 2).
        Results:      Of the 13 areas inspected, no violations or deviations were identified
        in 10 areas; two apparent violations were found in two areas (Failure to adequately
        evaluate the results of procedures, paragraph 7; and Failure to meet Technical
        Specification (TS) 3.0.4 requirements for the residual heat removal (RHR) systems,
        paragraph 8).
                    8507010041 850530 3
                    PDR    ADOCK 0500
                    O
  i
 
  . .
                                        REPORT DETAILS
      1.  Persons Contacted
          Licensee Employees
          J. W. Hampton, Station Manager
          E. M. Couch, Project Manager Construction
          T. B. Bright, Engineering Manager
          H. L. Atkins, QA Engineering Supervisor
          W. H. Bradley, QA Supervisor
          J. W. Cox, Superintendent, Techncial Services
          T. E. Crawford, Operations Engineer
          L. R. Davison, Project QA Manager
          M. K. Efird, Design Engineer, Electrical
        *W. G. Goodman, Projects QA
        *C. W. Graves, Jr., Superintendent, Operations
          R. C. Groves, Design Engineer Electrical
        *C  L. Hartzell, Licensing and Projects Engineer
          C. L. Jensen, Unit. Schedule Engineer
        *T. E. Holland, Operating Engineer
          R. A. Jones, Test Engineer
        - J. A. Kamer, Test Coordinator
        *G. Keener, QA Surveillance
        *P. G. Leroy, Licensing Engineer
        *D. Llewellyn, Construction Field Engineer
          T. D. Mills, Construction Engineer, Construction
        *C. Muse, Operating Engineer
          D. M. Robinson, Reactor Engineer
          D. Rogers, IAE Engineer
          R. O. Sharp, Nuclear Engineer
        *J. Stackley, I&E Support Engineer
          G. T. Smith, Superintendent, Maintenance-
'
          D. Tower, Operations Engineer
          Other licensee employees contacted included inspectors, construction crafts-
          men, technicians, operators, mechanics, security force members, and office
          personnel.
        * Attended exit interview
      2.  Exit Interview
          The inspection scope and findings were sumarized on April 25,_1985, with
          those persons indicated in paragraph 1 above. The licensee acknowledged the
          inspection findings with no dissenting coments. The licensee did not
          identify as proprietary any of the materials provided to or reviewed by the
          inspectors during this inspection.
 
, .
                                              2
    3.  Licensee Actio'n on Previous Enforcement Matters
        a.    (Closed) Violation 413/84-91-03: Failure to Follow Procedures to
              Change Torque Switch Settings.      The response for this item was
              submitted on December 14, 1984. The inspector reviewed and verified
              implementation of corrective actions described in the response and
              considers licensee actions to be acceptable.
        b.    (Closed) Unresolved Item 413/84-95-03:    Electrical Cables Not Properly
              Connected.    The specific cables identified with this item have been
              repaired.    The utility has conducted several surveys and have not
              identified additional areas and do not consider this to be a wide
              spread problem.    The inspector reviewed this area again and found no
              additional examples of this problem,
        c.    (Closed) Unresolved Item 414/84-35-01: Boric Acid Tank S/N RCN-244
              Incomplete Field Fabrication Weld Records. The inspector determined
              that weld records were not required onsite.      However, since the
              licensee was maintaining these records the inspector requested that
              appropriate corrected records be obtained. The inspector reviewed the
              records. Licensee actions are considered satisfactory.
        d.    (0 pen) Violation 413/83-55-01; 414/83-41-01: Failure to Implement all
              Requirements of Regulatory Guide 1.58, Revision 1. The response for
              this item was submitted on March 22, 1984. The inspector reviewed and
              verified implementation of corrective actions described in this
              response. One area of this response has not been fully reviewed and
              discussions between the inspector and QA management are in progress to
              complete this item. This will be completed in a subsequent report.
    4.  Unresolved Items
        An unresolved item is a matter about which more infomation is required to
      'detemine whether it is acceptable or may involve a violation or deviation.
        A new unresolved item is described in paragraph 5.
    5.  Independent Inspection Effort (92706) (Units 1 and 2)
        The inspectors conducted tours of various plant areas. During these tours,
        various plant conditions and activities were observed to detemine that they
        were being performed in accordance with applicable requirements and proce-
        dures.    No significant problems were identified during these tours and the
        various evolutions observed were being performed in accordance with applic-
        able procedures.
        The inspector reviewed the program for implementation of 10 CFR 21 require-
        ments in the Nuclear Production Department. Requirements are implemented by
        Station Directives 2.8.1, Reporting Requirements; 2.8.3,10 CFR 21 Report-
        ability Guidance, and 2.8.4, Incident and Station Report Format and Content.
        The inspector also verified that posting requirements of 10 CFR 21 were
        being met. During this review, the inspector noted that paragraph 5.3.2 of
 
                                                                    ,_
  . .
                                              3
        Station Directive 2.8.1 does not appear to require identification of
        problems for 10 CFR 21 applicability as required by 10 CFR 21 and NUREG
        1022, Question No. 22 guidance. In addition, it does not appear that
        requirements of 10 CFR 21.3(d)(3), relative to consideration of offered
        equipment, are clearly implemented in Station Directive 2.8.3, Enclosure 2.
        The licensee was requested to respond to these questions.          This is
        Unresolved Item 413/85-14-01: Adequacy of Part 21 Implementation.
        No violations or deviations were identified.
      6. 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
        the requirements. The inspector verified licensee conformance to the
        requirements in the following areas of inspection:      (1) activities were
        accomplished using approved procedures, and functional testing and/or
        calibrations were performed prior to returning components or systems to
        service; (2) quality control records were maintained; (3) activities were
        accomplished by qualified personnel; and (4) parts and 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 affect system performance. Examples of this
        observation was work performed to readjust flux penalty circuit, cleanup of
        the safety related batteries, and replacement of a cell in the security
        backup power supply system.
        No violations or deviations were identified.
      7. Surveillance Observations (61726) (Unit 1)
        During the inspection period, the inspector verified plant operations were
        in compliance with various Technical Specification (TS) requirements.
        Typical of these requirements were confirmation of compliance with the TS
        for reactor coolant chemistry, refueling water tank, residual heat removal,
        control room ventilation, and de electrical power sources. The inspector
        verified that surveillance testing was performed in accordance with approved
        written procedures, test instrumentation was calibrated, limiting conditions
        for operation were met, appropriate removal and restoration of the affected
        equipment was accomplished, test results met requirements and were
        reviewed by personnel other than the individual directing the test, and that
        any deficiencies identified during the testing were properly reviewed and
        resolved by appropriate management personnel.
        The plant safety-related batteries were reviewed to determine that battery
        records were reviewed to determine that the surveillances required by TS
        were being performed at the frequencies specified, that float voltages were
        correct, cells did not appear to be gassing excessively, that sediment was
        not building up at an excessive rate, and that when single cell chargers are
        used they are controlled by procedures and meet class 1E independent as
        specified in IEEE 384-1977. Other areas reviewed were spacing material used
          .-                    ,_      -      ..            _
                                                                      ---
 
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                                              4
        between the cells of the battery and if the cells were installed in accord-
        ance with manufacturers requirements. In addition, maintenance and charging
        procedures were reviewed to assure that equalizer charges are performed as
        required, and that individual cell voltages (ICVs) and specific gravities
        are properly compensated for temperature and electrolyte level.
        During this period records of TS surveillance conducted on the batteries
        were reviewed to assure that the data obtained met TS and procedural
        requirements. As a result of this review the inspector identified that for
        battery EBB Instrument Procedure IP/0/A/3710/08, Vital Battery and Terminal
        Post Inspection, was performed in whole or in part on 5/9/84, 7/25/84 and
        7/30/84. In each of these procedures, data that did not meet the acceptance
        criteria of the procedure being accomplished was recorded. The review
        process failed to identify that the acceptance criteria for three specific
        connectors was not obtained.    This review was conducted by both Instrument
        and Electrical supervision and Quality Control personnel. A discussion with
        engineering and Region II personnel concluded that these out of specifica-
        tion readings would not prevent the battery from performing its intended
        function. However, the inadequate review performed for these tests does
        constitute a violation for failure to adequately evaluate the results of
        procedures. This will be identified as a violation (413/85-14-02): Failure
        to Adequately Evaluate the Results of Procedures.
        In addition to the above, the inspector also witnessed the performance of
        the following surveillances in whole or in part:
        PT/1/A/4250/01A      -    MSIV Movement Test
        PT/1/A/4600/02A      -
                                  Periodic Surveillance Items Data-Mode 1
        PT/1/A/4250/02C      -
                                  Turbine Control Valve Movement Test
        IP/1/A/3240/04C      -    Excore Nuclear Instrumentation System (ENB) Power
                                  Range Calibration
        No additional violations or deviations were identified.
      8. Plant Operations Review (71707 and 71710) (Unit 1)
,
        The inspectors reviewed plant operations throughout the reporting period to
'
        verify conformance with regulatory requirements, TSs, and administrative
        controls. Control room logs, Danger Tag Log, Technical Specification Action
        Item Log, and the Removal and Restoration Log were routinely reviewed.
        Shift turnovers were observed to verify that they were conducted in accord-
        ance with approved procedures.
        The inspectors also verified by observation and interviews, that measures
        taken to assure physical protection of the facility met current require-
        ments. Areas inspected included the security organization, the establish-
        ment and maintenance of gates, doors, and isolation zones in the proper
        condition, that access control and badging were proper, and procedures
        followed.
 
  -
.
                                              5
        In addition to the areas discussed above, the areas toured were observed for
        fire prevention and protection activities. These included such thingt as
        combustible material control, fire protection systems and materials, and
        fire protection associated with maintenance and construction activities.
        On April 22, during review of the Control Room Operator's Log, the inspector
        noted that the plant was in a status that was in violation of TS 3.4.1.4.2
        which requires two residual heat removal loops be operable and at least one
        of the loops be in operation if the plant is in Mode 5 with reactor coolant
        loops not filled, in that loop 1A was inoperable due to maintenance being
        performed. Further investigation into this problem identified that loop 1A
        was placed in an inoperable status on 4/20/85 at about 4:00 p.m., and the
        reactor coolant loops were drained on 4/22/85 at about 7:00 p.m. This
        resulted in the plant being in violation of TS 3.0.4 which prohibits entry
        into an Operational Mode or other specified condition unless the conditions
        for the Limiting Condition for Operation are met without reliance on
        provisions contained in the Action requirements. When notified of this
        condition, the licensee took action to expedite work being performed on loop
        1A in order to meet TS requirements. This item is identified as a violation
        (413/85-14-03):    Failure to meet TS 3.0.4 requirements for RHR system.
        No additional violations or deviations were identified.
    9.  Power Ascension Test Witnessing (72528C) (Unit 1)
        The inspector witnessed on a sample basis some of the testing being
        performed during power ascension testing. The inspector reviewed these
        areas for understanding and communications between the operators and the
        reactor engineering group coordinating the test effort.      A review of the
        procedure was performed to assure that the latest changes had been approved
        and incorporated into the controlling documents, that the procedure would
        not deviate from TS, and that applicable TS were followed where required.
        The following is a list of tests or portions of tests that were witnessed:
        TP/1/A/2650/05        -
                                    Unit Load Transient Test
        TP/1/A/2650/06        -
                                    Unit loss of Electrical Load
        TP/1/A/2650/07        -
                                    Turbine Trip
        TP/1/A/2650/10        -
                                    Large Load Reduction
        No violations or deviations were identified.
    10. Review of License Conditions (92706) (Unit 1)
        a.    Operating Staff Experience (License NPF-35, Condition 10) (Unit 1)
              License Condition 10 of Facility Operating License NPF-35 requires that
              Duke Power Company (DPC) shall have a licensed senior operator on each
              shift who has had at least six months of hot operating experience on a
              similar type plant, including at least six weeks at power levels
              greater than 20% of full power, and who has had startup and shutdown
              experience. The licensee condition further requires that the NRC be
 
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  . .
                                                6
                notified at least 30 days prior to the proposed release of the advisors
                from further service.
                DPC notified NRR in a letter dated March 1, 1985, that this requirement
                would be met for 3 of the 4 shifts on or before April 3, 1985 and on
                April 17 for the remaining shift.    The inspector reviewed the records
                for experience, including startup and shutdown experience and
                identified that all senior operators on shift met this requirement
                prior to April 3, 1985.    Based on this review, the inspector concludes
                that this condition has been satisfied.
          b.  Safety Parameter Display System (License NPF-35, Condition 2.c(12)(b))
                (Unit 1)
                License Condition 2.c(12)(b) required that the Safety Parameter Display
                System (SPDS) be made operational prior to April 1, 1985. The licensee
                stated in correspondence dated March 15, 1985, that the system had been
                declared operational. The inspector reviewed the operations of this
                system and all procedures associated with this system. In addition,
                the inspectors witnessed a demonstration of the system in operation.
                Based on this review, the inspector concludes that this condition is
                satisfied.
          c.  Anticipatory Reactor Trip, II.K.3.10 (License NPF-35, Condition 2.c(13))
                (Unit 1)
                License Condition 2.c(13), requires that prior to exceeding 70% power
                DPC shall complete the turbine trip test to verify that the PORV's
                (Power Operated Relief Valves) will not be challenged when the
                anticipatory trip bypass is in effect.    This test is identified as
                TP/1/A/2650/07 - Turbine Trip. This test was witnessed by the resident
                inspectors and by a Region II inspector on March 27, 1985. The conduct
                of this test was successful. DPC correspondence dated March 28, 1985,
                reported this to NRR. Based on-the inspectors review and observations
                of this test, it is concluded that this license condition has been
                satisfied.
      11. Preoperational Test Program (70302, 70312, 71302) (Unit 2)
          The inspector conducted tours to verify that turned-over equipment was
          adequately protected and controlled. This review included observation of
          construction activities, observation for fire hazards and observation of
                                    '
          security boundaries.
          The inspector conducted further review of the system turnover process. This
          review included discussions with QA personnel, a preoperational test
          engineer, the schedule engineer and Unit 2 coordinator plus review of
          selected portions of turnover Nos. 2NCT-1, 2KCT-1 and 2KCT-2. This review
          was conducted to determine if turnovers were well coordinated and
          controlled, whether appropriate reviews and walk-down inspections were
          conducted by operations personnel, whether exceptions were being
 
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  .
                                              7
          appropriately reviewed by test personnel, and whether appropriate tagging
          was being implemented.
          In addition, the inspector reviewed training records for four test personnel
          to determined if appropriate training had been conducted in the areas of
          administrative controls, QA indoctrination, and technical training.
          The inspector reviewed two incidents which occurred while preparing for the
          Reactor Coolant System hydrostatic (hydro) test. One incident on April 19,
          involved overpressurization of both Residual Heat Removal (RHR) Systems up
          to the pump discharge check valves to approximately 2,000 psig for approxi-
          mately 3 hours. It appears that inadequate operational control existed in
          that check valves were bypassed and motor operated valves were left open      .
          allowing reactor coolant system pressure into the RHR system. In addition,
          the header into which the relief valve for this portion of the RHR system
          relieved was isolated, in effect, allowing no relief protection for the
          portion of the RHR system which was overpressurized.        The licensee is
          evaluating this incident for reportability.
          The second incident on April 20, involved overpressurization of the Volume
          Control Tank (VCT) and associated piping resulting in destruction of the VCT
,        and other equipment in the VCT room. Lack of appropriate operational
l        control appears to be involved in this incident also.          The VCT was
          apparently filled to a near solid condition allowing pressure to build up
          very rapidly until destruction occurred.    As in the first incident, relief
          protection was not provided in that the relief valve path was isolated.
,
          This incident was reported as a potential 50.55(e) on April 22, 1985.
          The inspectors discussed these incidents with the plant manager and
          expressed concerns that improved controls should be implemented in such
          areas as overall coordination of the hydro testing, procedural controls,
          training and provisions for relief protection prior to any further hydro
          testing.    The Plant Manager assured the inspectors that improvements in
          these areas would be implemented.
          These incidents are being reviewed by NRC regional personnel and will be
          addressed further in NRC Report 414/85-12.
      12.  Instrumentation (Com
          Activities (Unit 2) ponents and Systems) - Observation of Work and Work
          Requirements of installation of instrumentation are contained in various DPC
          specifications and site procedures.    The inspector observed installed
          instrumentation for plant process control for conformance to requirements in
          the areas of location, conformance to installation procedure requirements,
          use of specified materials and components, routing of tubing, supports,
          inspection, separation, record keeping, and physical protection.      Instru-
          ments observed were for Loop Nos. 2NV522, 2NV523, 2KC601, and 2KC602.
          No violations or deviations were identified.
                                                                                          J
 
                      -                              _
                                                        --
                                                                                                            -
  , .-
l                                                                  8
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      13. Followup on IE Infonnation Notices (92717) (Units 1 and 2)
.
            The inspector held discussions with licensee instrumentation and operations
            personnel to determine if Catawaba was affected by the problem identified in
'
                                                                                                                  l
              IE Information Notice No. 85-21: Main Steam Isolation Valve Closure Logic.                          '
            This problem does not exist at Catawba.
            No violations or deviations were identified.
l      14.    IE Bulletins (92703) (Unit 1)
l
              (Closed) IE Bulletin 84-03: Refueling Cavity Water Seal. The licensee's
'
              response to this item is contained in correspondence dated November 21 and
              December 31, 1984, and January 18, January 29, February 18 and March 22,
              1985.      The inspector reviewed this correspondence and discussed the
              responses with the Region II coordination for this bulletin.                      Based on the    ,
              discussions and reviews, the actions taken by Duke Power Company for the
              Catawba 1 unit is acceptable and this item is closed.
              No violations or deviations were identified.
      15. Licensee Identified Items 50.55(e) (99020) (Unit 2)                                                -
              a.    (0 pen) CDR 413, 414/84-01:                  Leaking Socket weld in RHR System. Since
                    the licensee had recently identified additional cracking in the RHR
                    . lines at their McGuire facility, the inspector requested the licensee
                    to inform him of further actions intended at Catawba. The licensee
                    provided a letter dated April 15, 1984, from Design Engineering Depart-
                    ment T. F. Wyke to the Station Manager at Catawba. The inspector
                    reviewed this letter and it appears that appropriate recommendations
                    have been made.                    In addition the inspector verified that operations
                    inspection of the affected area was being performed on each 12-hour
                    shift.  Further review of licensee actions will be conducted.
              b.    (0 pen) CDR 414/85-02: Radiographic Indications in Safety Injection
                    Cold Leg Accumulator Tank Welds. The inspector observed reexamination
                    of Accumulator 2D. The licensee has determined that rejectable defects
                    exist in the shell to upper-head weld of the 2D Accumulator. A further
                    report is required to be submitted to the NRC.
              No violations or deviations were identified.
        16. Followup on Previously Identified Inspector Findings (92701) (Unit 1)
              (Closed) Inspector Followup Item (413/84-53-01): Procedure Team Findings.
              Documentation identifying the corrective actions taken in response to the
              major corrective actions identified in Enclosure 1 of Inspection Report No.
              50-413/84-53 was reviewed by the inspector. A sampling of procedures was
      .
                ..
                                _ - _ _ _ _ _ - _ _
 
(,
  ..            . . .
                                                                            9
                          performed in addition to the procedure reviews conducted on a periodic basis
                          by the inspector. Based on this review the licensee has taken actions to
                        - incorporate NRC team comments and suggestions into their procedure
                          preparation and issue process.
              4
                      e
          4
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      ' ' '        '
                                                  - - - _ _ . . _ - _ _ -
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