Text

Insp Rept 50-413/87-21 & 50-414/87-21 on 870617-19.No Violations or Deviations Noted.Major Areas Inspected: Closeout of Open Insp Items
	ML20235X449
Person / Time
Site:	Catawba
Issue date:	07/17/1987
From:	Lawyer L, Long A, Shymlock M; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20235X418	List: ML20235X415; ML20235X449;
References
	50-413-87-21, 50-414-87-21, NUDOCS 8707240190
	Download: ML20235X449 (11)
	v • d • e

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, pM REGg UNITED STATES

f 'o RUCLEAR REGULATORY COMMISSION

~

l o REGION ll

5 j 101 MARIETTA STREET, N.W.

' 2 ATLANTA, GEORGI A 30323

\...../

Report Nos.: 50-413/87-21 and 50-414/87-21

Licensee: Duke Power Company

422 South Church Street

Charlotte, NC 28242

Docket Nos.: 60-413 and 50-414 License Nos.: NPF-35 and NPF-52

Facility Name: Catawba 1 and 2

Inspection Conducted: June -19,,1987

Inspect rs: . AW Date Signed

vA.R. pong

k (N e sn 'ACO7

L.'L. Lawyer ~ '

Date Signed

Approved by: / /. -

/,, 7[/7[f'7

M. B. Shymlock', Section Chief 1' ' Date Signed

Operations Branch

Division of Reactor Safety

SUMMARY

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Scope: This routine, announced inspection was in the area of closecut of open

inspection items.

Results: No violations or deviations were identified.

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REPORT DETAILS

1. Persons Contacted

Licensee Personnel:

G. Barrett, Training Records Document Control Specialist

H. B. Barron, Superintendent of Operations

W. H. Barron, Director of Operations Training

M. A. Cote', Licensing Specialist

J. R. -Fergeson, Unit Scheduling Engineer

C. L. Hartzell, Compliance Engineer

M. Janeski, Operations Training Instructor

R. Neigenfind, Staff Engineer

G. C. Rogers, Project Engineer

R. T. Simril, Assistant Operations Engineer

G. T. Smith, Superintendent,-Maintenance

R. F. Wordell, Superintendent, Technical Services

Other licensee personnel contacted included engineers, technicians,

operators, mechanics, security office members and office personnel.

NRC Resident Inspectors

M. Lesser, Resident Inspector

Attended Exit Interview

2. Exit Interview

The inspection scope and findings were summarized on June 19, 1987, with

those persons indicated in paragraph 1 above. The inspectors described

the areas inspected and discussed in detail the inspection findings,

including those listed below. No dissenting comments were received from

the licensee.

Item Number Status Description / Paragraph

IFI 414/87-21-01 Open Design and Implementation of Corrections to

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Identified Human Engineering Deficiencies

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VIO 414/86-27-01 Closed Procedural Errors and Failures to Implement

Procedures . on Loss of Control Room Test

(Paragraph 3.a)

UNR 414/86-27-02 Closed Failure to Provide Adequate Operator

Requalification Training on loss of Control

Room (Paragraph 3.b)

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UNR 413/86-05-05 Open Environmental Qualification of Hydrogen

Skimmer Fans - Open Pending NRC Policy

Determination (Paragraph 3.c)

IFI 413/86-05-01 Open Revision of Station - Directive 3.2.2 to !

Require Shift Supervisor Notification of- 1

Missed Surveillance Tests (Paragraph 5.a)

IFI 414/86-07-03 Closed Review and Implementation of Environmental

Qualification Maintenance Program (Paragraph

5.b)

The licensee did not identify as proprietary any of the material provided

to or reviewed by the inspectors during this inspection.

3. Licensee Action on Previous Enforcement Matters (92702)

a. (Closed) Violation 414/86-27-01: Procedural Errors and Failures to -

Implement Procedures on Loss of Control Room Test

During the Unit 2 Loss of Control ' Room Test on June 27, 1986, the

transfer of control of Steam Generator Power Operated Relief Valves

(PORVs) to the Auxiliary Feedwater. Pump Turbine Control Panel

(AFWPTCP) erroneously commanded all four PORVs to open to seventy-

five percent of full stroke. Reactor pressure and pressurizer level,

which had been decreasing slosly as a result of the cooldown after

the reactor trip at the start of the test, fell rapidly. Within a 1

minute of the transfer, pressurizer level indication was lost, and I

within two more minutes pressure had dropped below 1845 psig gener-

ating a safety injection (SI) demand signal. By design, the transfer

of control to the auxiliary panels had blocked automatic SI initia-

tion. After another three and one-half minutes of unsuccessful

attempts to manage the situation from the suxiliary panels, control

was returned to the control room. The transfer back to the control

room automatically intiated SI. By this time pressure had dropped as

low as 702 psig. 1

The underlying cause of the event was the failure to specify in the

Design Change Authot izatf on or other documents that the mode of 1

control of the steam generator PORV controllers at the AFWPTCP had i

been changed. This in turn led to a failure by station personnel to I

change procedures and train operators on this modification. The i

situation was further exacerbated by human engineering deficiencies

introduced by the modifications. Other contributing factors included

the lack of a human engineering deficiency review of the shutdown

panels, inadequate training on shutdown panel instruments and

controls, inconsistencies in labeling of instruments and controls,

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and reluctance to terminate the test. l

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The NRC issued a Confirmation of Action Letter (CAL) on July 3,1986,

containing corrective actions applicable to Units l' and 2. As

documented in NRC Inspection Reports 413/86-27, 414/86-30, and

413/86-36, 414/86-39 the corrective actions in the CAL were completed

and the test was successfully repeated on July 11, 1986.

NRC Inspection Report 414/86-27 identified as Violation 414/86-27-01 )

five examples of inadequate procedures or failures to follow proce- 1

dures related to the June 1986 depressurization event. The five. )

. examples of Violation 86-27-01 were subsequently cited as two

violations in Escalated Enforcement Action (EA) .86-147, issued

November 12, 1986. The licensee responded on December 12, 1986, with

an admission of Violation A with comments, and a denial of Violation j

B. As a result, the NRC modified Violation' B.2, and stated in the _;

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April 14, 1987 letter to the ' licensee that additional. corrective

l actions were necessary for the item. Corrective action commitments

for the other items in the Notice were considered acceptable by the

NRC.

(1) EA 86-147 Violation A.1: Failure to Review Design Change

Authorization for Impact on Established Operating Procedures

Background:

The licensee's program for design controls had not assured that

Design Change Authorization (DCA) CN-2-M-1527, which changed the

design basis for the mode of control for the Steam Generator

(SG) Power Operated Relief Valves (PORVs), was reflected in

necessary procedural modification. DCA CN-2-M-1527 was not

properly reviewed by plant personnel as required by ' Station

Directive 3.0.3, Management of Shutdown Requests, for the

effects on existing ope rr.ti ng procedures. As a result,

Procedure OP/2/A/6100/04 was not modified and incorrectly

specified the setpoint of the SG PORVs. Instead of remaining

closed, the SG PORVs opened to approximately 75 percent of full

open, contributing to the depressurization event.

In the December 12. 1986, response to the Notice of Violation,

the licensee stated that the following corrective actions had

been implennted prior to the restart of Unit 2:

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A review of all Unit 2 design changes and shutdown requests

implemented after Hot Functional Testing And prior to Fuel

Load

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Revision of the Auxiliary Shutdown Pan 91 operating proce-

dure and the Loss of Control Room abnormal procedure to

reflect the changes to the panels.

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Resolution:

Prior to the restart cf Unit 2, the licensee reviewed all Unit 2

Design Change Requests (DCRs) and Shutdown Requests implemented ,

between Hot Functional Testing and Fuel Load, for ef fects 'on j

established procedures and for human factors significance.. The

inspectors reviewed the . findings presented in a letter from

W. R. McCollum to File, dated July 3,1986. The licensee DCR

review identified the need to replace a particular valve label

which. contained a typographical error. The licensee verified

for the inspectors, by checking the label on the valve, that

this relabeling had been accomplished. The- licensee review of

Shutdown Requests identified the need to add Lighting Panel and

Breaker numbers to Procedure HP/0/B/1001/18, EMF Sampling. The

inspectors verified that this was accomplished in Revision 3 to ,

the procedure, approved December 15, 1986. Also as a result of

the review of Shutdown Requests, Procedure OP/2/A/6200/01, ,

Chemical and Volume Control System, was ravised on February 3, j

1987, to properly indicate new controller locations on the valve

checkli sts.

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The inspectors verified that Operating Procedure OP/2/A/6100/04, I

Enclosure 4.5 has been modified to specify the correct initial

positions for 2NV-294 and ENV-309 based upon the test data from

TT/2/A/9100/03, Auxiliary Shutdown Panel and Turbine Centrol 3

l Panel Supplemental test, which was written to verify proper l

functioning of the various valves while at the Auxiliary Shut-

l down Panel (ASP). This test was performed satisfactorily prior

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to the Loss of Control Room retest on July 11, 1986.

The inspectors also verified that training on the aforementioned

, procedure changes has been included in operator requalification j

l training (Paragraph 3.b). l

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(2) EA 86-147 Violation A.2: Failure to Adequately Review Shutdown

Requests for Human Factors Considerations as Required j

Background:

The control mode of the Steam . Generator (SG) Power Operated j

Relief Valves (PORVs) had been changed through Design Change

Authorization (DCA) CN-2-M-1527 without any visible change to .

the SG PORV controller or labeling at the Auxiliary Feedwater '

Pump Turbine Control Panel (AFWPTCP). This. occurred as a result

of the DCA not having been properly reviewed by' design

personnel.

The licensee stated in the December 12, 1986 response to the

Notice of Violation that the following corrective actions h'ad

been completed or were ongoing:

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A review of Main Control Board, ASPS and AFWPTCPs for both

units to identify differences between units and to verify

proper labeling nomenclature and units of measure (prior to

Unit 2 startup).

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Revision of Design Procedure EDP-3.17, Control Room Change

- Handling, to clarify the need for review of modifications

to the ASP and AFWPTCP and to clarify responsibility for

initiating the Control Room Change Form

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Revision of Instrumentation and Controls Workplace proce-

dure PR-3 to assure emphasis on labeling and scaling of

manual loaders, controllers, etc.

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Correction of all Human Engineering Deficiencies identified

l in NSM-CN-20227

Resolution: l

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The inspectors verified that prior to the restart of Unit 2, the

licensee reviewed all Unit 2 Design Change Requests (DCRs) and

Shutdown Requests implemented between Hot Functional Testing and ;

Fuel Load, for human factors significance as well as effects on j

established procedures (Paragraph 3.a 1). 1

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The inspectors observed the ASP and the AFWPTCP labeling nomen-

clature, meter unit designations, and controller position

labeling changes and verified that significant human factors

improvements had been made to the panels. This observation

confirmed that "0" and "C" (0 pen and Closed) labeling had. been ,

adaed to the panels, as well as labels which clearly identified j

the control mode of the Steam Generator PORV controllers. -

Design Procedure EDP-3.17, Control Room Change - Handling, was

revised to clarify the need for review of modifications to the

Motor Driven Auxiliary Feedwater Pump Control Panels, the ASPS

or the AFWPTCPs by the appropriate Design Group. _ Revision ' 3,

dated August 4,1986, clarified that the procedure applies to

the subject panels when the arrangement of. devices is modified;

when operator interface devices are added, deleted, or modified; 4

or when the appearance, labeling, or functioning of a device on

j the subject panels is modified.

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l The Electrical Division Procedure ECPI-PR-3 was revised to l

ensure emphasis on labeling and scaling of manual loaders,

controllers, etc. This was accomplished in Revision 1, dated

April 24, 1986, by changing Section 6.11, Operator Interface, to

read, " Scaling and labeling of components to support the

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functional description should be reviewed and documented on the

I&C list and the Instrument Detail. When changes or additions

to Main Control Boards, Auxiliary Shutdown Panels or Auxiliary

Pump Turbine Control Panels are required, a human factor review

in accordance with EDP 3.17 shall be requested."

As required by the Confirmation of Action Letter of June 27,

1986, the licensee reviewed all Human Engineering Deficiencies

(HEDs) identified in NSM-CN-20227 and their schedules for

implementation. As a result, complete re-engraving of al.1

nameplates on the ASPS and AFWPTCPs was accomplished prior to

August 22, 1986. As discussed in a July 30, 1986 letter, the

! remaining portions of NS'M-CN-20227 could not be implemented at

l that time since the remaining section required de-energizing

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part or all of the systems on the ASPS or the AFWPTCPs. All

HEDs are required to be corrected- prior to restart from the

first refueling outage in accordance with the Facility Operating

License. The design and implementation of corrections to the

HEDs identified in NSM-CN-20227 will be reviewed in a future

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inspection and will be tracked as IFI 413,414/87-21-01. <

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The inspectors verified that training was provided to appro-

priate personnel and included labeling and surface changes .made

to the ASPS and Unit 1/ Unit 2 control differences.

(3) EA 86-147 Violation B.1: Erroneous Valve Setpoints

Background:

During the Loss of Control Room test on June 27, 1986, depres-

surization occurred due to an inadequate procedure. . Enclosure

4.5 of Operating Procedure OP/2/A/6100/04, Shutdown Outside the

Control Room from Hot Standby to Cold Shutdown'specified initial '

settings for valves 2NV-294 and 2NV-309 which were inappropriate

and resulted in tnese valves assuming an incorrect. position when

control was transferred to the remote shutdown panels.

Resolution:

The inspectors verified that Operating Procedure OP/2/A/6100/04,

Enclosure 4.5 has been modified to specify initial positions.for

2NV-294 and 2NV-309 based upon the test data from j

TT/2/A/9100/03, Auxiliary Shutdown Panel and Tur31ne Control j

Panel Supplemental Test, which was written to verify proper

function of the various valves while at the ASP. This test was

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performed satisfactorily prior to the Loss of Control Room l

retest on July 11, 1986. !

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(4) EA 86-147 Violation B.2:

- Failure to Transfer Control Back to

Control Room

Background:

Test Procedure TP/2/A/2650/03, Loss of Control ' Room Functional

Test, was not properly implemented in - that control was not

transferred back to the control room when a situation arose that

could not be adequately c .ntrolled from the auxiliary shutdown

panels.

Resolution:

Operator requalification training specifically itddressing proper

l implementation of TP/2/A/2650/03 and lessons learned from the

l June 27, 1986 depressurization, has been completed for all

reactor operators and senior reactor operators (Paragraph 3.b)

(5) EA 86-147 Violation B.3: Remote Shutdown Panel Labeling

i Background:

Operations Management Procedure OMP 1-6, Control Panel Informa-

tion Changes, dated May 10, 1982, stated that any informational

changes to the control panel will conform to human factor

guidelines and agree with the setpoints, limits, and precautions

established in approved operating procedures. Contrary to this

procedure, the labels on the controllers at-the remote shutdown

panel for valves 2NV-294 and 2NV-309 were re' versed and indicated

the opposite of the intended and anticipated meaning. The NRC

considered the effect of the valve mislabeling to be significant

to the June 27, 1986 depressurization event.

Resolution:

The inspectors verified that the relabeling of .the ASP control-

1ers for valves 2NV-294 and 2NV-309, and other modifications to-

the ASP, had been approved and dncumented on the OMP 1-6 forms -

for control panel informational changes.

Through interviews with licensee personnel, the inspector

verified that OMP 1-6 is now being used to document control

panel labeling changes.

Except for the resolution of the identified Human Engineering Defi-

ciencies, which will be- tracked as IFI 414/87-21-01, the inspectors

concluded that the licensee had corrected the previous problems and

developed corrective actions to preclude recurrence of- similar

problems. Corrective actions stated in the licensee response to the

Notice of Violation have been implemented. The item is therefore

closed.

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l b. (Closed) Unresolved Item 414/86-27-02: Failure to Provide Adequate

Operator Requalification Training on Loss of Control Room

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Background:

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Prior to the June 1986 depressurization event, an upgrade of .the

Steam Generator PORV had been performed in accordance- with DCA

CN-2-M1527. This change as applied to the AFWPTCP led to confusion

because the operator was unaware that the same pressure setpoint

varying controller was being used to indicate and control Steam

Generator PORV valve position. Training was deficient in not

adequately teaching the Steam Generator PORV design change: to each

licensed operator and senior operator.

NRC Inspection Report 414/86-27 identified as a violation the failure

to provide adequate operator requalification training on facility

design changes in acccrdance with Technical Specification 6.4.1. The

NRC letter f rom J . Helson Grace to Duke Power Company, dated

November 12, 1986, stated that in accordance with the current NRC

policy statement on training and qualification of nuclear power plant

personnel the violation was not cited.

Resolution:

The Steam Generator PORV design change as performed under DCA

CN-2-M1527 displayed several deficiencies, predominately in the human

factors engineering aspects of the change. These deficiencies were

identified in Nuclear Station Modification NSM-CN-20227.

Deficiencies relating to changes to nameplates and labels on the ASPS

and AFWPTCPs were identified, incorporated into lesson plan

transparencies and layout drawings, and instruction was provided'to

all licensed reactor operators and senior reactor operators.

In addition, training included a detailed discussion of the June 27,

1986 incident. The lesson included the changes that were made to

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Procedures OP/2/A/6100/04, Shutdown Outside the' Control Room from Hot

Standby to Cold Shutdown, and AP/2/A/5500/017, Loss of Control Room.

The training also covered labeling and panel surface changes made to

the ASPS, control differences between Unit 1 and Unit 2, and proper

use of the newly revised panels and procedures to shutdown the

reactor and plant.

Based on this information, the item is closed.

c. (0 pen) Unresolved Item 413/86-05-05: Environmental Qualification of

l Hydrogen Skimmer Fans - Open Pending NRC Policy Decision

Status:

The item remains open pending an NRC policy decision on Environmental

Qualification.

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4. Unresolved Items

No unresolved items were identified during the inspection.

5. Licensee Action on Previously Identified Inspector Followup Items (92701)

a. (0 pen) Inspector Followup Item 413/86-05-01: Revision of Station

Directive 3.2.2 to Require Shif t Supervisor Notification of Missed

l Surveillance Tests

l Background:

During an inspection in March,1985 it was noted that Station Direc-

tive (SD) 3.2.2 was inadequate in several respects and was not being

followed in all cases. All of these problems have been resolved

except for one. It was noted that Station Directive 3.2.2 only

addressed the notification of Performance and Compliance when a

surveillance test could not be performed within the required time

interval. The procedure did not state that the Shift Supervisor must

be immediately notified if a surveillance interval had passed. The

licensee had stated that SD 3.2.2 would be revised. The licensee

noted that failure to meet a surveillance requirement was covered

under the provisions of Station Directive 3.1.8.

Status:

As of June 19, 1987, Station Directive 3.2.2 had not been revised to ;

require notification of the Shift Supervisor when a test had not been i

completed within the interval required in Technical Specifications.

The licensee committed at the Exit Interview to complete this action

by August 31, 1987,

b. (Closed) Inspector Followup Item 413/86-05-06, 414/86-07-03: Review

and Implementation of Environmental Qualification Maintenance Program

Background:

10 CFR 50.49 requires that a record of environmental qualification

(EQ) of electrical equipment important to safety must be maintained

to permit verification that each item meets its specified perforniance

requirements when it must perform its safety function up to the end

of its qualified life. Implicit in this requirement is the

constraint that records must be kept to substantiate that periodic

maintenance activities required to maintain a piece of equipment in

its qualified condition have been performed.

The licensee specifies these periodic maintenance requirements in the

Station Equipment Qualification Reference Index (EQRI). When the EQRI

was first being implemented, it contained numerous references to

instruction manuals and it was not clear which periodic maintenance

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activities were actually required for EQ. In a letter dated March = 27,

1985, outstanding maintenance activities or_ alternative actions taken-

by the station were identified for a Design Engineering Review to -

verify that all EQ-mandated maintenance had been accomplished. NRC

Inspection 86-07 identified that as of January 9,1986, the Design

Engineering Review had not been completed. Although an in-depth

review and revision of the EQRI was curtsntly in progress, the

potential existed that the qualifications of some equipment may have

been compromised or invalidated through a failure to perform

necessary periodic maintenance.

Resolution:

The inspector verified that the concerns presented in the March 1985

letter had been adequately resolved, as documented in a. letter dated

January 27, 1986. No equipment qualifications appeared to _ have been

invalidated or compromised by the identified ~ alternative maintenance

actions.

The EQRI manual has been completed by the licensee. The inspectors

verified that EQ-mandated maintenance now is identified in the EQRI

Manual. The sources of the EQ requirements are also referenced. '

Based on the above information, the item is closed.

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ML20235X449

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