IR 05000305/2004008
| ML18011A920 | |
| Person / Time | |
|---|---|
| Site: | Harris, Kewaunee  |
| Issue date: | 05/05/1995 |
| From: | Byron P, Elrod S, Darrell Roberts NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18011A919 | List: |
| References | |
| 50-400-95-05, 50-400-95-5, NUDOCS 9505180374 | |
| Download: ML18011A920 (22) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 303234199 Report No.:
50-400/95-05-Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
Inspection Conducted:
Harch 5 - April 8, 1995 Inspectors:
S.
E rod, Seni r
es den Inspector License No.:
NPF-63 Date S gned D.
o erts, Residen Insp ctor Date S gned P.
yr
,
Re Approved by:
s ent nspe tor, Brunswick Plant Date S gned gS D.. er elli, Chief Reacto Projects Branch lA Division of Reactor Projects Dat S gned SUHHARY Scope:
This routine inspection was conducted in the areas of operational safety, maintenance, surveillance, engineering activities, plant support, and licensee action on previous inspection items.
Numerous facility tours were conducted and facility operations observed.
Backshift tours and observations were conducted on Harch 12 and 30, 1995.
Results:
0 erational Safet Activities in the area of operational safety were routine and well planned (paragraph 3.a).
The licensee's employee concerns program, guality Check, was observed to be functioning well.
Several personnel concerns were resolved effectively through this program (paragraph 3.b).
9505i80374 950505 PDR ADOCK 05000400
Maintenance Maintenance activities were well executed and documented (paragraph 4).
En ineerin Activities Engineering activities to resolve a nonconservatism discovered in the original containment LOCA analysis were considered aggressive and well documented (paragraph 5.b).
The licensee's analysis of the containment sump suction valve pressure locking phenomenon, as it applied to containment spray and RHR pump suction valves, was considered adequate; as was the licensee's temporary operational approach to preventing such an occurrence (paragraph S.c).
Plant Su ort Activities observed during a practice emergency preparedness drill on March 30 indicated a need for improvement in the area of Technical Support Center command and control.
However, command and control activities in the Emergency Operations Facility were strong by comparison (paragraph 6.e).
REPORT DETAILS PERSONS CONTACTED Licensee Employees
- D. Batton, Manager, Work Control D. Braund, Manager, Security B. Christiansen, Manager, Maintenance
- J. Collins, Manager, Training
- J. Dobbs, Manager, Outages
- J. Donahue, General Manager, Harris Plant R. Duncan, Manager, Technical Support M. Hamby, Manager, Regulatory Compliance
- M. Hill, Manager, Nuclear Assessment D. McCarthy, Manager, Regulatory Affairs
- R. Prunty, Manager, Licensing 8 Regulatory Programs
- W. Robinson, Vice President, Harris Plant
- G. Rolfson, Manager, Harris Engineering Support Services
- H. Smith, Manager, Radwaste Operation
- B. White, Manager, Environmental and Radiation Control A. Williams, Manager, Operations Other licensee employees contacted included:
office, operations, engineering, maintenance, chemistry/radiation, and corporate personnel.
NRC Personnel P. Byron, Resident Inspector, Brunswick Plant S. Elrod, Senior Resident Inspector, Harris Plant
- D. Roberts, Resident Inspector, Harris Plant
- Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph.
PLANT STATUS AND ACTIVITIES b.
Operating status of plant over the inspection period.
The plant continued in power operation (Mode I) for the duration of this inspection period, essentially operating at full power.
The unit ended the period in day 156 of power operation since startup on November 8, 1994.
Other inspections during the inspection period.
P.. Byron, Resident Inspector at the Brunswick plant, was on site from March 27-31, 1995, providing site coverage while the Harris resident inspectors were unavailable.
The inspection findings are included in this repor.
OPERATIONAL SAFETY
'a ~
Plant Operations (71707)
Shift Lo s and Facilit Records The inspector reviewed records and discussed various entries with operations personnel to verify compliance with TS and the licensee's administrative procedures.
Records reviewed, in part, by the inspectors included:
shift supervisor's log; control operator's log; night order book; equipment inoperable record; active clearance log; grounding device log; temporary modification log; chemistry daily reports; shift turnover checklist; and selected radwaste logs.
In addition, the inspector independently verified clearance order tagouts.
The inspectors found the logs to be readable and well organized, and to provide sufficient information on plant status and events.
The inspectors found clearance tagouts to be properly implemented.
The inspectors identified no violations or deviations in the shift logs and facility records area.
Facilit Tours and Observations Throughout the inspection period, the inspectors toured the facility to observe activities in progress.
The inspectors made some of these observations during backshifts.
Also, during this inspection period, the inspectors attended several licensee meetings to observe planning and management activities.
Facility tours and observations by the inspectors encompassed the following areas:
security perimeter fence; control room; emergency diesel generator building; reactor auxiliary building; waste processing building; turbine building; fuel handling building; emergency service water building; battery rooms; electrical switchgear rooms; and the technical support center.
During these tours, the inspectors made observations regarding monitoring instrumentation
- including equipment operating status, el.ectrical system lineup, reactor operating parameters, and auxiliary equipment operating parameters.
They verified indicated parameters to be per the TS for the current operational mode.
The inspectors also verified that operating shift staffing was in accordance with TS requirements and that the licensee was conducting control room operations in an orderly and professional manner.
The inspectors additionally observed shift turnovers on various occasions to verify the turnover continuity of plant status, operational problems, and other pertinent plant information.
Licensee performance in these areas was satisfactor The inspectors identified no violations or deviations in the facility tours and observations area.
Effectiveness of Licensee Control in Identifying, Resolving, and Preventing Problems (40500)
Em lo ee Concerns Pro ram The inspector reviewed the guality Check Program at Harris.
The program operated per Nuclear Generation Group Guideline NGGH-302-16, Administration of the CP&L guality Check Program, and Nuclear Services Department Procedure OLCH-OI, Rev 1, Ouality Check Program.
This program was intended to ensure adequate means were made available to CPKL and contract employees, who were involved in nuclear work, to report observed or perceived concerns in a confidential manner.
The program directly processed concerns related to the safe and reliable operation of the nuclear plant, and also accepted reports in a variety of other areas.
The program transferred many of these other reports either to other programs or to the Human Relations Department.
The program included confidential telephone and written concerns, as well as interviews of,departing persons, and interviews of employees selected at random.
The inspector determined that nine concerns had been received since October 1,
1994.
Three of the nine were anonymous, showing that capacity to process anonymous concerns is an important program attribute.
All of the nine concerns were closed.
The inspector reviewed a sample of four of the nine concerns.
These had been appropriately processed, especially considering that an important program element is maintenance of confidentiality.
Concerns can often be processed more efficiently when confidentiality is not a factor.
The inspector also reviewed a
multi-faceted concern from August 1994, to see how the organization approached complex issues.
Resolving this concern required more than one iteration of the process.
The resolution appeared reasonable to the inspector.
The inspector concluded that the program is effective, providing for confidential telephone and written concerns, as well as interviews of departing persons, and interviews of employees selected at random.
The inspector identified no violations or deviations in this area.
Plant Nuclear Safet Committee On March 29, 1995, the inspector attended the monthly PNSC meeting.
Presentations to the committee included procedure revisions, a change to TS 3.0.4 bases statements, and reviews of a Fall 1994 TDAFM overspeed event and the service life of rubber components.
The inspector observed that the PNSC members frequently reviewed the material while it was being presented,
indicating that they may not have been as prepared for the meeting as they could have been.
However, committee members'uestions were of sufficient depth to allow them to ascertain the central issues.
The inspectors found that plant operations during this period were routine and well planned.
The inspectors identified no violations or deviations in the operational safety area.
MAINTENANCE a ~
Maintenance Observation (62703)
The inspectors observed or reviewed maintenance activities to verify that correct equipment clearances were in effect; work requests and fire prevention work permits were issued; and TS requirements were being followed.
Haintenance was observed and work packages were reviewed for the following maintenance activities:
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WR/JO 94-APWII, Correct TDAFW pump bearing oil leak problem-by removing and inspecting drain plugs, reinstalling drain plugs and sealing with Locktite 545 sealant compound.
WR/JO 94-APWI2, Correct oil level gauge leakage on AFW pump turbine by removing inboard and outboard oil level gauges, inspect, r epair or replace if.necessary.
WR/JO AKTJOOl, Perform oil sample for the Terry Turbine in accordance with procedure PH-H0074, Equipment Lube Oil Sampling.
WR/JO LFUOOI, Perform procedure PH-H0014, Limitorque Inspection and Lubrication, on the steam admission valve to the Terry Turbine.
The above four jobs were performed during a
TDAFW pump "outage" on March 15.
The inspector observed in each case that technicians were performing the work per approved procedures using materials specified in the work packages.
The inspector observed that technicians using Locktite brand sealant to repair several small oil-leaking components allowed it to cure per the manufacturer's specifications.
The inspector verified documentation of all work performed on the closed work tickets.
The inspector concluded that work performance was satisfactory in all cases.
The inspectors identified no violations or deviations in this are b.
Surveillance Observation (61726)
The inspector observed several surveillance tests to verify that approved procedures were being used; qualified personnel were conducting the tests; tests were adequate to verify equipment operability; calibrated equipment was utilized; and TS requirements were followed.
Test observation and data review included:
OST-1111, Auxiliary.Feedwater Pump IX-SAB Operability Test, Honthly Interval, Hodes 1-3.
This test was performed on Harch 15 following maintenance activities discussed in paragraph 4.a above.
Prior to the test, the inspector observed operators performing pre-start prerequisites.
The inspector observed, prior to the pump start, that the turbine trip and throttle valve stroked smoothly from full closed to full open and back.
When started, the pump ran smoothly with no operational problems.
The inspectors concluded that the operators diligently performed this test procedure.
HST-I0130, Hain Steamline Pressure, Loop 2 (P-0486),
Operational Test.
The licensee performed this surveillance test to meet the requirements of TS 4.3.2.1, ESFAS Instrumentation Surveillance Requirements.
The main steamline pressure loops provide input to safety injection automatic actuation logic as well as steamline isolation logic.
The test satisfied the TS monthly requirement to perform operational checks.
The inspector verified that technicians performing the test used calibrated HRTE, that the technicians followed the current revision of the approved procedure, and that as-found data was within the allowable ranges specified on the data sheets for various lead/lag amplifiers and signal comparators.
The inspectors concl.uded that the technicians competently and effectively performed the surveillance procedure.
HST-E0011, lE Battery quarterly Test; HST-E0012, lE Battery 18-Honth Test; and HST-E0010, lE Battery Weekly Test.
The licensee performed the above three surveillance procedures in preparation for returning the 1B-SB Emergency Battery to its normal configuration (with the 60 originally interconnected battery cells).
Cell number 20 had been jumpered out of the battery bank last winter and placed on a
single-cell equalizing charge because of low cell voltage readings.
A spare cell had been jumpered into the battery
to meet original design requirements.
Prior to reinstalling cell number 20, technicians performed weekly surveillance procedure MST-E0010 to verify its operability.
Technicians then performed quarterly surveillance procedure MST-EOOll on the entire battery rack (with the spare cell installed) to verify the entire battery's operability.
Finally, technicians removed jumper cables connecting the spare cell to the battery rack, removed cables jumpering cell number
to number 21, reinstalled cell number 20, retorqued all connections and checked cell-to-cell resistances at those connections in accordance with 18-month surveillance procedure MST-E0012.
The inspector observed the licensee perform MST-EOOll on the battery bank and reviewed documented results of the other procedures.
The inspector verified all data to be within acceptance criteria.
The technicians did a good job in restoring the battery.
The inspectors found satisfactory surveillance procedure performance with proper use of calibrated test equipment, necessary communications established, notification or authorization of control room personnel, and knowledgeable personnel having performed the tasks.
The inspectors observed no violations or deviations in this area.
Followup - Maintenance (92902)
(Closed)
VIO 400/94-22-02:
Procedure Violations - Three Examples.
The licensee responded to this violation in CP&L letter HNP-94-098, dated December 30, 1994.
(I)
Example I involved flammable liquid left unattended in a
safety-related work area.
The licensee found that procedures conflicted and that 'workers did not follow the procedures or address the conflicts.
Corrective actions included removing the flammable material, training mechanics in this area during the fall 1994 quarterly training session, and revising the procedures to properly express expectations.
The inspector verified that the flammable material had been removed at the time of the violation.
Additionally, the inspector reviewed Lesson Plan ME7C04H/94, Mechanical Continuing Training, Fourth quarter, 1994, which included training on this subject.
The inspector also reviewed procedure FPP-007, Rev 5, Control of Flammable and Combustible Liquids, which had been revised to clearly state that glass containers were not approved for use in the power block.
(2)
Example 2 involved inadequate procedures for installing caps on Target Rock solenoid valves resulting in cap distortion.
The licensee inspected a number of valve caps and replaced two that were distorted.
The inspector reviewed procedure
HPT-I0019, Rev 4/9, Target Rock Valve Refurbishment and Inspection.
Section 7.7 was changed to incorporate a cap installation technique approved by the vendor in Target Rock Memorandum JW950003.
(3)
Example 3 involved technicians marking as
"NA" procedural signature blocks where adverse conditions were required to be reported to the operations shift supervisor.
The licensee determined that the items to be reported were not outside an operability limit, but were outside a more conservative limit intended to prevent exceeding an operability limit.
A licensee review team found the procedures confusing on this point, among other battery issues not included in the subject inspection report.
The licensee addressed personnel performance during a plant standdown meeting on December 16, 1994.
Procedure HST-E0010, Rev 4/3, lE Battery Weekly Test, was issued on December 13, 1994.
The inspector found that the procedure elements involved in this violation were corrected.
Other elements of this procedure, and other procedures, will be inspected in followup to VIO 400/94-23-02.
The inspector has closed this violation.
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5.
ENGINEERING ACTIVITIES a.
Design/Installation/Testing of Modifications (37551)
The inspectors reviewed ESR 9500059, Rev 0 and Rev 1, and associated design package, AH-4 Cooling Coil Repair/Plug.
This package included the actual repair of the leaking containment fan coil unit.
The inspector concluded that the licensee had reviewed the package and approved the changes in accordance with 10 CFR.
50.59; and that the changes were performed in accordance with technically adequate and approved procedures.
b.
Followup - Engineering (92903)
(1)
(Closed) IFI 400/95-04-02:
Nonconservative Containment LOCA Analysis of Record.
The inspector reviewed ESR 9500344, Rev 0, Nonconservatisms in Design Inputs to Containment Analysis.
On March 3, 1995, the utility determined from an in-house technical analysis that the 1986 containment LOCA analysis of record was nonconservative.
The nonconservatism affected the long-term cooling rate following ECCS suction being shifted from the RWST to the containment sump.
Though the nonconservatism did not affect the peak containment pressure or temperature, it did increase the long-term containment temperature profile, so it mainly impacted post-accident lifetime of Eg qualified components needed for long-term accident respons e
The magnitude of the temperature profile change was initially estimated to be about
+10 degrees F at 10,000 seconds and +25 degrees F at I million seconds (ll+ days).
From an initial review of equipment Eg qualifications, the utility expected that adequate conservatism existed in the individual component qualifications.
Also, known containment analysis conservatisms existed and could be applied if needed.
The utility did not expect an impact on plant operations.
The utility discovered this problem while performing sensitivity studies using an in-house installation of the computer program GOTHIC.
The sensitivity studies were being performed to evaluate various repair techniques that might be applied to a leaking containment fan cooler.
The results did not adequately agree with the 1986 EBASCO analysis of record which used the computer program CONTEMPT.
The utility determined that Westinghouse and EBASCO had not adequately interfaced in the 1986 era and that their respective core and containment analyses had both taken credit for the heat removed by the RHR heat exchangers.
During the utility's review, they also determined that, in 1990, Westinghouse had changed the mass and energy methodology used for these analyses to be more conservative.
This effectively changed the analyzed containment water temperature (heat sink) from 120 degrees F to 180 degrees F.
The.utility has issued ACFR 95-00693 to document and track correction of these nonconservatisms.
The utility recently performed another analysis of record-extending time to 5 million seconds, accounting for both of the above effects, and accounting for new data from a fall 1994 SWOPI.
The licensee documented this new containment analysis in ESR 9500344, Rev 0; Nonconservatisms in Design Inputs to Containment Analysis, dated March 31, 1995.
This new analysis used computer code CONTEMPT-LT26, and included decrease'd calculated containment fancooler heat transfer caused by: (a) increasing fouling factor from 0.0005 to 0.001 to account for using service water and be consistent with the analysis of other heat exchangers, (b) decreasing ESW cooling water flow from 1425 gpm to 1360 gpm to account for the lowest TS-allowed lake level and the maximum strainer pressure drop in the ESW system, and (c) removal of one section of containment fan cooler tubing in each train.
The analysis concluded that the peak containment pressure and temperature would be 51.5 psi a and 253 degrees F
respectively.
At one million seconds, the containment temperature would be 139.1 degrees F vice the originally calculated 120 degrees F,
and pressure would be 19.6 psia.
At 5 million seconds, temperature would be 133 degrees F
vice 120 degrees F and pressure would be 19 psi The analysis included an evaluation of HOVs located in the containment
- finding that one HOV, whose long-term environmental qualification was for a lower temperature than the new long-term temperature profile, functioned to mitigate an accident other than a
LOCA within the containment, and functioned to provide early containment isolation after a
LOCA within the containment.
There was no change in early post-LOCA containment parameters.
The analysis included an evaluation of other Eg equipment within the containment.
Equipment determined to be not currently Eg qualified for one full year at 133 degrees F was evaluated for service and found acceptable.
The licensee's safety analysis addressed the changes and was considered adequate.
The FSAR was included in a list of documents to be updated.
The inspector considered the inadequate NSSS/AE interface and the NSSS change of methodology in 1990 to be generic issues.
The licensee's resolution of this problem was aggressive and well documented.
The inspector identified no violations or deviations in this area.
IFI 400/95-04-02 is closed.
(Closed)
VIO 400/94-21-02, Incomplete Information to the NRC on ESW Single Failure.
The Licensee responded to this violation in letters HNP-94-096, dated December 19, 1994, and HNP-95-010, dated January 19, 1995.
The violation involved an incomplete engineering review that was reported as complete to the NRC.
The inspector reviewed the licensee corrective actions as described in the response letters.
The licensee characterized the 'reason for the violation as a
failure of the action item closeout process, specifically, management-of-issues.
During the licensee's reviews of this violation, they identified additional examples.
The inspector concurred that the management-of-issues process in effect at the time failed to obtain objective evidence supporting statements of fact and failed to maintain adequate formality of information transmission across organization interfaces.
Regarding corrective actions involving this violation, the inspector reviewed the following PCR and ESRs, finding that all were completed formal documents with the appropriate management signatures:
PCR 7409, Rev 0, ESW Single Failure Analysis; ESR 9400056, Rev 0, Single Failure Analysis for ESCWS (GL89-13);
and
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ESR 9400057, Rev 0, Single Failure Analysis for CCW (GL89-13).
Regarding corrective steps to prevent further violations:
About the time this violation was identified, the licensee initiated procedure PLP-650, Engineering Service Request, as a "one form" process for requesting engineering services and then reporting the resolution.
The inspector found that the procedure addressed both the lines of communication and the documents used to facilitate process management and documentation.
The inspector found that this program, though not implemented to resolve this violation, has generally proven to be a very powerful tool for process control and management of interfaces, status, input, and output.
Subsequent to this violation, the licensee issued AP-028, Commitment Validation, which enhanced the objective evidence required to support statements of fact in correspondence to the NRC, other government agencies, INPO, and insurance companies.
The main procedure focus was the assembly of objective evidence confirming the correctness of each statement of fact or commitment, and then the subsequent review and acceptance of this material by the Licensing/
Regulatory Programs Group.
The acceptable forms of evidence were varied, but were substantial.
The procedure identified several unacceptable forms of documentation, including draft documents, memorandums that simply state that actions were completed, and electronic media.
The inspector observed that AP-028 supplemented an older procedure, AP-611, Outgoing NRC Correspondence, which:,
dated from early plant life and applied only to NRC correspondence; made reference to a position which no longer existed at Harris, i.e., the Assistant Plant General Manager; contained errors pertaining to section numbers and references thereto which created confusion; used Outgoing NRC Correspondence Input Verification forms that accomplished part of what procedure AP-028 did, but failed to provide
conclusive objective evidence that statements of fact were correct; partially implemented the Nuclear Generation Group guidance procedure NGGM 304-01, Outgoing NRC Correspondence, which included such human factors elements as a flowchart, list of response manager duties, and the forms for input verification and for identification of commitments; and
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defined a response manager as an "individual" assigned to either fully prepare or coordinate the response/input to the NRC, whereas procedure AP-028 defined this position as a "Unit or Section Manager" assigned this responsibility.
The inspector discussed the above observations with licensee personnel who, after the end of the inspection period, initiated a change to AP-611.
During this discussion, licensee personnel identified that procedure AP-611 did not reference procedure AP-028, as it should, and that this, along with some of the above-listed observations, would be corrected with the revision.
Licensee personnel indicated to the inspector that the intent of procedure AP-611 was to address all correspondence to,the NRC, while procedure AP-028 was intended to address only the more important subset of correspondence which might contain statements of fact or completed licensee actions.
The inspector concluded that, from reviewing procedure AP-6ll, the licensee's intentions were not clear, and that in issuing procedure AP-028 without enhancing procedure AP-611 to properly communicate expectations, the licensee solved the specific situation rather than solving the management-of-issues problem - and now has two apparently conflicting procedures to deal with.
Nevertheless, the changes addressed the problem cited.
The inspector has closed this violation.
(3)
(Closed) IFI 400/94-22-04, Target Rock Vendor Manual Update Activities.
This item concerned vendor information about installing electrical covers that had not been put in the manual at Harris.
The inspector reviewed Target Rock Vendor Manual identified as
"NEX", Rev 21, dated January 26, 1995.
Section 2 had been revised to include Target Rock Co.
instructions for installing the covers on the electrical connection section.
This item is close C.
(Closed) TI-2515/129, Pressure Locking of PWR Containment Sump Recirculation Gate Valves.
This TI was issued on Harch 17, 1995, to assess the short-term actions of certain licensees, including the Harris Plant, in response to IN 95-14, Susceptibility of Containment Sump Recirculation Gate Valves to Pressure Locking, issued February 28, 1995.
The basic concern was that, in some plants, water in the bonnet area of sump recirculation gate valves could expand upon heating and "pressure lock" the valve closed, thus preventing access to a water source for long-term reactor core cooling and for containment spray.
The inspection requirements, guidance, and current plant status follow:
Verify that the licensee has a documented analysis demonstrating that the water-filled piping configuration effectively precludes pressure locking.
The inspector verified that the licensee's analysis demonstrating that the water-filled piping configuration effectively precludes pressure locking of the RHR and CS sump suction valves is documented and contained in ESR 9500335, Rev 0, Document Review of Pressure-Locking Scenario for Containment.
Verify that the length and configuration of piping between the containment sump and the recirculation HOV is consistent with the assumptions contained in the analysis used to justify operability.
The inspector reviewed isometric fabrication drawings and compared the pipe lengths and configurations to assumptions used in ESR 9500335, Rev 0.
The pipe lengths and configurations were consistent with assumptions as follows:
ISO 1-CT-ll, Rev. 15 Total pipo run was 29 ft.- 5 in. - including a 5 ft. radius bend et the bottom end then a 3 ft. horizontal run.
Vertical drop was 23 ft.- 7-1/2 in.
approximately 24 ft. (page 4/9)
ISO 1-CT-12, Rev. 18 Total pipe run wes 29 ft: 9 in. - including e 5 ft. radius band at the bottom and then a 3 ft.- 2 in. horizontal run.
Vertical drop wes 23 ft.- 9 in.
approximately 24 ft. (page 4/9)
ISO 1-SI-1-02, Rev. 0 ISO 1-SI-2-02, Rev. 0 Total pipe run was 28 ft.- 1 in. - including a 5 ft. radius bend et the bottom and then a 1 ft.- 6 in. horizontal run.
Vertical drop wes 23 ft: 9+ in.
Total pipe run was 28 ft.- 2+ in. - including a 5 ft.
radius bend at the bottom and then a 2 ft; 8 in.
horizontal run.
Vertical drop wes 23 ft.- 8+ in.
approximately 24 ft. (page 4/9)
approximately 24 ft. (page 4/9)
Determine what actions the licensee has taken to ensure the line contains the amount of water assumed in the analysis.
Operating procedure, OP-112, Rev 5/5, Containment Spray System, Section 8.5 addressed establishing a thermal insulating level in recirculation sumps and required operators to maintain sump level at 10-25 percent for this purpose.
This water level has been checked daily and logged in the control room.
The sump is 5 ft. deep.
The inspector has observed the control room operator discussing this requirement at shift turnover.
The licensee planned to continue this action until the fall 1995 refueling outage when the utility plans to inspect the sump valves and drill the disks if necessary per ESR 9500424.
Has the licensee evaluated the insulating capabilities of the water-filled piping to the extent that it precludes pressure locking (considering heat transmitted through the piping metal and water inside the piping)?
Yes, the inspector found this evaluation in ESR 9500335, Rev 0,
Document Review of Pressure-Locking Scenario for Containment.
Has the licensee adequately evaluated and documented water-filled piping as a design-basis condition?
The inspector considered this question to refer to a
permanent configuration.
The inspector verified that original pipe support design calculations for the affected piping considered water-filled conditions which would be expected following a design basis accident.
The licensee has evaluated and documented the current non-accident water-filled condition as a satisfactory temporary condition.
Therefore, all the "permanent" documentation has not been changed.
The licensee has stated in ESR 9500335, Rev 0, that they do not intend to routinely operate with water in the sump after the fall 1995 refueling outage.
Has the licensee addressed the heat transfer to and from the atmosphere surrounding the valve under accident conditions (including the temperature surrounding the valve, and time to recirculation phase)?
Yes, the inspector found this evaluation in ESR 9500335, Rev 0.
Other documentation if the adequacy of water-filled piping cannot be demonstrate The inspector concluded that this requirement was not applicable since water-filled piping was shown to be adequate.
The inspector identified no violations or deviations in this area.
This item is closed.
6.
PLANT SUPPORT a ~
b.
C.
d.
e.
Plant Housekeeping Conditions (71707)
- The inspectors reviewed storage of material and components, and observed cleanliness conditions of various areas throughout the facility to determine whether safety or fire hazards existed.
Radiological Protection Program (71750)
- The inspectors reviewed radiation protection control activities to verify that these activities were in conformance with facility policies and procedures, and in compliance with regulatory requirements.
The inspectors also verified that selected doors which controlled access to very high radiation areas wepe appropriately locked.
Radiological postings were likewise spot-checked for adequacy.
Security Control (71750)
- During this period, the inspectors toured the protected area and noted that the perimeter fence was intact and not compromised by erosion or disrepair.
The fence fabric was secured and barbed wire was angled.
Isolation zones were maintained on both sides of the barrier and were free of objects which could shield or conceal an individual.
The inspectors observed various security force shifts perform daily activities, including searching personnel and packages entering the protected area by special purpose detectors or by a physical patdown for firearms, explosives, and contraband.
Other activities included vehicles being searched, escorted, and secured; escorting of visitors; patrols; and compensatory posts.
In conclusion, the inspectors found that selected functions. and equipment of the security program complied with requirements.
Fire Protection (71750)
- Fire protection activities, staffing and equipment were observed to verify that fire brigade staffing was appropriate and that fire alarms, extinguishing equipment, actuating controls, fire fighting equipment, emergency equipment, and fire barriers were operable.
During plant tours, areas were inspected to ensure fire hazards did not exist.
Emergency Preparedness (71750/82301)
- Emergency response facilities were toured to verify availability for emergency operation.
Duty rosters were reviewed to verify appropriate staffing levels were maintained.
As applicable, emergency preparedness exercises and drills were observed to verify response personnel were adequately traine On Harch 30, 1995, the licensee conducted an EP drill in preparation for its annual exercise to be run on April 18, 1995.
The inspector observed activities in the makeshift drill control room, TSC, and EOF.
As noted previously by NRC inspectors, the makeshift drill control room does not allow for evaluation of operator physical response.
The operators functioned based on the drill script and the utility's evaluation was based on crew decision making.
Licensee management has previously indicated intentions to relocate this drill function to the plant simulator.
The inspector observed that the Site Emergency Coordinator in the TSC made sound technical decisions and communicated well with team members and during briefings.
The inspector noted that engineering discussions were held several times in the TSC rather than in the accident assessment team room.
These discussions in the TSC became animated with increasing volume and were distracting.
Additionally, the inspector noted at least two occasions where only two principal functional members of the TSC staff were in the TSC.
The EOF, OSC, and TSC had b'een staffed for at least 30 minutes before the EP staffing board in the TSC was fully implemented.
These observations indicated that TSC command and control needed strengthening.
The inspector did not identify any significant weaknesses when he observed the operation of the EOF.
EOF command and control appeared to be a strength in contrast to the TSC.
The l.icensee met the objectives of the drill.
The inspector discussed his observations with the licensee who informed the inspector that ERO Team "D" was recently organized and had the
'east experience as a team.
The licensee had also identi'fied the same weaknesses as the inspector.
Licensee personnel indicated that this response team would participate in another practice drill on April 13 before the NRC graded exercise scheduled for April 18, 1995.
The inspectors found plant housekeeping and material condition of components to be satisfactory.
The licensee's adherence to radiological controls, security controls, fire protection requirements, emergency preparedness requirements, and TS requirements in these areas was satisfactory.
The inspectors identified no violations or deviations in the plant support area.
EXIT INTERVIEW (30703)
The inspectors met with licensee representatives (denoted in paragraph I) at the conclusion of the inspection on April 7, 1994.
During this meeting, the inspectors summarized the scope and findings of the inspection as they are detailed in this report.
The licensee representatives acknowledged the inspector's comments and did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
The licensee expressed some disagreement with the inspectors'omments regarding the procedure
developed to close violation 400/94-21-02 (paragraph 5.b.(2)), the practice emergency drill (paragraph 6.e),
and the PNSC meeting (paragraph 3.b); however, no other dissenting comments were received.
'Subsequently, NRC Region II has carefully reviewed these report sections and concluded that they stand as written.
Item Number 400/94-22-02 400/95-04-02 400/94-21-02 400/94-22-04 TI-2515/129 Status Closed Closed Cl os ed Cl osed Closed Descri tion and Reference VIO Procedure Violations - Three Examples, paragraph 4.c.
IFI Nonconservative Containment LOCA Analysis of Record, paragraph 5.b.(1).
VIO Incomplete Information to the NRC on ESW Single Failure, paragraph 5.b.(2).
IFI Target Rock Vendor Manual Update Activities, paragraph 5.b.(3).
TI Pressure Locking of PWR Containment Sump Recirculation Gate, Valves, paragraph 5.c.
ACRONYHS AND INITIALISNS ACF.R AE AFW CCW CFR CPRL EBASCO ECCS EOF EP Eg ERO ESCWS ESFAS ESR ESW FSAR GL GPH HNP IFI INPO ISO LOCA Adverse Condition and Feedback Report Architect Engineer Auxiliary Feedwater Component Cooling Water Code of Federal Regulations Carolina Power 8 Light Co., Inc.
An Architect/Engineer Firm's Name Emergency Core Cooling System Emergency Operations Facility Emergency Preparedness Environmental gualification/ Environmentally gualified Emergency Response Organization Essential Services Chilled Water System Engineered Safety Feature Actuation System Engineering Service Request Emergency Service Water Final Safety Analysis Report Generic Letter Gallons per Minute Harris Nuclear Plant Inspector Followup Item Institute of Nuclear Power Operations Isometric Drawing Loss of Coolant Accident
H&TE HOV NRC NRR NSSS OSC PCR PNSC PSIA PSP PWR RHR RWST SWOPI-TDAFW-TI TS TSC VIO WR/JO-
Heasuring 8 Test Equipment Hotor Operated Valve Nuclear Regulatory Commission Nuclear Reactor Regulation Nuclear Steam System Supplier Operations Support Center Plant Change Request Plant Nuclear Safety Committee Pounds per Square Inch, Absolute Physical Security Plan Pressurized Water Reactor Residual Heat Removal Refueling Water Storage Tank Service Water Operational Performance Inspection Turbine Driven Auxiliary Feedwater Temporary Instruction Technical'pecification Technical Support Center Violation Work Request/Job Order