ML20215K308

Insp Repts 50-413/87-14 & 50-414/87-14 on 870426-0525. Violations Noted:Failure of Written Operations Procedures to Adequately Require Implementation of Security Plan Under Degraded Standby Shutdown Facility Conditions

ML20215K308
Person / Time
Site:	Catawba
Issue date:	06/08/1987
From:	Lesser M, Peebles T, Skinner P, Vandoorn P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215K269	List: IR 05000413/1987014 ML20215K266 ML20215K278 ML20215K308
References
50-413-87-14, 50-414-87-14, IEIN-86-029, IEIN-86-049, IEIN-86-052, IEIN-86-062, IEIN-86-105, IEIN-86-29, IEIN-86-49, IEIN-86-52, IEIN-86-62, NUDOCS 8706250289
Download: ML20215K308 (10)

See also: IR 05000413/1987014

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A UNITED STATES '

, [' s stroo,Do .. NUCLEAR REGULATORY COMMISSION

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$ -jf 101 MARIETTA STREET,N.W.

• 's ATLANTA, GEORGI A 30323

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Report Nos. 60-413/87-14 and 50-414/87-14 l

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, Licensee: , Duke Power Company  !

'422. South Church Street j

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. Charlotte, N.C. 28242

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

NPF-52

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Facility.Name: Catawba.1 and 2

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. Inspection Conducted: April 26 - May 25, 1987 '

Inspec, tors: h. . u w /eM/$F')

P. T.,VanDoorn '

Date Signed

P. In Sk nner'

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Date Signed j

Approved by: h, ,& h A Mlt, A _ d&dM

T.~A. Peebles,.Section Chief / 'g Date' Signed.

Projects. Branch 2 4

Division-of Reactor. Projects- ,

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SUMMARY '

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Scope: This ' routine. unannounced inspection was' conducted on site inspecting

in the ' areas of - review of plant" operations;' surveillance observation;-

maintenance observation; review of' licensee nonroutine event reports; followup l

of previously identified items; and!. followup of Information Notices, j

Results: Of the six (6) areas inspected, one apparent violation was identified

in one area. (Failure of Written Operations Procedures to Adequately Require

Implementation of the Security Pl an Under Degraded SSF Conditions -

paragraph 3). One Unresolved Item was also identified (paragraph-5f).

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

J. W. Hampton, Station Manager

• H. B. Barron, Operations Superintendent

W. F. Beaver, Performance Engineer

W. H. Bradley, QA Surveillance

S. Brown, Reactor Engineer l

B. F. Caldwell, Station Services Superintendent

R. N. Casler, Operating Engineer

R. H. Charest, Station Chemistry Supervisor

• M. A. Cote, Licensing Specialist 4

• T. E. Crawford, Integrated Scheduling Superintendent 1

W. P. Deal, Health Physics Supervisor i

C. S. Gregory, I.& E. Support Engineer

C. L. Hartzell, Compliance Engineer

J. Knuti, Operating Engineer

F. N. Mack, Project Services Engineer

W. W. McCollough, Mechanical Maintenance Supervisor

C. E. Muse, Operating Engineer

F. P. Schiffley, II, Licensing Engineer

• G. T. Smith, Maintenance Superintendent

J. Stackley, I. & E. Engineer

D. Tower, Shift Operating Engineer

• R. F. Wardell, Technical Services Superintendent

• R. White, Chairman, Catawba Safety Review Group

Other licensee employees contacted included technicians, operators,

mechanics, security force members, and office personnel . ]

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• Attended exit interview. l

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2. Exit Interview l

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The inspection scope and findings were summarized on May 27, 1987, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings. No

dissenting comments were received from the licensee. The licensee did not

identify as proprietary any of the materials provided to or reviewed by

the inspectors during this inspection. The following new items were

identified.

Violation 413,141/87-14-01: Failure of Written Operations Procedures to

Adequately Require Implementation of the Security Plan under Degraded SSF

Conditions.

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Litensee Identified Violation 413/87-14-02: Failure to Perform Inservice

. Testing of Residual Heat Removal ~ Check Valves.

Unresolved Item 414/87-14-02: Nonconservative Calibration of Power Range

Nuclear Instruments.

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3. Licensee Action on Previous Enforcement Matters (92702)

a .- (CLOSED) Violation 413/86-05-04: Two' Examples of Inadequate

Maintenance Procedures. ~ The licensee' responded to- this item in'

correspondence dated May 5, .1986. The actions described in this

response were reviewed by the inspector and based.on this resiew this

item is closed.

b. (CLOSED) . Violation 413/86-24-02, 414/86-26-02: Failure to Provide i

Adequate Procedures Resulting in a Violation of TS 4.6.1.la. The I

licensee responded to this item in correspondence dated August 20,  !

1986. The inspector reviewed the response .and verified that

corrective actions were completed.

c. (CLOSED) Unresolved Item 413/86-51-05: Inadequate Incident

Investigation Report C86-161-1 and Subsequent LER 413-86-59. The

licensee submitted adequate revisions ' to the above' reports which

clarified the event, elaborated on the root cause, and ' identified

additional and appropriate corrective action. Based on this e.ction,

this item.is closed. '

d. (CLOSED) Violation 414/87-05-05: Failure to Comply with Technical

Specification 3.6.3 Associated with Inoperable Containment Isolation'

Valve.2BB8A. The licensee. responded.to'this item'in correspondence.

dated April 8, 1987. 'The inspector reviewed' the response and

verified that corrective actions were completed.

e. (CLOSED) Unresolved Item 413/87-10-02: Potential Failure to Implement

Procedures for a Degraded Standby Shutdown Facility (SSF). On 1

April 10,1987, the inspector noted that the Standby Shutdown

Facility Standby Makeup pump for Unit 1 was logged inoperable in the '

Technical Specifications Action Item Log (TSAIL), placing the SSF in

a degraded condition. The inspector pointed .out .to the Shift

Supervisor that the applicable portions of the Security Plan under

degraded SSF conditions had not been implemented. The Shift

Supervisor verified that the Security Duty' Team Supervisor had not

been informed by Operations of the degraded SSF and corrective action

was immediately taken to implement the Security Plan. The SSF had

been in a degraded condition from approximately 8:20 a.m. - 1:15 p.m. ,

without the required security precautions. Operations failed to

notify the Security Duty Team Supervisor of the condition as required

by enclosure 4.7 of OP/0/B/6100/13, Standby Shutdown Facility

Operations. The licensee determined that its written procedures were

inadequate in that there was no reference or requirement for

Operations to implement enclosure 4.7 of OP/0/B/6100/13 when

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declaring the Standby Makeup Pump inoperable. This coutitutes a

violation of Technical Specification 6.8.1, and is identified as

Violation 413,414/87-14-01: Failure of Written Operations Procedures

to Adequately Require Implementation of the Security Plan Under

Degraded SSF Conditions,

f. (OPEN) Unresolved Item 414/87-10-02: Review of Possible Safety l

Significant Problem Involving Safety Injection System. The licensee

Design Engineering Division (D/E) has evaluated the valve lineup

previously performed to relieve pressure in the Safety Injection l

System (NI) discharge header. The condition was apparently an  ;

unanalyzed condition but the NI System was operable. Procedural

guidelines were recommended to prevent contamination of the Refueling

Water Storage Tank (RWST) during the recirculation phase, however,

contamination of the RWST due to the existing lineup was not

addressed. Site health physics personnel have recently sampled the

air space at the top of the RWST and have measured noble gas

concentrations greater than 500 times the public MPC limit. At this

concentration approximately 100,000 cubic feet per minute outflow

would be needed to reach the site boundary limit. Although the tank

is vented to atmosphere, appreciable outflow does not occur. This

concentration was higher than expected due to the abnormal valve

alignment which had been performed. Therefore site personnel have

requested D/E to evaluate the situation. This item remains open

pending this evaluation.

One violation was identified as described in paragraph 3.e. above.

4. Unresolved Items *

A new unresolved item is identified in paragraph 5.f.,

5. Plant Operations Review (Units 1 & 2) (71707 and 71710)

a. The inspectors reviewed plant operations throughout the reporting

period to verify conformance with regulatory requirements, Technical

Specifications (TS), and administrative controls. Control room logs,

danger tag logs, 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 accordance with

approved procedures.

The inspectors verified by observation and interviews, the measures

taken to assure physical protection of the facility met current

requirements. Areas inspected included the security organization,

the establishment and maintenances of gates, doors, and isolation

zones in the proper condition, that access control and badging were

proper and procedures followed.

• An Unresolved Item is a matter about which more information is required to

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determine whether it is acceptable or may involve a violation.

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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 things as combustible material control, fire protection

systems and materials, and fire protection associated with

maintenance activities, The inspectors reviewed Problem

Investigation Reports to determine if the licensee was appropriately

documenting problems and implementing appropriate corrective actions. i

b. The inspectors conducted a detailed walkdown of portions of the l

Nuclear Containment Spray Systems and portions of the Residual Heat l

Removal Systems for both Units. j

c. Unit 1 Summary l

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The unit began the period at 100% power and ran until May 22, 1987 l

when the Unit was shutdown to fix Reactor Coolant (NC) System leakage l

from the C Resistance Temperature Detector bypass manifold at a valve

and an instrument fitting. The Unit was restarted on May 23, 1987.

d. Unit 2 Summary

Unit 2 began the period at 100% power also. The plant was manually a

tripped from 100% power on May 6, 1987 due to loss of air cooling to )

the NC Pump motors. The loss of cooling occurred when a cooling I

water valve closed while personnel were replacing a breaker. The NC  !

Pumps were tripped and the plant cooled down as expected via natural )

circulation. The unit was restarted on May 7,1987. On May 8, 1987

the unit was manually tripped from 65% power due to impending 10-10

level in a steam generator (SG) from a failed closed main feedwater

regulation valve. The unit was restarted on May 9, 1987, and

remained on line for the remainder of the period,

e. On May 1,1987 the inspector noted that Construction Division tags

were being used in several areas of the plant. The inspector

discussed this with Operations and Construction personnel and was

assured by the plant manager that use of these tags would be

discontinued for plant equipment and that only operations tags would

be used. This will assure that Operations is aware of equipment

status,

f. On April 29, while observing shift turnover, the inspector questioned

operators why Unit 2 was being held at 97% power. The inspector was

told that during a power increase from 90%, the operators noted that

Megawatt output from the main generator had reached its expected 100%

value while Power Range Nuclear Instruments (PRNI) and Reactor

Thermal Power indicated 97%. (Reactor Thermal Power is determined

from a secondary calorimetric and displayed on the Operator Aid

Computer.) Calibration of the PRNI's to Reactor Thermal Power had

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just been completed prior to the power increase and the operators

were concerned .that 'the PRNI's had potentially been calibrated in a

non-conservative direction. This was later confirmed to be the case

when _it was determined that the S/G Auxiliary Feedwater Nozzle

Tempering Control Valve, 2CF100, had been incorrectly opened

following a recent Turbine Acceptance Test. A small percentage of.

feedflow w's a not being accounted for by feed flow instruments, the

effect being the Reactor Thermal Power calculation was approximately

3% lower than actual Reactor Thermal Power. Prior to identifying

this valve error the Shift Supervisor (SS) had ordered the PRNI gains

to be raised to indicate 100% power while lowering Megawatt output

slightly. The SS reasoned that this action ensured the Power Range

Neutron Flux High Setpoint was not in a non-conservative direction.

The licensee applied Technical Specification (TS) 2.2.1 to the event

to determine if the High Setpoint was 'ever outside the Total i

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Allowance as determined by Equation 2.2-1. The licensee has.shown in

Memorandums dated May 14, 1987 and May 19, 1987 that the Total

Allowance was never exceeded. The inspector has asked for assistance

from Region II in clarifying T.S. 2.2.1 and the terms in equation

2.2-1. The inspector has additionally asked the licensee for an

evaluation of precautions to take prior to calibrating PRNI's. _ This

is identified as Unresolved Item 414/87-14-02: Nonconservative

Calibration of Power Range Nuclear Instruments pending licensee

evaluation to prevent recurrence and NRC interpretation of T.S.

2.2.1. j

No violations or deviations were identified.

6. Surveillance Observation (Units 1&2)(61726)

a. During the inspection period, the inspector verified plant operations

were in compliance with various TS requirements. Typical of these

requirements were confirmation of compliance with the TS for reactor

coolant chemistry, refueling water storage tank, emergency power

systems, safety injection, emergency safeguards systems, control room

ventilation, and direct current electrical power sources. The-  ;

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inspector verified that surveillance testing was performed in '

accordance with the 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,

b. The inspector observed the following surveillance activity:

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PT/1A/4250/028 Turbine Valve Movement Test

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The inspector reviewed the following surveillances for acceptance: j

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PT/2/A/4200/30A MSIV Inservice Test

PT/2/A/4200/17 BB Valves Inservice Test

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No violations or deviations were identified.

7. Maintenance Observations (62703)

a. Station maintenance activities of selected systems and components

were observed / reviewed to ascertain that they were conducted in

accordance with requirements. The inspector verified licensee

conformance to the requirements in the following areas of inspection:

the activities were accomplished using approved proceduras, and

functional testing and/or calibrations were performed prior to

returning components or systems to service; quality control records

were maintained; activities performed were accomplished by qualified i

personnel; and materials used were properly. certified. Work requests

were reviewed to determine status of outstanding jobs and to assure t

that priority is assigned to safety-related equipment maintenance

which may effect system performance.

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b. The inspector observed the following maintenance activities:

MP/0/A/7150/60 Seal Injection IA Filter Replecement

5273 SWR Semiannual Preventive Maintenance on 2A2

Component Cooling Pump

The inspector reviewed various maintenance work requests on RHR hot  !

leg suction valves and MSIV actuators.

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c. Based on a Potential Generic Item (87-02) identified by NRC, the

inspector reviewed the licensee's requirements for 0-Ring lubricant i

on Main Steam Isolation Valve (MSIV) air actuators. Although the l

licensee has not yet developed detailed procedures for the MSIV

actuators since work has not yet been required, the manuals for the

MSIV's do specify the appropriate lubricant. The inspector informed l

the licensee of the problem at another plant and indicated that the

other plant had found that the lubricant should be applied sparingly.

The licensee indicated that they would consider this problem in

development of the maintenance procedures.

No violations or deviations were identified.

( 8. Review of Licensee Nonroutine Event Reports (Units 1 & 2) (92700)

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a. The below listed Licensee Event Reports (LER) were reviewed to

L determine if the information provided met NRC requirements. The

determination included: adequacy of description, verification of 1

compliance with Technical Specifications and regulatory requirements, 3

corrective action taken, existence of potential generic problems,

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reporting requirements satisfied, and the relative safety

significance of each event. Additional inplant reviews and

discussion with plant personnel, as appropriate, were conducted for

those reports indicated by an (*). The following LERs are closed:

*413/86-05 Rev.2 Both Trains Control Room Ventilation Inoperable

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Following Loss of Chilled Water Makeup due to

Design Deficiency and Equipment Malfunction

L *413/87-12 Rev,1 Unit Shutdown Resulting from PORV's Inoperability

) due to Design / Installation Deficiency and

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l *413/87-14 Technical Specification Violation Because l

Inservice Inspection of Valves was not Performed

due to Management Deficiency (LIV issued, para.

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• 413/87-15 Reactor Trip Caused by Unexpected Closure of Main  !

( Feedwater Isolation Valve due to Installation l

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413/87-16 Manual Opening of Reactor Trip Breakers due to

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413/87-17 Inoperable Fire Barrier Penetration due to

Defective Procedures

• 414/86-49' Safety Injection on Spurious Low Steam Line

Pressure due to Dirty Contacts in 7300 Process

Control Cabinet

• 414/87-02 Rev 1 Reactor Trip due to Accidental Shorting of Test

Cable and Auxiliary Feedwater Start due to

Personnel Error

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• 414/87-08 Rev. 1 Technical Specification Violation due to a Design

Deficiency in the Operator Aid Computer Reactor

Coolant Leakage Program (LIV issued, see Report

414/87-10)

414/87-11 Auxiliary Feedwater Auto-Start on Loss of Both

Main Feedwater Pumps due to a Design Deficiency

414/87-13 Auxiliary Feedwater Auto-Start on Loss of Both

Main Feedwater Pumps due to Equipment Failure

414/87-14 Unexpected Steam Generator Low Low Level Signal

Actuated During Main Steam Valve Testing due to

Unknown Cause

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• 414/87-16 Unit 2 ~ Shutdown due to Unidentified Leakage

through Reactor Coolant Radiation Monitor Relief

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b. LER 413/87-14 listed above involved a situation whereby both trains

of the Residual Heat Removal (ND) System had to be declared

, inoperable since the Inservice Test had not been performed for~ the ND )

check valves from the RWST. The licensee identified this violation I

via a Testing Review Committee formed . in response to a previous

violation. Therefore, the licensee is appropriately given credit for-

g identifying this violation. This is Licensee Identified Violation

(; 413/87-14-02: Failure to Perform Inservice Testing of Residual Heat

y Removal Check Valves. This item does not require a response and is

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closed by this report since appropriate corrective actions have been-

implemented,

c. While reviewing LER 413/87-05, Rev. 1: Unit Shutdown due to Design

Deficiency with Containment Air Return Fans, the inspector noted that ,

no corrective action had been defined relative to the Design i

Engineering aspects of the problem. This is the second LER which was  ;

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found to- be incomplete for a similar reason (ref. LER 414/86-45).

The inspector informed the licensee that these LER's would remain ,

open pending new responses and implementation of an improved- J

coordination process when issues involve Design Engineering

Department. q

No violations or deviations were identified. j

9. Followup of IE Notices (92701)

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The inspector reviewed the actions taken by the licensee upon receipt of  ;

an:IE Notice (IEN) sent for information purposes only. The Compliance

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Engineer, at present, controls receipt and distribution of these documents j

to assure appropriate personnel review the contents and determine actions j

that may be required as a result. The following notices were reviewed to  !

assure receipt, review by appropriate personnel, and any resulting action  !

identified, documented and followed to completion:

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IE Notice 86-29 Effects of Changing Valve Motor Operated Switch

Settings

IE Notice 86-49 Age / Environment Induced Electrical Cable Failures

IE Notice 86-52 Conductor Insulation Degradation on Foxboro Model E

Controllers

IE Notice 86-62 Potential Problems in Westinghouce Molded Case Circuit

Breakers Equipped with a Shunt Trip

IE Notice 86-105 Potential For loss of Reactor Trip Capability at .'

Intermediate Power Levels

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10. Previously Identified Inspector Findings (92701) l

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a. (CLOSED) Inspector Followup Item 413/85-22-01: Review New Problem

Identification Reporting and Escalation Controls Upon Implementation.

The licensee has now implemented the Problem Investigation Report l

program which includes an escalation process.

The inspector has reviewed this program and considers the licensee l

actions to be acceptable,

b. (CLOSED) Inspector Followup Item 413/86-05-07, 414/86-07-04: l

Satellite Document Control Station In the Maintenance Department Not 2

Being Maintained Up To Date. The satellite files have been modified l

to remove all technical manuals. Station Directive 2.2.1, Procedure l

for Records Management Revision 32 has been changed to only allow  ;

equipment history, completed calibration information and purchase 'i

information for test equipment to be maintained at the satellite

files. Based on this review, this item is closed,

c. (CLOSED) Inspector Followup Item 413/86-47-04: Review of Licensee

Action Relative to Improper Torque Value. The licensee has

appropriately corrected the errant procedure. A previous evaluation

had been performed which showed that no technical problem had j

existed, i

d. (OPEN) Inspector Followup Item 414/87-10-03: Review of ND Hot Leg

Suction Valves Maintenance. Further review of selected work requests

involving the subject valves has confirmed that these valves have

stuck shut on at least three different occasions. The licensee

indicated that a review would be performed to evaluate the need for

an improved design or increased maintenance. This item remains open

pending licensee actions. j

No violations or deviations were identified. f

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