IR 05000413/1990016

Insp Repts 50-413/90-16 & 50-414/90-16 on 900611-15. Violations Noted But Not Cited.Major Areas Inspected: Conformance to Reg Guide 1.97 & Instrumentation for Light water-cooled Nuclear Power Plants During Accidents

ML20055H591
Person / Time
Site:	Catawba
Issue date:	07/09/1990
From:	Hunt M, Merriweather N, Mark Miller NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20055H589	List: IR 05000413/1990016 ML20055H588
References
RTR-REGGD-01.097, RTR-REGGD-1.097 50-413-90-16, 50-414-90-16, NUDOCS 9007270035
Download: ML20055H591 (16)

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NUCLEAR REGULATORY COMMISSION i

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101 MARIETT A ST RE ET, ATL ANT A, GEORGI A 30323 l

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l Report Nos.: 50+413/90-16 and 50-414/90-16

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Licensee: Duke Power Company 422 South Church Street Charlotte NC 28242 Docket Nos.: 50-413 and 50-414 License Nos.: NPFJ35 and NPT-52 i

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Facility Name: Catawba 1 and 2 ,

Inspection Conducted: June 11-15, 1990 Inspectors: . k,~~ 47/ 7/7 6

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N. Merriweather Date 51gned

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N h r1lA > 'Il9 )9b 7 ate 5fgned

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.M. Miller  :

f Approved by: 2AMb M. D. Kunt, Kcting Chief 7/9)93 Ditt 5'Igned Plant Systems Section e Engineering Branch

• Division of Reactor Safety

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SUMMARY l Scope:

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This special announced inspection has conducted in the areas of. the licensee't l conformance to Regulatory Guide (RG) 1.97, Instrumentation for Light  :

L Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions

[ During and Following an Acciden Results: '

L The licensee has implemented an adequate program of plant instruments to meet .

l_ :the intent of RG 1.97, Revision 2; the .SER; and their submitta However,

! weaknesses were identified in two areas and one non-cited (413, 414/90-16-01)

violation regarding environmental qualification (EQ) was also identified. The

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E licensee acknowledged these concerns end aroposed to take certain corrective 0 actions. The inspectors considered the icensee's proposed actions to be

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appropriate and reasonabl Overall, the -licensee's RG 1.97 program was ,

. considered average.

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9007270035 900713

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PDR ADOCK 05000413

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Violation (Non-cited)

i i- Failure to' Include Certain RG 1.97 Category 2 Instruments in' The Master EQ

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: Weaknesses bifc Not all instruments in the control rooms are tagged with a pl. ant' equipment identification numbe Several Category 2 instruments are not in the calibratior progra '

e Strengths: '

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! The licensee : uses the loop method in the calibri. tion program which

. simultaneously verifies calibration of all instrumeres in the string (loop)

Maintenance work performed on the instruments was clearly and . concisely described in the " work order".

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The violation, strengths. ~and weaknesses are discussed in Paragraph s-1 o;-

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REPORT DETAILS

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, Persons'Ctntacted Licensee Employees

• Dickard, Engineering Supervisor

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• East, Support Engineer

• L. Hartzell, Compliance Manager

• Jones, Maintenance Engineering Manager

• D. King, Nuclear Production Engineer j

• R.'G. Mallaney, Design Engineer  ;

• W. R. McCollum, Maintenance Superintendent '

• R. G. Morgan, Design Engineer

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• T. B. Owen, Station Manager

• F. C. Poley, Design Engineer

• J. E. Thomas Design Engineering Manager Other licensee employees contacted during this inspection included engineers, operators, and administrative personne ,

Other Organizations

• K. N Jabbour, NRC/NRR NRC Resident Inspectors

• W. -T. Order:. SRI

• J. Zeiler, R1

• Attended exit interview

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Acronyms and initialisms used throughout this report are listed in *

Paragraph . Inspection of Licensee's Implementation of Multiplant Action Item A-17:

Instrumentation for Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident (Regulatory Guide 1.97)

(25587).

Criterion 13. " Instrumentation and Control" -of Appendix A to 10 rFR Part 50 includes a requirement that instrumentation be provided to monitor variables and systems over their anticipated ranges for accident conditions as appropriate to ensure adequate safety. Regulatory Guide 1.97 describes a method acceptable to the NRC staff for complying with the Commission's regulations to provide instrumentation to monitor plant variables and systems during and following an acciden l

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The licensee responded to RG 1.97 (NUREG 0737 Supplement 1) in letters dated September 26, 1983 and October 22, 1985. The Safety Evaluation !

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Report was issued as Appendix to Supplement No. 5 of NUREG-0954 dated -

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February 198 The SER concluded that the licensee's instrumentation for RG 1.97 either i conforms to or is justified in deviating from Regulatory Guide 1.97, '

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Revision 2; with the exceptions of addressing environmental qualification L for certain variables in accordance with 10 CFR 50.4 L

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This inspection assessed the licensee's RG 1.97 instrumentation system-using (1) the design and qualification criteria described in Section of RG 1.97, Revision 2; 2) the EG&G Technical Evaluation Report N '

EGG-EA-6973, dated December 1985, Conformance to Regulatory Guide 1.97, Catawba Nuclear Station, Unit Nos. I and 2; (3) the licensee's submittals '

as discussed previously; and (4) 10 CFR Part 5 A random sample of 26 variables from the licensee's submittal were .

selected to evaluate the licensee's program. The variables selected were classified as Category 1 and 2 which have the most stringent design requirements of all RG 1.97 instruments. The-instruments examined and the results achieved are discussed in the paragraphs and tables below.- i i Category 1 and 2 Instruments

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The instrumentation listed in the following Tables were examined to verify that the design and qualification criteria for RG 1.97 or toe 1 SER and licensee comuitments had been satisfie The instrumentation i was inspected by reviewing orawings; procedures, data sheets and 5 other documentation; and performing walkdowns for visual observation of selected installed equipment including control room indicators and recorders. The following areas were inspected:

(1) Equipment Qualification - The EQ Master Equipment List (EQR) '

Q-list, I&C list, seismic teat reports, and instrument drawings were reviewed for confirmation that the licensee had addressed environmental qualification requirements and seismic qualifica-L tion. A non-cited violation was identified in this area as

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discussed in Paragraph 2.b.

l (2) Redundancy - Walkdowns were performed to verify by visual I observation that selected instruments were installed as L specified and that separation requirements were met. In

!. addition, wiring drawings for all listed Category 1 instrumenta-tion were reviewed to verify redundancy and channel separatio (3) Power Sources - Wiring drawings were reviewed to verify the instrumentation is energized from a sa'ety-related power source ,

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(4) - Display and Recording - Walkdowns were performed to verify by visual observation that the specified display and recording instruments were installed. Wiring drawings were reviewed to verify there was at least one recorder in a redundant channel andtwoindicators,oneperdivision(channel)foreachmeasured variabl (5) Range - Walkdowns were performed to verify the actual range of the indicator / recorders was as specified in RG 1.97 or as stated

.in the licensee's submittal. Review of calibration procedures verified sensitivity and overlapping requirements of RG 1.97 for instruments measuring the same variable.-

(6) Interf aces - The wiring drawings, I&C list, and Q-list were reviewed -to verify that safety-related isolation devices were used when required to isolate the circuits from non-safety 7 system (7) Direct Measurement - Wiring drawings were reviewed to verify that the parameters are directly measured by the senor (8) Service, Testing, and Calibratian - The maintenance program for performing calibrations and surveillances was reviewed and discussed with the licensee. Calibration and surveillance procedures and the latest data sheets for each instrument were reviewed to verify the instruments have a valid calibration. A concern was identified .in this area as discussed in paragraph (9) Equipment Identification - Walkdowns were performed to verify that types A, B and C instruments designated as Categories 1 and 2 were specifically identified with a comon designation on the control panels. A concern has identified in this area and is discussed in paragraph TABLE 1 CATEGORY 1 INSTRUMENTS Variable Instrument Number RCS Pressure NC-PT-5120 4 NC-P-5120 SM-CR-5080 NC-PT-5140 NC-PT-5140 SM-CR-5810 ICCM PAM A ICCM PAM B

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TABLE ;

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Variabl Instrument Number l

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Core Exit- .1CCM PAM A  ;

i Temperature ICCM PAM B  !

T/C TI-T34.'

T38. T44s T45 1

u T47. T59, 162 i p- i i Pressurizer Level .NC-LT-5150 NC-P-5153 )

NC-CR-5910 l-e~ >' NC-LT-5160 NC-P-5164-E NC-CR-5900 NC-LT-5170i .)

NC-P-5174' I i

Degrees of.Subcooling ICCM PAM A i ICCM PAM B-i'y '

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RCS Cold Leg NC-RD-5860 -)

Temperature NC-P-i3860 l NC-CR-5880 4 NC-P-5880- '

NC-CR-5860'

NC-RD-5910  :

NC-RD-5930 1 NC-CR-5910 ICCM PAM A-ICCM PAM B s

RCS Hot Leg NC-RD-5850 ,

Temperature NC-P-5850  ;

NC-CR-5850 NC-RD-5870 NC-P-5870 ,

NC-CR-5850 ,

I NC-RD-5900 NC-RD-5920 NC-CR-5900 ,

i Containment Sump NI-LT-5260 t Water Level NI-P-5260 Wide Range NI-CR-5340 NI-LT-5270 ,

NI-P-5270 NI-CR-5350  !

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Y TABLE 1 I h CATEGORY 1 INSTRUMENTS

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Steam Generator CF-LT-5610 i- Level' CF-P-5610 Wide Range SM-CR-5080

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CF-P-5620 i .SM-CR-5800 CF-LT-5630 CF-P-5630 CF-P-5630 SM-CR-5160 CF-LT-5640 CF-P-5640 SM-CR-5810 Auxiliary Feedwater Valve & Indication RN-250A, CA-16&l7 Assured Source Valve & Indication CA-116A, CA-19&20 Valve & Indication CA-015A, CA-24&25 ,

Valve & Indication RN-3108. CA-49&50 Valve & Indication CA-0858, CA-52&53 Valve & Indiention CA-018B, CA-63&64 ,

CA-FT-5000 CA-P-5000 CA-FT-5010 .

CA-P-5010-CA-FT-5040 ,

CA-P-5040 1 Pump Indication RN-23 Pumpi ' ndication RN-67 Steam Generator CF-LT-5490 Level CF-P-5490 Narrow Range CF-LT-5500 CF-P-5500 CF-LT-5510 CF-P-5510 CF-LT-5520 CF-P-5520 CF-LT-5530 :

CF-P-5530 CF-LT-5540 '

CF-P-5540 CF-LT-5550 CF-P-5550 CF-LT-5560 CF-P-5560

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TABLE 1 CATEGORY 1 INSTRUMENTS Variable

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CF-P-5570 CF-LT-5580 CF-P-5580 CF-LT-5590 CF-P-5590 i CF-LT-5600 CF-P-5600 Neutron Flux NS-DT-0013 NS-IR-51 NS-NC-47 NS-DT-0014 NS-IR-52-Containment Hydrogen MI-MI-5320 Concentration MI-MI-5320A MI-P-5320 MI-CR-5320

'Al MT-5330 Mi-MT-5330A MI-P-5330 -

MI-CR-5350 Refueling Water Storage FW-LT-5000 Tank Level FW-P-5000 NS-0R-5390 FW-L1-5010 FW-P-5010 ,

FW-LT-5120 FW-P-5120 FW-LT-5130 FW-P-5130 NS-CR-5040 ,

Containment Pressure NS-PT-5370 Wide Range NS-P-5370 MI-CR-5340 NS-PT-5380 NS-P-5380 MI-CR-5350 Steam Line SM-PT-5080 Pressure SM-P-5080 SM-CR-5090 SM-PT-5090 -

SM-P-5090 SM-PT-5100

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SM-P-5100 SM-PT-5110

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SM-P-5150 SM-PT-5160

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SM-P-5170 SM-PT-5180 3 SM-PT-5190 SM-P-5190 ;

SM-CR-5810 ;

Containment Pressure- NS-PT-5040 j

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4-NC-CR-5040 NS-PT-5050

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NS-PT-506 !

- NS-P-5060 -l NS-PT-5070 :

NS-CR-5390 TABLE 2

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n CATEGORY 2 INSTRUMENTS

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Auxiliary Feedwater - CA-FT-5090 l Flow CA-P-5090 !

CA-FT-5100 CA-P-5100 CA-FT-5110 CA-P-5110 CA-FT-5120 ,

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TABLE 2 CATEGORY 2 INSTRUMENTS

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Containment Spray NS-FT-5020 Flow NS-P-5020

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Containment Temperature VV-RD-5100 1: VV-RD-5130 VV-RD-5150 VV-RD-5180 RHR System Flow ND-FT-5180 (Low Pressure Injection) - ND-P-5180 J ND-FT-5190

ND-P-5190 High Pressure Injection NI-FT-5120-Flow NI-P-5120 ~,

NI-FT-5150 .

> NI-P-5150 Boric Acid Charging NV-FT-6080 *

Flow NV-P-6080 RHR Heat Exchanger ND-RD-5000

,< Outlet Temperature ND-CR-5070 l ND-RD-5120 l ND-CR-5060

! RCS Safety Relief Valve Valve NC-328 l' Position (PORVs) Switch NC-LL-0320 i

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Switch NC-LL-0321  :

Indication NC-122 i Indication NC-1P3 Valve NC-368

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Switch NC-LL-0360 Switch NC-LL-0361 Indication NC-116 Indication NC-117 Valve NC-34A Switch NC-LL-0340 Switch NC-LL-0341 Indication NC-56 Indication NC-57 RCS Safety Relief Valve Valves NC-1, 2, & 3 Position (Code Valves) Detector TBox-380 Detector TBox-381

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CATEGORY 2 INSTRUMENTS

Variable Instrument Number Steam Flow SM-FT-5000'

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SM-FT-5010 SM-P-5010 i SM-FT-5020-SM-P-5020 SM-FT-5030 ,

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SM-P-5040 SM-FT-5050 SM-P-5050 SM-FT-5060 SM-P-5060  :

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SM-FT-5070 SM-P-5070 , biscussion and Conclusion The inspectors concluded that Catawba has imolemented a satisfactory '

. program for RG 1.97. The implementation of their RG 1.97 program was  !

considered arjecoate in most areas; with the exception of a few l Weaknesses in_ tie areas of equipment identification and labeling, end calibration. In addition a non-tited violation was identified in the~ g

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EQ area which is discussed in detail later in Peregraph To resolve these weaknesses and the non-citea violation the licu.see's  :

management proposed certain voluntary corrective action The !

inspectors considered these proposals acceptable to resolve all l concerns. A brief discussion of the areas reviewed and the results achieved including any licensee planned action are summarized belo (1) Equipment Identification and Labeling The inspectors toured the control room and general plant areas and examined the selected RG.I.97 instruments for proper range and identification. During the inspection, the inspectors noted

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the following: (a) Certain instruments in the control room were not tagged with a plant " equipment identification number". .These instruments the includedand neutron flux monitors, allthe recorders ICCM plasma (both displays;RG 1.97( and othe The steam generator wide range level recorders were not identified as " wide range"; and (c) Containment temperature is monitored by 12 temperature loops displayed in the process computer. Only four

.,f these loops, VV-RD-5100, 5130, 5150 r J 5180 are environ-mentally qualified as RG.197 Category 2 items. However, the computer display does not identify these four loops as RG 1.97

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instruments and the E0Ps do not list them to be used by the operator The licensee indicated that those instruments not already marked will be. properly tagged with a plant equipment identification number and the steam generator wide range level recorders will be relabeled " wide range". The four containment temperature loops will be either put in the E0Ps or specifically identified as RG 1.97 instruments in the computer display. The inspectors-considered this proposed corrective action as acceptabl (2) Calibration The inspectors reviewed the latest calibration data sheets fo those RG.197 instruments and loops identified in Tables 1 and 2 The inspectors the licensee noted as not that1Eseveral Class instruments or Quality (considered Assurance Condition 1by)

were not in the calibration program. The instruments and their latest calibration are listed as follows:

Steam Generator Narrow Range level recorders latest calibration was 1985 Steam Flow recorders latest calibration was 1985 RHR Flow Looas ND-FT-5180 and ND-FT-5190 calibration was February 18, 2987 for Unit 1 June 30, 1987 for Unit 2 Containment Temperature Loops VV-RD-5100 and VV-RD-5180 latest calibration was October 1986 Containment Spray Flow Loops NS-FT-5020 and NS-FT-5030 latest calibration was March 1983 for Unit I and August 1984 for Unit 2 The licensee immediately started reviewing the calibration program to determine if other instruments were excluded. In addition, the license initiated " work orders" and was in the process of performing calibrations for this instrumentatio Although these instruments are not Class IE, the inspectors considered the lack of recent calibration as a weakness in the Preventive Maintenance Progra (3) Environmental Qualification Concerns The inspectors reviewed the licensee's EQ Master list, I&C list, wiring drawings, location drawings, and accident environment zone maps for several RG 1.97 components identified in Tables 1 and 2 above. In addition a walkdown was performed on certain instruments in the plant to verify installation acceptability, name plate data, identification, and location. From this review the inspectors determined that at least eight Category 2

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it.struments per unit were located in harsh environment However,.none of these instruments had been included on the EQ

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Master lis The licentee took the position that for those RG 1.97 Category 2 .

variables classified as non-safety, full environmental qualificatio,' to 10 CFR 50.49 was not required. The inspector took exception to this position and informed the licensee that 4 10 CFR 50.49(b)(3), requires that certain post accident monitoring equipment important to safety must be environmentally -

qualified. The variables covered by the rule are described in RG 1.97 as Category 1 and 2 variables. The licensee's submittal to RG.I.97 identified these eight instruments (4 variables) as '

Category The variables of concern are RHR heat exchanger outlet temperature, HPI system flow, containment spray flow and containment atmosphere temperature. Contrary to the above, the licensee failed to include these instruments on the EQ Master ,

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Two of the four variables HPI flow and containment spray flow '

were inspected during walkdown of the plant and were verified to be located in areas that were considered radiation harsh during post accident conditions. The expected total integrated I radiation dose in these areas is 5.3E5 rads gamma for HPI

, instruments and 2E8 rads gamma for containment spray instrument The particular instruments used in these applications are Veritrak Model 26DP Tobar Model 32DP and Rosemont Model 1153 D, differential pressure transmitter .

The Veritrak and Tober transmitters are used for measuring HPI System flow and are located in the HPI pump rooms. The Rosemont transmitters are used to measure containment spray flow and are located in the containment spray pump room .

Prior to the end of the inspection, the licensee was able to provide the NRC with information to support qualification for all the above transmitters. The licensee indicated that Tobar Test Report No. 5519A32 establishes qualification for both the Tobar and Veritrak transmitters for use in radiation environ-ments up to 1.2E7 Rads. This exceeds the expected level of 5.3E5 Rads. The Rosemont transmitters were supplied by the-vendor as safety related and qualified to IEEE 323 - 1974. This would qualify these instruments for use in the expected ,

radiation fields of 2E8 Rad '

The other instruments, resistance temperature detectors (RTD),

requiring qualification were not accessible at the time of the inspection. However, the licensee did provide information for the inspectors which shows that the RTDs for both the RHR heat exchanger outlet temperature and containment atmosphere temperature channels were purchased as safety-related and were

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qualified by the Vendor to IEEE 323-1974. In addition to the above, one of the four Unit 2 containpent atmosphere temperature RTDs (2VVRD5130) was visually inspec'.ed by the licensee. The licensee provided photographs of tre installation for the inspectors. From these pictures th1 inspectors were able to determine that the installation appeared to be satisfactor The inspectors noted that the RTD had been terminated using Raychem heat shrink materials. However, the package that documented the installation of the RTDs did not identify the size and type of heat shrink materials used. Therefore,' the inspectors requested the licensee to measure the outside diameters of the field cable lead wires and the RTD lead wires; and to record the size and type of Raychem material use Based on this information the inspectors concluded that the splice materials were properly selected in accordance with vendor

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instructions. In addition, the licensee confirmed that the installed cable and electrical penetration were qualified. The licensee also indicated that the other containment temperature RTD installations would be inspected and the drawings updated to reflect the termination requirements, i

, With the above information, the inspectors in consultation with Regional Manager.1ent cor.cluded that this problem is basically a j documentation problem and a failure by the licensee to include i these instruments on tne EQ Master list. It appears that all !

the associated equipment is qualificd. Therefore, this item was

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identified to the license as non-cited violation (NCV) 50-413, 414/90-16-01, Failure to Include Certain RG 1.97 Category 2 Variables on the EQ Master List. This NRC identified violation .

is not being cited because criteria specified in Section V A of 1 10 CFR Part 2, Appendix C of the NRC Enforcement Policy is satisfied. The licensee informed the inspectors, prior to the end of the inspection, that auditable qualification files will be developed for those instruments in accordance with the EQ rule and that they will be added to the EQ Master Lis . Exit Interview The inspection scope and results were summarized on June 15, 1990, with those persons indicated in Paragraph 1. The inspectors described the areas inspected and discussed in detail the inspection results summarized abov Proprietary information is not contained in this repor Dissenting comments were not received from the license The licensee proposed the following corrective actions in response to the inspection findings and in cer tain areas was already implementing these corrective actions:

The calibration program was being and would be completely reviewed to ensure all RG 1.97 instruments and instruments important to plant safety (although not classified QA-1) would be placed in the

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i preventive maintenance calibration progra *

Instruments identified in Paragraph 2.b(2), calibration, as not ,

having a current calibration will be calibrated. [ Work orders have i

beeninitiatedandcalibrationoftheseinstrumentsisinprogress.]

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Instruments not already tagged with a " plant equipment identification number" will have them adde *

The four EQ qualified Category 2 containnent temperature loops will either be identified in the E0Ps or in the computer display as RG 1.97 instrument >

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The S/G wide range level recorders will be identified as " wide i range".

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Non-cited violation 50-413/414/90-16-01, Failure to Include Certain ,

RG 1.97 Category 2 Variables On the EQ Master List. The licensee- -

Stated that qualification files will be developed for those instruments ir, cccordance nith the EQ rule and these files will be ;

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added to the EQ Master Lis ' Acronyms and Initialisns CA -

Chatt Recorder Duke - Duke Power Company +

DT - Neutror. Flux Amplifier / Monitor EQ - Environmentol Qualification '

EQRI - Environmental Qualification Reference Index ESF - Engineered Safety Features FT - Flow Transmitter- HPI - High Pressure Injection l IAE -

Instrumentation and Electrical l .I&C - Instrumentation and Controls t

'ICCM - Integrated Core Cooling Monitor IR - Neutron Flux Indicator LL - Limit Switch ,

LT Level Transmitter l MP -

Miscellaneous Indicator

! MT - Miscellaneous Transmitter l NR - Narrow Range L NRC - Nuclear Regulatory Commission L PAM - Post Accident Monitoring l P - Indicator PT - Pressure Transmitter QA - Quality Assurance

RCS - Reactor Coolant System RD - Resistance Detector ,

RHR -

Residual Heat Removal .

RG - Regulatory Guide

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SER - Safety Evaluation Report S/G - Steam Generator T/C - Thermocouple TE - Temperature Element ,

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