IR 05000413/1985012

Insp Rept 50-413/85-12 on 850318-22.No Violations or Deviations Noted.Major Areas Inspected:Surveillance Testing, Maint Activities,Operational Activities & Event Review

ML20127G363
Person / Time
Site:	Catawba
Issue date:	04/26/1985
From:	Gibson A, Julian C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127G351	List: IR 05000413/1985012 ML20127G348
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.5, TASK-TM 50-413-85-12, NUDOCS 8505210045
Download: ML20127G363 (19)

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p UNITED STATES g-

/ p Feig'o NUCLEAR REGULATORY COMMISSION

[ p REGION 11 g j 101 MARIETTA STREET. * 's ATLANTA, GEORGI A 30323

%, . . . . . ,o Report No.: 50-413/85-12

^ Licensee: Duke Power Company 422 South Church Street Charlotte, NC- 28242 Docket No.: 50-413 License No.: NPF-35 Facility Name: Catawba 1-Inspection Conducted: March 18-22, 1985 -

Inspectors: O-\b C.A.Julgn-TeamLeader u Y/2 8/

' Date Signed F. R. McCoy W. K. Poertner B. T. Debs C. Caldwell L. Watson- 7 R. Pierson ,

Approved by: N A. F. Githon', Branch Chief

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Z6 !Ib Date Signed Division of Reactor Safety SUMMARY Scope: This routine', announced inspection entailed 269 inspector-hours in the at 3as of Surveillance Testing, Maintenance Activities, Operational Activities,

-and Event Revie Results: No violations or deviations were identifie PDR ADOCK 05000413 G PDR

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I s REPORT DETAILS

.. Persons Contacted

^i Licensee Employee: .

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[ *G. Vaughn, General Manager Nuclear Stations, DPC -

• J. W. Hampton, Station Manager

• C. W. Graves, Jr., Superintendent Operations

• J. W. Cox, Superintendent Technical Services

• G. T. Smith, Superintendent Maintenance

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• B. F. Caldwell, Superintendent Station Services s 'i '

"T. B. Bright, Engineering Manager, Construction '

• E. M. Couch, Project Manager Construction

• C. L. Hartzell, Compliance Engineer

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• D. Tower, Operating Engineer

• A. S. Bhatnagar, Test Engineer "

• W. H. Barron, Senior Instructor n

• J. H. Knuti, Operation *W. W. McCollough, Mechanical Maintenance g

. * P. Deal, Station Health Physicist t

• T. D. Mills, Construction Engineering, Electrical

• T. H. Propst, Construction, Mechanical Technician

• H. Bradley, QA Surveillance Supervisor

• E. G. Williams, Project QA Technician

• LeRoy, Licensing Engineer l *D. M. Robinson, Reactor Engineer =

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• R. O. Sharpe, Nuclear Engineer R. B. Wilson, Planning Engineer '

D. R. Rogers, IAE Engineer J. B. Teofilsk, Operations

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Other licensee employees contacted included craftsmen, engineers, tech- i nicians, operators, mechanics, and office personnel.

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NRC Resident Inspectors i

• P. Skinner

• K. Vandoorn '

• Attended exit interview I l i l Exit Interview J The inspection scope and findings were summarized on March 22, 1985, with those persons indicated in paragraph I above. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio L

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s s s Licensee Action on Previous Enforcement Matters URI (413/84-93-02, 414/84-42-02) Downgrading of License Prep Tests to Quizzes - Clased - Sufficient justification for this downgrading was provide The licensee has committed to adequate preparation and review of exams prhr to them being administered which will preclude this problem in the futur URI (413/84-93-04, 414/84-42-04) Past Nuclear Equir, ment Operator Qualification Checklist Deficiencies - Closed - As a result of this inspection finding, the licensee has taken action to revise the conduct of completing task lists to preclude this type of event through management control and review of task training documentatio . Unresolved Items *

Three unresolved items were identified during this inspection. These unresolved items concern lack sf full adherence to Station Directive (SD)

3.2.2 during conduct of the periodic test program (paragraph Sa), removal of low pressure service water minimum flow interlocks from service without declaration of inoperability (paragraph Sb), and failure to provide for feedback of operating experience for mechanical maintenance technicians (paragraph 6e). Surveillance Testing Identification and Scheduling of Periodic Testing The inspectors reviewed the administrative control system for identifying and scheduling periodic tests. The objective of this review was to verify that surveillance testing required by Technical Specifications and other periodic testing prescribed by licensee commitments to the NRC were identified, controlled, and met the scheduling requirements of Technical Specifications. The review included verification of administrative control on scheduling surveillance tests required for mode change. The following documents were utilized in the review:

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Administrative Policy Manual for Nuclear Stations, Duke Power Company, Nuclear Production Department, Rev. 21, 10/1/83

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Catawba Nuclear Station Directive 3.2.2 (TS), " Development and Conduct of the Periodic Testing Program," Rev. 8, and proposed revisions to be included in Rev. 9

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Catawba Nuclear Station Directive 3.1.15 (0P), " Activities Affecting Station Operations or Operating Indications," Rev. 7

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Catawba Nuclear Station Directive 2.8.1 (TS), " Reporting Require-ment," Rev. 5

• An Unresolved Item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviatio _

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Catawba Nuclear Station Directive 2.1.7 (TS), "FSAR and Technical Specification Amendment Processing and Interpretation," Rev. 1 -

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Catawba Nuclear Station Directive 3.0.9 (TS), " Catawba Action List File (CALF)," Rev. 1 The licensee performs periodic test scheduling utilizing a computer 4 data base. Several printouts providing data for different applications are pulled from the data base. On a weekly basis, the Periodic Test Program printout is provided to all groups responsible for periodic -

testing. This printout identifies all periodic tests to be performed by the responsible group for the subsequent six-week period (or longer)

and also provides other pertinent information. The Periodic Test  :

Program covers tests performed on monthly or greater intervals. Tests 3 performed on less than monthly intervals are covered by Section j procedures and audited by a surveillance procedure on a monthly basis which is included on the Periodic Test Program tracking syste Printouts of the data base indicating the tests utilized in meeting each Technical Specification surveillance requirement and listing unit conditions / modes affecting tests are also availabl Each section is responsible for scheduling tests under their cognizance d

within the interval provided by the printout. The interval specified by the program meets the Technical Specification requirements. It was

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noted that in addition to the Periodic Test Program tracking, several of the other sections had their own tracking mechanism These tracking mechanisms were, in most cases, used instead of relying on the m Periodic Test Program. It was determined that in several areas, SD 3.2.2 was not utilized, resulting in a failure to follow procedure Examples include the failure to provide Performance and Compliance with  ;

an attachment showing tests were not performed within the time allotted by the progra In addition, tracking mechanisms had been developed by sections to handle specialized areas such as mode changes and -

surveillances dependent on Effective Full Power Days, that had cot been "

incorporated into the tracking procedures. These are examples of an e Unresolved Item (URI 413/85-12-01) pending further review by the licensee and will be examined during a future inspectio }

Provisions for monitoring tests which are not performed within the ~

appropriate interval due to plant conditions or inoperable equipment are provide In some cases, notification of the appropriate i individual was being handled under the provisions of other Station '

Directives instead of those specified by SD 3.2.2. This represents another example where the licensee is not fully implementing the

requirement of SD 3.2.2. The licensee has stated that SD 3.2.2 will  ;

receive a cross disciplinary review to assure that the procedure i reflects the appropriate tracking mechanism It was further noted by the inspectors that SD 3.2.2 only addressed the notification of Performance and Compliance when a test could not be  ;

performed within the required time interva The procedure did not C state that the Shift Supervisor had to be immediately notified if the -

test was not performed within the required interva The licensee -

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stated that SD 3.2.2 would be revised to require notification of the i Shift Supervisor when a test is not completed within the allowed TS --

interval. It should be noted that the licensee stated that failure to _

meet a surveillance requirement would be under the provisions of '

SD 3. _

The inspectors reviewed Station Directives 2.1.?, 2.8.1 and 3.0.9, 4

which described the methods used to assure that new surveillance _d requirements are identified and responsibility for the surveillances assigne The inspectors discussed the implementation of these documents with the licensee. No violations and deviations were identifie _

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b. Performance of Surveillance Testing ) 9 The inspectors reviewed selected procedures to assure that the j procedures had been performed within the required Technical Specifica- 3 tions interval. The inspectors reviewed documentation on tests which a were not performed within the computer program intervals. The tests -

were either delayed due to equipment inoperability or plant conditions "

or were not required on the computer program interval due to mode $

changes. No violations or deviations were identifie .:

The inspectors reviewed selected surveillance procedures assigned to ;

the Operations Section, Chemistry Section and Instrumentation and -

Electrical Section to assure that procedures correctly addressed all --

Technical Specification requirements. Emphasis was placed on those  ;

surveillances requiring performance at a quarterly, monthly, weekly, j daily, or twelve hour frequency. Consistent with the extent of the review performed, it appears that Technical Specification surveillance -

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requirements are adequately delineated within plant procedure ". .

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In one case, the procedure addressing the adjustment of level in the i cold leg accumulator, Operating Procedure OP/1/A6200/09, did not ;

included a precaution to assure that an accumulator boron sample was -

analyzed within six hours as required by Technical Specification 3 4.5.1.1.1.b. The chemistry scheduling procedure did, however, address -

the six hour requirement. Review of the completed procedure indicated ;

that the boron analysis was completed within the appropriate time -

frame. The licensee has agreed to include this precaution in the ;

procedure. No other discrepancies were note _

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The inspector reviewed selected data packages for completed surveil- i lance inspections and confirmed, in general, that the licensee had "

satisfactorily completed the surveillances as required within the -i requisite time interva One concern was noted with the quarterly -

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operational check performed on February 18, 1985, for the train "B" low ?

pressure service water minimum flow interloc This feature halts ;

radioactive liquid effluent releases when insufficient flow exists for 4 dilution. The inspectors noted an apparent calculation error which }

gave indication that the instrument was properly adjusted when, in a fact, the instrument was set in a less conservative manner than that ;

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required. As a result of other work performed by the technician on this instrument during the course of the operational check, an E-Max Optical Isolator was replaced. Improvements in current output as a result of this component replacement gave indication that the interlock may have fortuitously been within specification following replacemen A subsequent operational check was not performed following component replacement and consequently this has not been confirmed. During discussions with Operations personnel to determined if radioactive effluent discharges had been completed which would have relied on this interlock being properly set, it was noted that since February 15, 1985, as a result of change 6 to procedure OP/0/B/6500/14, the low pressure service water minimum flow interlocks had been by passed (set points adjusted to 0) duric.g radioactive effluent discharges since the instruments were considered unreliable. When questioned, Operations personnel replied that the instruments had not been declared incperable. The inspectors consider that the instruments should have been declared inoperable when it was determined that they would not be used due to unreliabilit Since that time, discharges have been accomplished under manual control with flow rates calculated every four hours as allowed in Technical Specifications. However, Technical Specifications state that this method of discharge may continue for only 30 days. The licensee stated that actions are currently underway to replace this flow control system with an improved design. The inspectors consider this item to be unresolved pending review of additional information. The resident inspectors will follow up on this item (URI-413/85-12-02).

The inspectors reviewed the methods used to ensure that required surveillances under Operations section cognizance are accomplished prior to making a mode change. The startup procedure and shutdown procedure are the documents which govern entry into each of the mode These procedures require each section to verify that all surveillances under their cognizance which are required to be complete for entry into the applicable mode have been completed. In the case of surveil-lances under Operations section cognizance, this verification is based on completion of three items each of which must be documente (1) All surveillances are current for the existing mode (2) The applicable premode performance test procedure which lists additional control room surveillances required to make a given mode transition has been completed. There is a separate procedure issued for each mode and each procedure is sectionalized with respect to existing mod (3) All surveillances required for the mode to be entered are indicated as current on the operations performance test computer printout. This printout lists all surveillance test procedures, the applicable modes for each procedure, the frequency required by Technical Specifications, the last date that the procedure was performed, and the next scheduled performance dat ,

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The method for ensuring required surveillances are completed prior to a mode change appears to be adequate for surveillances under Operations section cognizanc I

The inspectors reviewed the method in which the operating staff is I aware of surveillance testing in progress. Each surveillance test must '

be authorized for performance by .the Shift Supervisor. Prior to .l authorizing the test, the Shift Supervisor will have it logged in the Surveillance Test Log. Completion or termination of each test will also be noted thus constituting a logging out of each test that is not

.in progress. Consequently, this log constitutes a listing of all active surveillances in progres . Maintenance Activities An evaluation of maintenance practices was conducted. Included in this evaluation was a review of the following:

Work Requests Maintenance Procedures Removal and Restoration of Equipment Training Shift Coverage / Turnover The following procedures and directives were reviewed in conjunction with this evaluatio Catawba Nuclear Station Maintenance Manual Procedures:

1. 1.0 Work Request Preparation

1. 1.2 Instrumentation and Electrical Procedure Development Catawba Nuclear Station Directives CNSD 4.2.2 Independent Verification Requirements CNSD 3.1.15' Activities Affecting Station Operations or Operating Indications Station Procedures MP/0/A7600/06; Kerotest 1/2, 3/4,1 inch "Y" Type Globe Valve Corrective Maintenance MP/0/A/7650/02; Lubrication of Safety Related Equipment MP/0/A/2001/01;. Troubleshooting and Corrective Maintenance IP/0/A/3890/01; Controlling Procedure for Troubleshooting and Corrective Maintenance l

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lWorkRequest The work request: system was examined. - .The current work request backlog

.is.approximately 3000 items'. total. Of these, the majority are Priority-3 and 4 Work Requests. In most of-these instances, the work requests are in _ progress -or -are on hold awaiting Lparts or outside assistanc To~date,only,four priority I work requests have been issue . Catawba Nuclear Station Maintenance Manual Procedure Number 1.0, Work Request. Preparation, was reviewed. This procedure is in the process of being rewritten. The inspector's concern that failure. analysis is no adequately. addressed 'is being' corrected in the rewritten procedur The draft Revision 'of M.M.P.1.0 stated that corrective - maintenance work ; requests _(equipment -failure, : repair, etc.) shall be reviewed for-generic = failure implications. This includes equipment misapplication, maintenance : or operational errors, equipment or design deficiency and/or other failures ' that could affect other similar equipment, components'and system ALARA -planning is incorporated into work requests through utilization of:a Health ' Physics - (HP) technician assigned to the maintenance-planning staf .

This individual reviews the planned work and is responsible for ensuring :that . adequate radiation protection measures are implemented. This HP technician is also responsible for assigning

, the Radiation Work ~ Permit' Number, if appl 1 cable, to the Work Reques No violations or deviations were note ; Procedures

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Use of - procedures - within Maintenance - was reviewe In both the 1 Mechanical group and .I&E group', utilization of " skill of the trade" techniques in lieu of-procedures are used frequently, especially by I&E

. technicians due to the nature of the instrumentation work. Mechanical

, maintenance use of general . troubleshooting procedures is _ limited and'

infrequent. -IP/0/A/3890/01,' Controlling Procedure for. Troubleshooting and Corrective Maintenance, is used for -I&E : safety-related equipment

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when. the. exact cause of malfunction is undetermined ano a detailed

. procedure to perform this determination is'not practical. The. licensee stated that this" procedure is currently being revised to incorporate more specific guidance and signature requirements. This revision was not reviewed by the. inspecto ,

Independent verification, as it pertains to maintenance activities, was examined. ' Independent verification steps are -incorporated as needed-within _ maintenance procedures per the guidelines _ of MS Directive

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4_.2.2, Independent Verification Requirements. TypicJiy, these are steps which do'not require Quality Assurance verification but are of a safety-related natur To the; extent .of this~ review, the use of procedures was adequat Procedures- were detailed enough to perform their specified tasks and the intent of procedural compliance was not being circumvented through the. use Lof general. or non-specific procedures providing only rudimentary guidance.

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No. violations or deviations were note ' Removal and Restoration of Equipment I Catawba : Nuclear Station Directive 3.1.15 provides guidance for removal of an: instrument or component from service and its subsequent return to service. Removal: and' restoration: procedures include a checklist which must _be 1 completed L by control' room operational personnel prior to releasing _ the l equipment for maintenance. This list also addresses-Technical / Specifications applicability prior to removal and subsequent to return-to service. In_ addition, Technical Specification items which are removed from service -are noted in ~the Technical Specification Action Item List (TSAIL). _ Maintenance' and operational personnel appeared knowledgeable about these requirements. No violations or deviations were note . T.rai ni ng -

The licensee' is in the process of creating a system designated as the

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. Employee Training Qualification System (ETQS). This system will amplify and document' the present training system. The ETQS will provide a formalized framework such that each supervisor will know

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which . equipment his employees are familiar with as well as providing guidelines and qualification criteria for certification on a particular

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- compone_nt or - ~ equipment ite The present system in use doe's not formally utilize a tracking -system such that ' supervisory personnel can use documented evidence in assigning technicians to particular task Typically, maintenance . personnel complete a formal training course conducted 'at the corporate Technical - Trair.ing Center. This program

• includes an introductory phase of 4-6 weeks and subsequent Fundamental

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Mechanical . Maintenance phase or Basic Instrumentation and Electrical

Maintenance phase, depending upon the technician's area of expertise, of 18 .22_ weeks ~ duration. Upon completion of this program, the

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technician is assigned :to a maintenance group. ' After a period of development when the individual is closely supervised, the technician

..is given greater . responsibility _. and integrated into his assigned

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sectio At present, supervisors utilize an informal method to gauge the-individuals knowledge 'and expertise. Tasks are assigned by the

. supervisor based on his personal knowledge of a particular. technician's ability or professional development needs. .Upon implementation of the

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'ETQS, a formal' mechanism will' exist which will document which-technicians are qualified to do what as well as providing a guideline to. allow a- newly assigned technician to become integrated within his assigned section as rapidly as possibl ,In accordance with TMI Action Plan Item I.C.5, Procedures for Feedback of Operating Experience to Plant Staff (NUREG-0737), each app 11 cant for an. operating license sh'ould prepare procedures to assure that operating information pertinent to plant safety originating both within and outside the utility organization is continually supplied to operators

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and other personnel and is ' incorporated into training and retraining programs. These procedures should provide a means through which information from operating experiences can be readily related to the job functions of the recipients including maintenance personnel. The licensee has in place an organization, the Operating Safety Evaluation

' Program, which identifies, evaluates, and resolves for licensee nuclear stations the nuclear safety concerns through operating experienc This is coordinated through shared responsibilities of the licensee's general office and station. The specific delineation uof responsi-bilities is discussed in the licensee's Administrative Policy Manual for Nuclear Stations, Section 4-9, Operationc1 Safety Evalaution Program (OSEP). Section 4.9.6.1, Station Activities, states in part that a principle function of the OSEP to be performed at each station is the distribution of operating experience information to plant personnel in a timely and controlled manne . .

Maintenance compliance with these directives was examined. Operating experience information can be provided through a variety of mechanisms but is most typically submitted to Mechanical Maintenance, Instrumenta-tion and Electrical and Planning Groups through the Catawba License and Compliance Group or the Catawba Safety Review Group. The Instrumenta-tion. and Electrical Group has established an I&E Routing System which formalizes and documents the transmittal of this information to the technicians. This is accomplished by initialing a required reading list or attending a presentation with attendance taken and documente Formal mechanisms for assuring that personnel have been presented the required information is . lacking within the Mechanical Maintenance and Planning Group. In these groups the individual in charge receives the operating experience information but there is no formal mechanism in place to ensure that all individual technicians are adequately informe Although there is no evidence that the informal training which is occurring within these groups is inadequate, a formal training program, which ensures that pertinent operating experience information has been adequately promulgated and documented with records that can be retrieved and evaluated, is neede Having been recently licensed, Catawba has no TMI NRC order and the inspector could not identify a clear regulatory requirement to implement TMI item I.C.5. This is left as an-Unresolved Item (URI 413/85-12-03).

f. ' Shift Coverage / Turnover Mechanical Maintenance and Instrumentation and Electrical groups are-currently working rotating shifts in conjunction with operations personnel. The Planning group does not routinely provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> /7 day coverage although back shift support is provided if dictated by work requirement Mechanical Maintenance and Instrumentation and Electrical sections each have a daily meeting in the morning to provide for turnover to the day sectio In the evenings, no formal turnover occurs.but section supervisors discuss work in progress. Neither group utilizes a turnover checklist or turnover procedur No violations or deviations were noted.

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7. Operational Activities Conduct of Operations The inspector reviewed the following procedures:

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Operation Management Procedure (OMP) 2-1- Audit of Safety Tags and Tagout (R&R).

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OMP 2-3 - Operations Work Request OMP 2-5 - Operations Work List and Technical Memorandum OMP 2-14 - Temporary Modification OMP 2-16 - Control Room Conduc OMP 2-17 - Control Room and Unit Supervisor Logbook DMP 2-18 Tagout/ Removal and Restoration (R&R) Procedur MP 2-19 - Round Sheet OMP 2-22 - Shift turnove OMP 2-28 - Diesel Generator Logboo OMP 2-29 - Technical Specifications Logboo OMP 2-30 - Test Logbook OMP 2-31 - Control Room Annunciator Statu CNSD 3.1.10 - Control Room Access and Control

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CNSD 3.1.15 _ Activities Affecting Station Operations or Operating Indication CNSD 3.1.16 - Recorder Chart CNSD 3.1.18 - Investigation of Reactor Trip CNSD 3.1.19 - Action to take in Case of " Exceeding of Limits"

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CNSD 3.1.24 --Documentation of Allowable Operating Transient Cycle CNSD 3.1.26 - Operations Management Procedure CNSD 3.1.27 - Operations Management Responsibilitie CNSD 3.3.7 - Work Request Preparation.

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-' CNSD 4.2.1 - Development, Approval'and use of Station Procedure CNSD 4.2.2 - Independent. Verification Requirement SNDS 4.4.3 - Temporary Station Modification CNSD 2.8.1 - Reporting Requirement CNSD 2.8.2 - LER Reportability Guidance

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CNSD 2.8.3.- 10 CFR 21 Reportability Guidance

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_CNSD.2.8.4 - Incident and Station Report Format and Conten The ' inspectors interviewed operations personnel, reviewed applicable

. logs and other documentation to determine if operation of the plant was being conducted as described in the above listed procedures, and concluded that operational activities were conducted in accordance.with these procedures. -The inspector observed a shift turnover in the

. control room. The turnover was conducted in a professional manner and appeared to be quite thorough and conducted in accordance with operations Management Procedure (OMP) 2-22, " Shift Turnover". Technical Specifications The inspector verified that a copy of the current license and -

controlled set of Technical Specifications (TS) are maintained in the control room and that a program is in place to add TS amendments promptly upon issue. SD 2.1.7, "FSAR and Technical Specification Amendment Processing and Interpretation" describes the manner in which TS changes will be implemented and reviewed by the station groups. The amendments are handled by Licensing which issues them to the various sections which are in turn responsible for making procedure changes (if applicable). .The changes to procedures generated are . reviewed by an 4 independent nuclear safety review board' and the operators receive training on the amendment by the shift technical adviso The Technical Specifications and procedures are cross referenced in the Technical Specification / Performance Test Manual which balances the TS requirements against the procedure. This manual, like all documents, is updated by the Operating Engineer of Document Development (0EDD) to assure that it is current. In this case, the update occurs every six months. Another document, 'the Technical Specification Reference Manual,. relates the operational mode to the applicable component to the TS. The inspector noted that the only method of relating an instrument-to a. TS is by the ; Annunciator Response Procedure. The inspector observed that these manuals are used by the control room operator Within this area inspected, no violations or deviations were identified.

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12 Procedure and Documents

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The. inspector reviewed the controlling documents for writing, reviewing, implementing, -and changing procedures. The inspector reviewed selected procedures, drawings, and logs to determine if- they were being kept in accordance .with the controlling documents and also observed operations personnel in their use of procedure The inspector reviewed 0MP 4-1, " Procedure Writing Guide", .0MP 4-2,

" Procedure Justification Document", OMP 4-6, " Retype and Reissue of

' Procedures", and SD 4.2.1, " Development, Approval, and Use of- Station Procedures". These instructions provide detailed information on how to

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develop, obtain approvals of, and use preoperational,' permanent, and E

temporary procedures. The inspector noted that procedures are changed-for safety related equipment by using a Procedure Major Change Process Record. .This consists of Nuclear Safety Evaluation Checklist and an ALARA Checklist which analyze the safety and radiological impact of the change. The changes are reviewed and approved by the Safety Review Committee and are maintained with-the master copy. SD 4.2.1,-provides

- a list of ' people that are authorized to review procedure The

. inspector- then reviewed the following procedures to determine if they are being kept in accordance with the controlling documents:

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OP/1/A/6100/02, Controlling Procedures for Unit 1 Shutdown

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OP/1/A/6100/05, Unit Fast Recovery

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OP/1/A6200/09, Cold Leg Accumulator Operations

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OP/1/A/6100/03, Controlling Procedure for Unit 1 Operations

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EP/1/A/5000/1A, Reactor Trip Response

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EP/1/A/5000/IC6, LOCA Outside Containment

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EP/1/A/5000/IE,' Steam Generator Tube Rupture-The inspector noted that the procedures followed the recommended format, the change records were updated as required, the last ' working copy was in the front of the procedure folder in the control room, all changes and change numbers were entered on the controlled copy, the working copy and controlled copy were compared within- one week when ,

required, and all tagout removal and replacement forms were attached

.when: work was performed. In addition, all initial conditions, prerequisites, and procedure signoffs were filled in as required for !

procedures in progres The inspector observed that the control room operators have all necessary procedures available to them' (e.g. Operating Procedures, Emergency Procedures, Abnormal _ Procedures, Response Procedures) and

.that they are being used in accordance with the controlling document The OEDD 'is responsible for maintaining all procedures in an up-to-date status. The inspector noted one possible problem with the handling of procedure The Shift Supervisor is allowed to delete a step in a l procedure if certain criteria are met; however, there is no requirement t

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to review th'e deleted ~ step to determine if its dele' tion was. in fact .

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" proper under the. applicable circumstances. A step deletion is reviewed -;

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itLhas 'been ~ deleted from .the procedure several times and this

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-istdone only ' to determine if the procedure needs a permanent chang :The inspectors consider ' that ~ the licensee should take action to provided:a management review;to, ensure that steps are deleted in ~ an appropriate fashion. This _is identified-.as an _ Inspection Followup Item

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The inspector ' reviewed 'the. control room drawings and determined that r they are good quality and readily accessible to the operators. The

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-inspector: then selected ten drawings in the control room and verified

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. -that they are current to the master-copies' located ~'in document contro i The :0EDD is responsible for maintaining these documents and reviews

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each drawing on an annual basis to assure that it is up-to-dat ,

.Within this area inspected,. no violations or deviations were ,

' identifie > Independent Verification

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The inspector reviewed Operations Manual Procedure (OMP) 1-15, "Inde- -

~ ' pendentL Verification" and Station Directive (SD) 4.2.2, " Independent Verification Requirements'.' to determine if the licensee's procedures

'are in -order to assure that ' independent ' verification is carried out

properly in :accordance with the FSAR response to TMI Action Item I.C.6.- t The inspector also reviewed OMP 2-18, "Tagout Removal and Restoration" and l0MP 2-33, " Valve and Breaker Position Verification and Valve

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Operation"ito determine how these- procedures actually relate to inde-

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pendent verification. OMP 1-15 and SD 4.2.2 detail the actions to be

performed by. the operators when they are performing the independent-

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verificatio SD ' 4.2.2 gives 'the methods for ~ identifying and-n ' establishing the status of systems and the acceptable means of I accomplishing independent ' verification. OMP 1-15 gives the require-

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ments, methods-for-performing, and the components (valves and breakers) ,

that ' are required to be . independently verifie These procedures J

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lspecify that the operators are to act independently of one another j (although they may travel together while performing.the task) and that I all' safety-related equipment and equipment important to safety is to be '

independently verifie OMP 2-33 amplifies the independent verification process by providing the method for checking valve and

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breaker . position which includes the methods for positioning and checking locked valves. In addition, OMP 2-18 specifically states when

, andJwho; may waive .the requf- .. tnt for independent verification if necessar .

The ' inspector noted that the Quality Assurance (QA) Surveillance group had completed, an audit' of independent verification and had identified some ' deficiencies. : The QA Surveillance group recommended corrections

, 'to these _ deficiencies which included such items as adding flanges and hangers,- that are necessary to the operability of safety systems, to the required -independent' verification component list and training of maintenance personnel in independent verificatio !

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, iThe Loperators; are _ currently trained in the: use - of independent verification J in their : initial _ training program and _ they will - be

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-periodically retrained in their operator requalification program. The

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Nuclear ' Equipment Operators .(NE0's) are capable of performing valve

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and breaker lineups- (including . independent verification) Jon all- ECCS

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equipment;provided that'they have been certified on the ECCS systems.

- Therinspector noted that the all ECCS ' lineups are verified correct

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-priorfto entering mode'four. These procedures are in accordance with-theilicensee's FSAR response to TMI actions item-I. Within' this area inspected, no ~ violations or deviations were

. identifie ~ Maintenance of Required Logs xc 'The Linspector reviewed OMP 2-29, " Technical Specification Action Items

' Logbook". .This ' instruction requires that a logbook be maintained and

'that an entry be made in the logbook anytime - a limiting condition for-operations (LCO) cannot be met.withoet the associated actions state-ment, inoperable equipment causes operation- in an action statement, inoperable redundant equipment is not required in the existing ' mode, inoperable equipment due to _ surveillance requirements does not meet

. acceptance criteria" or is not performed within the specified- time m- . interval, or anytime equipment is made inoperable by the inoperability nof _ other equipment. The . inspector then reviewed the actual logbook

' maintained by the shift supervisor and determined that it is maintained and reviewed in accordance with the controlling document with one'

exception. The shift supervisors were not recording the time of thei weekly: review in the Llog. _ The inspector brought this to the attention-of the Shift Operating Enginee The inspector reviewed OMP 2-31, " Control Room Annunciator Status Log".

This . instruction requires that a log be maintained by the control room operator that lists all significant alarm and alert conditions. The-inspector- then reviewed the actual log and determined that itt is

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maintained properly and that the required reviews and audits were being performed in accordance with the Jcontrolling doc'ument. The inspector noted that a current set of annuciator response p'rocedures is located in the. control room and that it'is used by the operator Within this are . inspected, no violations or deviations were ,

~ identifie Support Group Interface to Operations-

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The inspector reviewed the interface of support groups such as Health Physics,, Quality Assurance, Maintenance and Security with Operation Discussions were held with the supervisors and personnel from Opera-tions as well as the _ support groups. The inspector noted that the

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Operations personnel at all levels feel that they have adequate support

>from 'the Health Physics, Quality Assurance, Maintenance and ' Security

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departments. The inspector. also noted some novel programs that aid in

the operations-support interface. One such program in place is the use

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of. Health Physics shift technicians that rotate on-shift with Opera-

. 'tions' personnel.. These technicians are partly at the disposal of the i shift: supervisor - for :such things as surveillance, ' releases,- and-Technical Specification related item Discussions with the supervisors :and personnel from the support groups revealed that they

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have a good working relationship with the Operations departmen ~

i The inspector ; discussed with the Superintendent of Operations and -!

' Maintenance the mechanisms in place for feedback .of ' generic. type

problems- found .at -other Duke plants that do not qualify as Licensee j

~ Event Reports and the methods of tracking to . identify -generic problems found at. Catawba. The discussions revealed that' there is no: formal

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! program-in place but that the superintendents and supervisors routinely

, meet for an , administrative review of all Duke plants and that some

' technical matters are discussed. The inspector also noted that~ the

- computer system used ; in tracking trend analysis for~ work requests cannot. flag an item of generic implication; however, a failure study is

performed on.each work' request to determine the cause of failure for a ,

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Sithin .this. area inspected, no violations. or deviations were

" identifie . ' General Observation of Plant Systems The ins'pectors toured portions of the control building, turbine building, and aux 111ary- building. Observations included tagout verifications, housekeeping <ai.J general plant condition The inspectors expressed ~ concern about the number of liquid leaks evident throughout the plant and consider that priority should be

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directed ' toward repair .of- these leaks at this time before the system becomes: radioactive'with resultant contamination and radiation exposure complications. The inspectors noted that many valves 'are tagged for leaks ' indicating maintenance work is required but it . appears that no -

priority is assigned to this- work. The inspectors noted that-there appeared to be' an' unusually large number of catch basins attached.to leaking valves. Licensee representatives indicated that there are:an excess of 250- catch basins in place. Licensee management further indicated that . a systematic approach is being formulated to correct

'those leaks which can be repaired during plant operations -and those

which will require outage attention. This is identified as an Inspector

Followup ~ Item (IFI 413/85-12-05).-

The inspectors noted - numerous in' valid annunicators lit in the control room. The licensee stated that I&E had agreed to repair approximately three deficiencies a day to resolve these problems. The inspectors

- _ endorse the'-licensees.prioritizing these deficiencie The. inspectors noted four Unit 2 valves that were danger tagged in the closed position and yet' valve indication indicated the valles to be open; The : inspectors notified the shift supervisor who took prompt action to correct the deficienc Further investigation determined that the tags- were con.d.ruction tags hung by the Construction System Group. The valves in question had no interface with Unit I and- were

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' originally hung to prevent backflow into Unit.2 systems which had been ,

previously flushe g; The inspectors noted that_ valves:are labeled within the. plant _but that the11abels are often' very difficult - to : read. ALARA concerns dictate-that valves be readily . identifiable and to this end, the licensee

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should consider improving the readability of valve tags. This is

. identified as an, Inspector. Followup Item (IFI 413/85-12-06).

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, Event-Review ~

R .The inspector reviewed the functions and performance ~of the Catawba

' Safety Review Group (CSRG). This organization existscas a result of Duke Power Company's' initiative and is not required b9 the licensee's Technical Specification According to -the CSRGs charter, this t organization "is an on-site independent technical . review. group established for _the purposes of examining and making detailed recommendations to manage.nent on plant operating characteristics, _NRC issuances, Licensing Information Service Advisories, and other

~ appropriate plant design and operating experience information from INPO,L NSS suppliers, 'etc., that may enhance- or improve plant. safety; reviewing and auditing routine plant activities to verify .that plant operations and maintenance activities are performed correctly; making recommendations that may improve . plant safety and operational per-

-formance; and conducting station incident investigations and preparing

. required reports."

The : inspector reviewed selected licensee generated Non-Routine Event . s

' Reports and followup . investigations by tthe CSRG. The inspector found these investigations tor be detailed and accurate and consistent with the information provided in the subsequent Licensee Event keports (LER)-

submitted to the NR An' inspector reviewed the draft Catawba Nuclear Station Directive 3.11.3 " Duke Power Company. Catawba Nuclear Station Materia 1' Condition."

This procedure divides the station into areas of responsibility by work

. groups and management who will have the responsibility to ensure that material' condition' standards are maintained. 'The procedure also provides a program of inspections.to identify and track deficiencie '

-The inspector found no violations or deviations in this are a; Post-Trip Review

, The inspector reviewed Station Directive 3.1.18 for post trip review cand the completed post trip review package for the following events

=1/14/85- Manual Trip Due to Loss of RCP Cooling 1/23/85- Trip From Lo Lo SG Level

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1/29/85: Reactor Trip During Blackout Test 1/31/85 Trip:During Loss of Control Room Test

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3 /14/85- N44. Nuclear Instrument Noise With N41 Placed in Trip The. ' inspector observed 'that the ' packages- were acceptable and showed evidence i of continuing improvement. The inspector . emphasized to

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Licensee management at. the .exi_t' interview that the purpose- of a post

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trip- review :(PTR) is to look1for equipment that did not perform correctly. The Catawba PTR emphasizes the cause of the trip and relies-

j heavily on the plant computer. Control ' room strip chart-recorders are only used as a-last resort. The inspector pointed out a recent failure

.of: overpressure differential temperature instruments at McGuire as -an exampla where review of ' strip charts revealed incorrect performance of equipment. Licensee representatives acknowledged their -understanding of these comment Xenon Transient

~During the-inspection period,-the plant encountered a substantial xenon transient. The causes and corrective action were examined. AEstartup-test was in progress on' March 18 to measure the maximum flux perturba '

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. ytion expected from a dropped - control ro With the reactor i at approx -

0-12:w,imately150% : power, as fully} inserted, anothera flux fluxmap mapwas take was Whenbut planned peripheral'

equipmentrod-

. problems ~ delayed the flux map. After niae hours, it was decided to

' delay -the test- and the rod was withdrawn to its former positio Within . hours, it became clear that a quadrant to - quadrant xenon-

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transient was -in progress and when a' nuclear -instrument (NI) surveil-lance test could not meet acceptance criteria, power reduction 'was-begun. -The surveillance ' calls for verification that all four NI

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channels read within 2% of each other 'and.with the xenon oscillation in

. progress,.the acceptance criteria could not be met. The worst observed

power tilt was as follows: With reactor thermal power of.48.5%, total-

- power.- in. quadrants 1 and 3. was indicated to :be 45.5% ' and 46.8%

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-respectively while quadrants 2 and 4 read 73.6%-and 30.5% respectivel This : is an 1 undesirable condition but allowed by the Technical

Specifications as the quadrant power tilt. limits are only ' applicable-for reactor _ powers exceeding 50%. -On March 19 power was reduced to 20%

and the oscillation was reduced for a period of time, but manifested itself again later that da o The reactor vendor was consulted and the situation reviewed by licensee management. It was-determined that no limits were in danger of being .

exceeded and the oscillation was dampening. Power was.again increased to approximately 30% to hasten the dampening and the .NI channels closely monitored to ensure'that no Technical Specification limits were

' exceeded. The inspector observed that during this transient,' licensee actions were timely, conservative and pruden No violations or deviations were identifie ~

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19. Followup On Previously Identified Items IFI - (413/84-25-03, 414/84-10-03) Indepth Surveillance of Reactor and Senior Reactor Operator Training by Quality Assurance - Closed. An inspector reviewed the licensee's Departmental Audit NP-84-9 (CN) dated June 11, 1984, which, 'in part, reviewed operator training record This action by the licensee is considered sufficient to close this ite IFI- (413/84-25-04, 414/84-10-04) Simulator Training Group Size -

Close Licensee training management indicated _that past inspection simulators training group sizes have been kept within the four trainees per group guidelines provided in the licensee Final Safety Analysis-Repor Technical Specification Training Concern Stated in In'spection Report (50-413/84-93,50-414/84-42). Although not addressed as an inspection followup item by the NRC, the' licensee has provided some documentation

'of . Technical Specification training for cold license groups 1 and Subsequent to the aforementioned inspection, additional Technical Specification training was provided as part of the licensee's requalification program. The inspectors found this initiative to an NRC concern both adequate ~and responsiv .

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