IR 05000261/1982011

IE Insp Rept 50-261/82-11 on 820311-0410.Noncompliance Noted:On 820326,high Radiation Area on Second Level of Containment Not Posted for Access from Northwest Personnel Stairway & Area Around Spent Fuel Pit Incorrectly Posted

ML20054H079
Person / Time
Site:	Robinson
Issue date:	04/21/1982
From:	Burger C, Weise S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20054H051	List: IR 05000261/1982011 ML20054H050 ML20054H058 ML20054H068 ML20054H071
References
RTR-NUREG-0654, RTR-NUREG-0737, RTR-NUREG-654, RTR-NUREG-737, TASK-2.K.3.01, TASK-2.K.3.25, TASK-3.A.2.2, TASK-TM 50-261-82-11, IEB-79-27, NUDOCS 8206220551
Download: ML20054H079 (11)

Text

-

.

'

/pnsreg o UNITED STATES

[ } ", }3

'

.; e NUCLEAR REGULATORY COMMISSION REGION 11 0,P .,[ 101 MARIETTA ST., N.W., SUITE 3100

%, * O e ATLANTA, G EORGIA 30303

Report l10. 50-261/82-11 Licensee: Carolina Power & Light Company 411 Fayetteville Street Raleigh,iC 27602 Facility llame: 11. B. Robinson Steam Electric Plant

,

Docket flo. 50-261 License flo. DPR-23

,

Inspection at H. B. Robinson Unit 2 near Hartsville, South Carolina Inspector: ' "

M/ '-

S. Weise - Date Signed E ~ rh " 7

'

Approved by: " '

C. Burger,/Section Chief, Division of Project Date Signed and Resident Programs SUttt1ARY Inspection on flarch 11 - April 10,1982 Areas Inspected This routine, announced inspection involved 141 resident inspector-hours on site in the areas of technical specification compliance, plant tour, operations perfomance, reportable occurrences, housekeeping, site security, surveillance

, activities, maintenance activities, quality assurance practices, radiation control activities, outstanding items review, IE Bulletin, Circular, tiotice followup, Till Action Item review, and refueling activitie Resul ts Of the 15 areas inspected, no violations or deviations were identified in 14 areas; one violation was found in one area (Failure to follow procedures - see paragraph 7.b).

!

8206220551 820603 PDR ADOCK 05000261 0 PDR

-_. __ . . _ _ . _ - - -- . . . -

.

-

.

DETAILS Persons Contacted Licensee Employees

• R. B. Starkey, Plant General flanager

• d. Curley, Manager Technical Support

• F. Gilman, Senior Specialist, Regulatory Compliance F. Lowery, Unit 2 Operations Supervisor

• W. Crawford,flanager, Operations and Maintenance R. Chambers, Unit 2 fiaintenance Supervisor

• C. Wright, Specialist, Regulatory Compliance

• S. Crocker, flanager, Environmental and Radiation Control D. Gainey, Senior Specialist, Emergency Planning

• D. Baur, Project QA/QC Specialist

• W. :lacCready, Radiation Control Supervisor Other licensee employees contacted included technicians, operators, mechanics, security force members, and office personne * Attended exit interview Exit Interview The inspection scope and findings were summarized on April 9,1982, with those persons indicated in paragraph 1 above. The licensee acknowledged failure to follow their Health Physics procedure Additionally, as addressed in paragraph 16, the licensee committed to conducting surveillance on the Dedicated Shutdown System as delineated in their proposed Technical Specification submitta . Licensee Action on Previous Inspection Findings (Closed) Unresolved item 81-27-0 This item concerned the required independent review of certain changes to the facility and procedures as described in the FSAR. The inspector picked ten modifications that appeared to be changes to the facility as described in the FSA (llodi fica tions 418, 472, 445-F, 501, 515, 520, 525, 526, 539, 542, S /3)

Of these modifications, five (418, 445F, 472, 520, 526) had been submitted to and reviewed by the Corporate Nuclear Safety Committee (CNS) as required. llodi fications 501, 515, 526, 542 were equipment additions as a result of the Tl11 Action Plan. Since these were modifications to provide additional accident instrumentation, or containment isolation dependability, they do not appear to be changes in the FSAR as intended by 10 CFR 50.59. Ilodifications 539 and 573 were changes to the facility as described in the FSAR, in that, FSAR Section 6.2 states that the operators can open the stean generator alowdown lines fro 1 the control roun af ter containaent isoittio Tnese nodifications require sdditional operator action froa outside tne

_

-

, . .

.

auxiliary building to open these valve These modifications were incorrectly determined to not be changes to the FSAR, however, CilS did review 539 and 573 through their auditing system. The inspector noted that while these two modifications were not recognized as changes to the FSAR, 50.59 safety evaluations were done, since plant _ procedures require a safety review for all plant modification These safety _

evaluations appeared adequat Reporting of changes to the FSAR to the flRC should occur regardless, as the licensee is required t' subnit an updated FSAR by July 22, 198 Recent revisions to the licensee's modification procedures also appear to be adequate to correct these deficiencie (Closed) Severity Level V Violation. 81-31-04. The inspector reviewed the licensee's response dated December 22, 1981, General Procedure-6, Operating Procedure-38A, and plant training records. Corrective action for this item appears adequate and coaplete, (0 pen) Unresolved item. 81-33-01. Tnis item concerns the failure of the power operated relief valve blacs valves to fully sea CPSL has enlisted the technical aid of llestinghouse, using information provided by the valve nanufacturer (Velan) and the cpe-ator manu facturer (Limitorque). Based on liestingnouse racomeJations, CPuL uas to increase the torque switch setting fran about 1.7 to Insce: tion of the block valve torque setting cr/eil M 1 men :ndq of tne The licensee is continuing to investigata the apparent dasign proalen-in light of this new informatio This inconsistency raised an additional concer In that the licensee does not record or stipulate torque settings in their_ maintenance instructions for motor operated valves, the inspector is concerned that motor operated safety-related valves could experience failures similar to that of the block valve Because the torque switch setting is only used in the shut direction, only valves which shut on receipt of protective or safeguards signals would be affected. This concern is an open item pending further inspector review. (50-261/82-11-01).

4. Unresolved Items Unresolved items were not identified during this inspectio . Plant Operations Review The inspector periodically during the inspection interval reviewed shift logs and operations records, including data sheets, instrument traces, and records of equipment malfunctions. This review included control room logs, auxiliary logs, operating orders, standing orders, jumper logs and equipment tagout records. The inspector routinely observed operator alterness and demeanor during plant tours. During abnormal events, operator performance and response actions were observed and evaluated. The inspector Conduct 9d rando-1 off-hours inspections dJring the reporting intdrVdl to assure Ondt

.

operations and security re.nained at an acceptable level. Shift turnovers

_ . . . .

.

.

were observed to verify that they were conducted in accordance with approved licensee procedures. The inspector has no further questions in this are . Technical Specification Compliance During this reporting interval, the inspector verified compliance with selected limiting conditions for operation (LC0's) and reviewed results of selected surveillance tests. These verifications were acconplished by direct observation of monitoring instrumentation, valve positions, switch positions, and review of completed logs and records. The licensee's compliance with selected LC0 action statements were reviewed as they happene . Plant Tour The inspector conducted plant tours periodically during the inspection interval to verify that monitoring equipnent was recording as required, equipnent was properly tagged, operations personnel were aware of plant conditions, and plant housekeeping efforts were adequate. The inspector determined that appropriate radiation controls were properly established, excess equipment or material was stored properly, and combustible material was disposed of expeditiousl During tours the inspector looked for the existence of unusual fluid leaks, piping vibrations, pipe hanger and seismic restraint abnormal settings, various valve and breaker positions, equipment clearance tags and canponent status, adequacy of firefighting equipment, and instrument calibra tion dates. Some tours were conducted on backshif t ' During a tour of containment on thrch 20, 1982, the inspector detannied that unposted access to a high radiation area was availabl The hign radiation area was associated with the reactor vessel head storage area on the second level. The area was properly posted for access from the south side of containment, however personnel using the northwest stairway could access the area without being warned of the high radiation area. Licensee Health Physics Procedure HP-1 requires that those high radiation area perimeters not physicaly bounded be cordoned off to delineate area bounds. Additionally, on a tour of the auxiliary building on April 7,1982, the inspector determined that the area of the spent fuel pit heat exchanger was not posted as a high radiation area. Radiation levels in the area of insulation restoration activ-ities near the heat exchanger were about 100-1500 mrem per hour, but the area was posted as a radiation area. The inspector also reviewed the licensee's survey of the area conducted ilarch 29, 198 This survey also found 100-150 mrem per hour general area readings and identified the area as a high radiation area. The postings apparently were not updated at that tim These two iteils are examples of failure to follow procedure HP-1 for the posting of high radiation area (32-11-02). The licensee took pronpt action to correctly past thesa drda * '

.

. . - .

.

4 Refueling Activities The inspector reviewed various activities concerned with refueling or preparation for refueling operations. Prior to the licensee handling fuel, the inspector reviewed selected surveillance testing data to ensure Technical Specification (TS) requirements were met. In particular, Periodic Test (PT) 26.0, Fuel Handling Equipment Interlock and Operation Test, and PT 24.0, Fans and Associated Charcoal and Absolute Filters, data was reviewed to ensure equipment operability. . Fuel Handling Instruction FT 3.0, Fuel Assembly and Core Component flovement Prerequisites and Periodic Checkoff, was reviewed. to ensure all applicable requirements were covered by the procedure and met prior to fuel movement. Checkoffs were reviewed periodically covering core offloa The inspector verified that licensee staffing during core offload was in accordance with TS and plant admin-istrative instructions. Core reload is scheduled for late April or early

'May, and will be observed by the inspector. flo violations or deviations were note . Semi-annual Radiation Protection Drill The inspector observed the required semi-annual inplant radiation protection drill on March 26, 198 This particular drill required obtaining a high level radioactive reactor coolant sample in an area of sinulated high radiation and airborne radioactivity. Participants were required to notify

~

appropriate personnel, select and operate equip.nent properly, talk through sample setup and analyses, and properly document their actions. Af ter the drill, the inspector attended the CP&L critiqu This critique covered all the inspector comments with the following exception Because the plant is in a refueling outage, drill interference is at a maximu Future drills should be conducted under conditions conducive to a complete walk through with minimal simulation, Simulated radiation levels in the Chemistry Lab were not provide These levels should have been provided to correspond to sample radiation leve Air sample data was provided at the same time as area radiation levels without requiring the technician to indicate he would take an air sampl Drill planning and performance was adequat The inspector had no further comment . Physical Protection The inspector verified by observation and interview during the reporting interval that measures taken to assure the physical protection of the facility net current requirements. Areas inspected included the organi-23 tion of the security force, the establishment and naintenance of gates, door and isolation zones in the proper condition, that access control and

---

---____-__ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _

.

.

.

badging was proper, that search practices were appropriate, and that escorting and communications procedures were followe . IE Bulletin Followup IEB 79-27 Loss of Non Class IE Instrumentation and Control Power System Bus The inspector reviewed the licensee's response dated February 28, 1980, Abnormal Procedure (AP)-24 for loss of Instrument Bus, and inspection report 50-261/80-1 AP-24 appeared adequate to meet the commitments of the CP&L le t te r . The discrepancies noted in inspection report 80-16 have been transmitted to both IE and NRR, although not formally by the license AP-24 reflects the corrected system lineup vice the error noted in report 80-1 Based on the above, it appears unnecessary to request a supplemental response and this Bulletin is close . TII Action Plan Review TAP No. III.A.2, NUREG 0737, lleteorological Data. (tlilestone 4) This item concerns installation of emergency response facility meteo-rological hardware and software as clarified in NUREG 0737 and Appendix 2 to NUREG 0654. CP&L letter dated December 31, 1981 submitted the functional description and system confijuration for the Robinson meterological Systen. CP&L's implementation schedule will not be commenced until written MRC concurrence is obtained. Based on this position, it appears that it would not be operational until late 1982 or early 1983. The present neteorological instrumentation has been inspected, as reported in IE Inspection Report 50-261/82-02. The licensee's present program appeared adequate at that time. This item will remain open pending NRC clarification and system installation and operabilit TAP No. II.K.3.25, NUREG 0737, Effect of Loss of Power on Reactor Coolant Pump Seal This item required the licensee to evaluate the ability of the reactor coolant pump seals to withstand a complete loss of offsite power for two hours and propose necessary modifications to ensure operability. CP&L letter NO-81-2151 of December 29, 1981 reported that no modifications are necessary based on the availability of conponent cooling water and charging pumps. The inspector reviewed system pump and valve power supplies and confirmed that the licensee's position appeared acceptable. This item is close TAP No. II.K.3.1, NUREG 0737, Automatic Power Operated Relief Valve (PORV) Isolation. This item required the licensee to evaluate an automatic isolation feature for the pressurizer PORV's. The inspector reviewed CP&L letter NO-81-1134 dated June 30, 1981 and Westinghouse WCAP-9804 dated February,1981. Based on the UCAP evaluation, CP&L has detennined that no modifications are necessar Inis item is close . .. .

. .

..

.

-

.

.

13. Licensee Event Report (LER) Followup The inspector reviewed the following LER's to verify that the report details met license requirements, identified the cause of the event, described appropriate Corrective actions, adequately assessed the event, and addressed any generic implications. Corrective action and appropriate licensee review of the below events was verified. The inspector had no further comment LER Event 79-34 Rev. 1 Auxiliary Feedwater flotor Operated Isolation Valve Failure 81-13 Rev. 1 Failure to Test Containment Isolation Valves 14. Review of IE Circulars and Notices (IEC's and IEN's)

The inspector verified that IE Circulars and Notices had been received onsite and reviewed by cognizant licensee personnel. Selected applicable IE Circulars and Notices were discussed with licensee personnel to ascertain the licensees actions on these items. The inspector also verified that IE Circulars and Notices were reviewed by the Plant Nuclear Safety Committee in accordance with facility administrative policy. Licensee action on the following IE Circulars and Notices were reviewed by the inspector and are close IE Circulars IE Notices 81-10 81-05 81-19 81-23 81-10 81-39 81-26 81-31 81-36 80-32 Revision 1 81-09 81-15 81-34 15. Temporary Rentir Procedure Review The inspector reviewed Engineering Procedure ENG 5.6, Temporary Repairs (Revision 0), and the temporary repair logbooks maintained in the Control Room and by the Unit 2 flaintenance Supervisor. ENG 5.6 sets forth the requirements for processing, controlling, and disseminating teaporary repairs to structures, systems, and components under the facility quality dssurance progra Safety evaluations for the active temporary repairs were reviewed ano appeared adequat . _ _ _ _ _ _ _ _ _

- _ . . . . . - _

~

.

.

During the review of the temporary repair logbooks maintained by the flaintenance Supervisor and the Control Room, the following deficiencies were noted: The master log index was not being maintained as required, Temporary repairs were being routed to the control room but were not being maintained as an active file. At the time of the inspection, the control room file contained only one out of the twelve active temporary repair form One of the missing forms required additional surveil-lance by operations personnel. The inspector reviewed the control operators logs and determined that the required surveillance was conducte Several temporary repairs that had been permanently corrected had not been processed for closecu The licensee took corrective action to update both the control room logbooks and the master log and index. An individual has been assigned respon-sibility for maintaining the control room logbook. The inspector had no further question . Dedicated Shutdown System (DSDS)

During review of the long term upgrading of the Auxiliary Feedwater System issues, the inspector determined that the licensee was taking credit for the installed, non-Technical specification DSD CP&L reported the system installed and operable in a letter to f;RR dated January 9,1981. Proposed Technical Specifications were submitted December 2,1980, and are pending NRC issuanc In that CP&L is taking credit for the system, the inspector reviewed the licensee's proposed surveillance requirements to ensure a program had been established and implemented. Review revealed that no prog ra.T existed for surveillance on the DSDS operating panels or for instrumentation checks, however, diesel test runs and verification of adequate fuel inventory were being conducted. Additionally, the inspector was unable to determine if appropriate instrumentation was included in the master instrument list. When informed of the inspector's concerns, the licensee agreed to implement the proposed surveillance program during the present refueling outage. Pending program implementation and verification that all instruments are included in the calibration program, this is an open ite (50-261/82-11-03).

1 Outstanding Item Review (Closed) Inspector Followup Item 81-25-09. The inspector reviewed the site quality assurance (QA) organization's response to the corporate QA auditors and reviewed tne indoctrination docunentation for the affected individual The inspector had no further question (Closed) Open Iten 31-25-10. T11s ite, concerned tne required reading file far auditars not oeing part af an approved procedure and the licensee having

_________ -

.

-

.

.

.

no apparent verification of knowledge transfer for auditor The inspector '

reviewed Corporate QA Procedure CQAD 80-2 for audit personnel training and qualification and verified that the reading list had been incorporate The reading list appeared adequate. Discussions with licensee personnel indicated that CP&L verifies knowledge transfer to auditors via evaluation of their performance on several audits. This appears to meet the require- .

ments of ANSI N45.2.3-197 (Closed) Inspector Followup Item 81-25-0 This item concerned CP&L's failure to maintain vendor examinations for auditor Through discussions with the licensee, the inspector determined that the vendor does not wish to provide exam copies due to exam security concerns. Additionally, CP&L's program is designed around a practical examination process which utilizes Lead Auditor input for audits in which the trainee participate This appears to meet the requirements of ANSI N45.2.23-1978. Since the vendor exam is not the qualification exam per se, maintaining a copy of the exam is apparently not require (Closed) Open item 81-25-0 This item concerned the adequacy of the reading list for onsite and offsite QA/QC personne The inspector reviewed Robinson procedure QAP-103, Revision 3 and corporate procedure CQAD 80-2 Revision 0, concerning qualification and training of QA/QC personne The reading lists incorporated into these procedures appeared adequat (Closed) Open tem 81-27-24. This item concerned the long lead time on some craf t and techaician course material and trainin The inspector reviesed -

CP&L's schedule for training as' documented in memorandum NO-81R096 dated October 28, 198 While the lead times appear to be somewhat shorter, the scope of the training program contributes to the long preparation time CP&L appears to have increased its emphasis of this area, and the inspector had no further question (Closed) Open item 81-27-1 This item concerned not having acceptance criteria on instrument data sheets. CP&L's position is that this item is '

not warranted. Plant calibration procedures contain specific acceptance criteria for each calibration and the data sheets are for recording values only. A spot check of procedures showed acceptance values for safety-rela ted instruments. As long as CP&L maintains the quality of their instruments, they appear to be within regulatory requirement (Closed) Inspector Followup Item 81-27-2 This item concerned periodic retraining for auxiliary operators ( AO). The inspector reviewed Revision 5 to Training Instruction (TI)-104. The program requires auxiliary operators to be checked out on applicable plant systens every two years by the Shif t Foreman. This program appears acceptable. The inspector reviewed auxiliary operator qualification records and found that the progran had been ingle-mented as describe (Closed) Inspector Followup Iten 81-19-0 Inis iten was to review the function of the fuel nanipulatar and its checkout priar o the nac re fuel ing. ine inspector witnessed Section G of Jeriodic Test ;PT) 26.0, _

_____ ________

-

,

. .

,

.

l

unich verifies operation of the manipulator and its associated interlock In particular, the inspector was concerned with usage of the Z-axis tape and recording of those values significant to safe fuel handling. This subject uds previously identified in IE tiotices 80-01 and 81-23. PT 26.0 Section G does not record any of tne Z-axis tape values corresponding to gripper tube up or dovm positions. The inspector noted tnat values fran the previous refueling were recorded on masking tape on the side of the manipulator for ready ope ator reference. These values, while apparently accurate, are not controllea for operation or maintenance purpose Fuel Handling Procedure FT 9.12, !!anipula tor Crane Operating Procedure, provides blanks for recording selected Z-axis readings for use during fuel handling operation A review of the master copy of FT 9.12 fraa tne 1980 refueling showed the following deficiencies: Stap 2.2.5 for lowering the gripper tube into the fuel assembly does not require the operator to check the Z-axis tape in addition to the limit ligh Step 2.2.10 for raising the fuel assembly to tne top limit switch does not require the operator to check the Z-axis tape readin Steps 2.2.15 and 2.3.4 for losering the fuel assembly into and for atrie/ing a 4;el 1ssenbly fron the fuel transfer container do not

.

; .. ..2 cat are to ta used during these fuel transfer i: " li ties . ' a ;coce :Jre provides olanks for recording these value N that the proceduct nas not been revised since the previous refueling, the inspector was concernea tnat the licensee has not taken sufficient action in lignt uf :ne IE Notices. Tnese concerns were discussed with licensee nanagenen Teaporary revisions were made to the fuel handling procedures to answer the concerns prior to fuel movemen These revisions are to be permanently incorporated into the procedure (Closed) Open item 81-27-09. This item concerned weaknesses identified in the plant design change program. The inspector reviewed the following licensee procedures for plant design change control:

Engineering Procedure 5.0, Plant Design Control, Revision Engineering Procedure 5.1, flodification Package Development and Revision, Revision Engineering Procedure 5.2, Design Verification, Revision Engineering Procedure 5.4, Turnover and Processing of As Built Packages, Revisions Engineering Procedure 8.0, Preparation of Engineering Calculations, Revision ________ __ _._.

1 , - . .

These procedures appear to adequately address the weaknesses previously identifie (Closed) Open item 81-27-10. This item concerned not positively identifying all design change drawings. Engineering Procedure 5.5, Design Change Motice appears to adequately identify affected document (Closed) Open item 81-27-11. This iten concerned weaknesses in the preventive and corrective maintenance programs. The inspector reviewed recent revisions to fbintenance Instruction-1, Maintenance Administration Program; lbintenance Procedure MP 1-1, Maintenance Work Request Procedure; MP 1-8, Trend Analysis; and Quality Assurance Procedure QAP 202, Document Review. These procedures appear to adequately address the performance appraisal team concern (Closed) Inspector Followup Item 81-27-35. Tni s i tea concerneu 'tne establishment and implementation of a Health Physics procedure far nonthly radiation surveys of the Unit 2 secondary plant and a Unit I radiological surveillance program. The inspector reviewed Health Physics Procedure- This procedure provides for monthly surveys of the trash landfill area and tool storage areas, and quarterly surveys on the Unit 2 secondary side and other outside areas. This procedure does not provide a Unit 1 surveillance program. CP&L conducted a decontamination of Unit 1 using an acid flush sol ution . The inspector reviewed an April 2,1982 meno from the Manager, Environmental and Radiation Control concerning the status of Unit 1 contamination and surveillance. Tne memo describes the present contami-n a tion sta tus , posting, and entry requirements. The surveillance program presently consists of general smear surveys outside of Unit 2 and a weekly Unit 1 liquid sample for presence of radioactivit Licensee actions appear adequate for the existing levels of contaminatio (Closed) Open item 81-03-03. This item concerned liner degradation observed during the diesel generator inspection conducted during the 1930 refueling ou tage . The inspector reviewed a CP&L letter to the NRC dated October 21, 1980, a CP&L letter to the vendor dated October 17, 1980, and the vendor's response dated January 13, 198 The vendor's response provided several recommendations to improve early detection of the engine jacket water adapter leaks believed to have caused the cylinder liner erosion. The inspector reviewed Periodic Test 23.1 for test running the diesels weekl Since iby, 1981, this procedure has required surveillance of water pressure flunctuations for indications of adapter leakage. The inspector also reviewed Preventive ibintenance procedure PM-10, which governs periodic diesel inspections. This procedure incorporates the balance of the vendor recommendation Additionally, the present refueling interval diesel inspection has found no similar erosion indications. The inspector had no further question _