ML20127M007

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

ML20127M007
Person / Time
Site:	Catawba, University of California - Irvine
Issue date:	05/30/1985
From:	Dance H, Skinner P, Van Doorn P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127L940	List: IR 05000326/2004025 ML20127L935 ML20127L998
References
TASK-2.K.3.10, TASK-TM 50-413-85-14, 50-414-85-11, IEB-84-03, IEB-84-3, IEIN-85-21, NUDOCS 8507010041
Download: ML20127M007 (10)

See also: IR 05000413/1985014

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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101 MARIETTA STREET, N.W.

ATLANTA, GEORGI A 30323

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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 ~~

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Approved by: ( (L'*

17. C. Dance,3 Section Chief

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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

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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-

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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.

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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

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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)

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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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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)

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The inspectors reviewed plant operations throughout the reporting period to

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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.

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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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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

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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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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 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. 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.

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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.

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13. Followup on IE Infonnation Notices (92717) (Units 1 and 2)

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The inspector held discussions with licensee instrumentation and operations

personnel to determine if Catawaba was affected by the problem identified in

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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)

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(Closed) IE Bulletin 84-03: Refueling Cavity Water Seal. The licensee's

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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

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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.

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