IR 05000400/1990008

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Insp Rept 50-400/90-08 on 900421-0518.Violations Noted But Not Cited.Major Areas Inspected:Plant Operations, Radiological Controls,Security,Fire Protection,Surveillance Observation,Maint Observation & LERs
ML18009A577
Person / Time
Site: Harris 
Issue date: 06/01/1990
From: Dance H, Shannon M, Tedrow J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18009A576 List:
References
50-400-90-08, 50-400-90-8, NUDOCS 9006210536
Download: ML18009A577 (17)


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C n0 lVl Cy Wp*y4 UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323 Report No.:

50-400/90-08 Licensee:

Carolina Power and Light Company P. 0.

Box 1551 Raleigh, NC 27602 Docket No.:

50-400 Facility Name:

Harris

Inspection Conducted: April 21 - May 18, 1990 Inspectors:

J.

e r w, enior Resi ent Inspector License No.:

NPF-63 Date Signe an

, Resi ent nspector at igne Approved by:

a e,

ection ie React r Projects Branch

Division of Reactor Projects ate igne SUMMARY Scope:

This routine inspection was conducted by two resident inspectors in the areas of plant operations, radiological controls, security, fire protection, surveillance observation, maintenance observation, licensee event reports, evaluation of licensee self-assessment capability, actions regarding loss of decay heat removal, and licensee action on previous inspection items.

Numerous facility tours were conducted and facility operations observed.

Some of these tours and observations were conducted on backshifts.

Results:

Two non-cited licensee identified violations were identified:

Failure to properly analyze a reactor coolant sample following a power decrease, paragraph 5.b Failure to sample secondary liquid waste during a continuous release, paragraph 5.d.

An operational strength involving a pre-planned work activity is identified in paragraph 3.

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PDC

Further discussion of a previously identified weakness involving a backlog of required reviews by the CNS Section is included in paragraph REPORT DETAILS Persons Contacted Licensee Employees R. Black, Jr.,

Manager, Nuclear Safety Review

  • J. Collins, Manager, Operations W. Crawford, Manager, Corporate Nuclear Safety G. Forehand, Manager, gA/QC J. Garcia-Serafin, Sr. Reactor Engineer
  • C. Gibson, Director, Programs and Procedures
  • P. Hadel, Project Specialist, Maintenance Planning J.

Hammond, Unit Manager Onsite Nuclear Safety C. Hinnant, Plant General Manager

  • C. Jeffries, Sr. Specialist, Regulatory Compliance
  • D. McCarthy, NED Site Principal Engineer
  • J. Nevill, Manager, Technical Support C. Olexik, Manager, Shift Operations
  • H. Pollock, Sr.

gA Specialist W. Ponder, Sr. Reactor Engineer R. Richey, Manager, Harris Nuclear Project Department

  • J. Sipp, Manager, Environmental and Radiation Monitoring H. Smith, Manager, Radwaste Operation
  • M. Staton, N. C. Power Agency
  • F. Strehle, Project Engineer, gA Engineering
  • W. Szuba, Jr., Supervisor, Modification Management
  • D. Tibbits, Director, Regulatory Compliance
  • E. Willett, Manager, Modification Projects Other licensee employees contacted included office, operations, engineering, maintenance, chemistry/radiation and corporate personnel.

"Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph.

Review of Plant Operations (71707)

The plant continued in power operation (Mode 1) for the duration of this inspection period.

a.

Shift Logs and Facility Records The inspector reviewed records and discussed various entries with operations personnel to verify compliance with the Technical Specifications (TS)

and the licensee s administrative procedure The following records were reviewed:

Shift Foreman's Log; Control Operator's Log; Auxiliary Operator's Log; Night Order Book; Equipment Inoperable Record; Active Clearance Log; Jumper and Wire Removal Log; Shift Turnover Checklist; and selected Chemistry/Radiation Protection and Radwaste Logs.

In addition, the inspector ind'ependently verified clearance order tagouts.

No violations or deviations were identified.

b.

Facility Tours and Observations Throughout the inspection period, facility tours were conducted to observe operations and maintenance activities in progress.

Some, operations and maintenance activity observations were conducted during backshifts.

Also,.during this inspection period, licensee meetings were attended by the inspectors to observe planning and management activities.

The facility tours and observations encompassed the following areas:

security perimeter fence; control room; emergency diesel generator building; reactor auxiliary building; waste processing building; fuel handling building; emergency service water building; battery rooms; and electrical switchgear rooms.

During these tours, the following observations were made:

(I)

Monitoring Instrumentation - Equipment operating status, area atmospheric and liquid radiation monitors, electrical system lineup, reactor operating parameters, and auxiliary equipment operating parameters were observed to verify that 'indicated parameters were in accordance with the TS for the current operational mode.

(2)

Shift Staffing - The inspectors verified that operating shift staffing was in accordance with TS requirements and that control room operations were being conducted in an orderly and professional manner.

In addition, the inspector observed shift turnovers on various occasions to verify the continuity of plant status, operations problems, and other pertinent plant information during these turnovers.

(3)

Plant Housekeeping Conditions - Storage of material and components, and cleanliness conditions of various areas throughout the facility were observed to determine whether safety and/or fire hazards existed.

(4)

Radiological Protection Program - Radiation protection control activities were observed routinely to verify that these activities were in conformance with the facility policies and procedures, and in compliance with regulatory requirement The inspectors also reviewed selected RWPs to verify that the RWP was current and that the controls were adequate.

(5)

Security Control - In the course of the monthly activities, the inspector included a review of the licensee's physical security program.

The performance of various shifts of the security force was observed in the conduct of daily activities to include:

protected and vital area access controls; searching of personnel, packages, and vehicles; badge issuance and retrieval; escorting of visitors; patrols; and compensatory posts.

In addition, the inspector observed the operational status of Closed Circuit Television (CCTV) monitors, the Intrusion Detection system in the central and secondary alarm stations, protected area lighting, protected and vital area barrier integrity, and the security organization interface with operations and maintenance.

(6)

Fire Protection - 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.

No violations or deviations were identified.

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3.

Surveillance Observation (61726)

Surveillance tests were observed 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.

The following tests were observed and/or data reviewed:

OST-1008, 1A-SA RHR Pump Operability quarterly Interval OST-1014, Turbine Valve Test Monthly Interval MST-I0108, Pressurizer Pressure and PORV Loop (P-0444) Calibration MST-I0207, Refueling Water Storage. Tank Liquid Level Channel IV (L-0993) Operational Test Test MST-I0108 involved an operational test of a pressure transmitter which supplied a control signal for automatic plant pressure control.

Since this test became due during power operation, manual control of plant pressure was necessary.

Operations personnel conducted a

pre-evolution planning/briefing meeting to cover possible events and actions which might be necessary pending equipment/test malfunction.

Also the licensee utilized the plant simulator to rehearse operator actions required during plant transients with manual pressure control, and stationed dedicated operators in the control room to.control pressure during the test.

As a result of this pre-planning, plant operators were able to expeditiously respond to a spurious opening of the pressurizer

spray valve.

Manual operator action limited the resultant pressure decrease to only 15 psig.

This type of pre-evolution planning to anticipate possible plant transients is considered to be an operational strength.

No violations or deviations were identified.

Naintenance Observation (62703)

The inspector observed/reviewed maintenance activities to verify that correct equipment clearances were in effect; work requests and fire prevention work permits, as required, were issued and being followed; quality control personnel were available for inspection activities as required; and, TS requirements were being followed.

Maintenance<was observed and work packages were reviewed for the following maintenance (WR/JO) activities:

Troubleshoot loss of power to the "B" containment hydrogen monitor (AE-01SP-7438SB)

and post maintenance testing in accordance with procedure MST-I0116, Containment Hydrogen Analyzer System Calibration.

Repair seat leak on chill water valve 1CH-9 in accordance with procedure CN-M0031, Yarway Valves (2" and smaller)

Disassembly and Maintenance.

Repack low head safety injection vent valve 1SI-307.

Troubleshoot intermittent level spike on RWST Level Channel IV and post maintenance testing in accordance with procedure MST-I0043,

. Refueling Storage Tank Liquid Level Channel IV (L-0993) Calibration.

Inspect/repair CST level transmitter FT-9010A in accordance with procedure CN-I0104, Rosemount Transmitter Model 1153 and 1154 Sensor Nodule Replacement, and post maintenance testing in accordance with procedure MST-I0086, Condensate Storage Tank Level Loop (L-9010A)

Calibration.

No violations or deviations were identified.

5.

Review of Licensee Event Reports (92700)

The following LERs were reviewed for potential generic impact, to detect trends, and to determine whether corrective actions appeared appropriate.

Events that were reported immediately were reviewed as they occurred to determine if the TS were satisfied.

LERs were reviewed in accordance with the current NRC Enforcement Policy.

a ~

(Closed)

LER 89-09:

This LER reported the failure to obtain a grab sample while a radiation monitor was inoperable.

As discussed in NRC Inspection Report 50-400/89-33, the licensee formed a task force to correct weaknesses associated with implementing compensatory measures for inoperable radiation monitors.

The task force recommendations appear to have corrected this deficiency.

The

b.

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inspector reviewed and verified the licensee's corrective action as stated in the LER.

(Closed)

LER 89-10:

This LER reported that a

TS required isotopic analysis of reactor coolant was not performed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following a change in reactor power greater than 15 percent.

The licensee's corrective action included counseling the technician who made a

personnel error, and reviewing this event with other technicians to prevent similar errors.

This matter is considered to be a licensee identified NCV and is not being cited because criteria specified in section V.G.1 of the NRC Enforcement Policy were satisfied.

NC4 (90-08-01):

Failure to perform an isotopic analysis of reactor coolant following a reactor power change greater than 15 percent.

(Closed)

LER 89-11:

This LER reported that reactor power slightly exceeded the maximum permitted by the operating license on several occasions.

The inspector reviewed and verified the licensee's corrective action as stated in the LER.

d.

(Closed)

LER 89-12:

This LER reported the failure to sample secondary liquid waste dur ing a continuous release.

A grab sample of secondary waste, taken after the release was terminated, indicated no radioactivity was present.

The licensee has revised their procedures to help prevent the recurrence of this event.

This matter is considered to be a licensee identified NCV and is not being cited because criteria specified in section V.G.1 of the NRC Enforcement Policy were satisfied.

NC4 (90-08-02):

Failure to sample secondary liquid waste during a continuous release.

e.

(Closed)

LER 90-07:

This LER reported that the methodology used to calculate the activity for waste gas releases was nonconservative.

The inspector reviewed and verified the licensee's corrective action as stated in the LER.

(Closed).LER 90-09:

This LER reported that plant operators failed to perform an evaluation of the RCS leak rate during inoperability of the plant computer.

This event is similar to LER 90-04 which is discussed in NRC Inspection Report 50-400/90-06.

The inspector reviewed and verified the licensee's corrective action as stated in the LER.

g.

(Closed)

LER 90-11:

This LER reported the failure to conduct leakage tests on a

RCS pressure boundary valve.

This matter was previously discussed in NRC Inspection Report 50-400/90-06 and was the subject of a violation (90-06-04).

For record purposes, further action on this event will be tracked by the violatio h.

(Open)

LER 90-12:

This LER reported an inadvertent emergency diesel generator actuation while performing undervoltage testing.

This event was previously discussed in NRC Inspection Report 50-400/90-06.

The licensee is presently redesigning the undervoltage test circuit to prevent recurrence of this event.

The LER will remain open pending completion of this corrective action.

Evaluation of Licensee Self-Assessment Capability (40500)

The inspectors reviewed the activities of the licensee's Corporate Nuclear Safety and Onsite Nuclear Safety units and discussed the responsibilities of these units with licensee personnel.

Onsite review committee activities were previously discussed in NRC Inspection Report 50-400/89-28.

The CNS Program Policy Statement and CNS/ONS procedures were reviewed to determine general requirements.

This review 'included a

determination that TS requirements were being satisfied with regard to unit composition, qualification of unit members, unit functioms, required reviews, and records of unit activities.

Unit activities included system reviews, field observations, special investigations, participation in task forces, and reviews of plant events.

Some of the specific activities and recommendations reviewed are listed below:

CNS special investigation October 9, 1989 ONS system reviews of the CNS special investigation plant star tup CNS special investigation

, problems ONS special investigation of the generator/transformer fire of ESW and SI systems into a NI miscalibration during the last of recurrent radiation monitor system into circuit breaker problems The inspectors found the special investigations and system reviews to be thorough and recommendations appropriate.

Recommended actions were tracked, discussed with plant management, and adequately resolved.

Particularly noteworthy was the practice by ONS to perform weekend/backshift observations of plant activities which included plant startups and special evolutions.

As part of their review of plant events, the licensee is presently developing a program to trend and categorize root causes.

Full implementation of this program will enhance the independent review process in determining areas in need of review/audit.

While reviewing this area, the inspector noticed that a mechanism did not exist which could determine if problems were repetitive.

Personnel memory was relied upon to determine if an existing problem had previously occurred.

Although this process can produce the desired result, it is subject to personnel changes.

The failure to have a mechanism to track repetitive problems impedes the effectiveness of the independent review process.

A review of the corporate tracking program also found a high reliance on memory.

No documented method existed for tracking the status of

,

recommendations.'tems such as responsible person, due date, and required action, were not documented but rather remembered by the responsible reviewer.

The licensee was in the process of developing a

new tracking system, which would document the above items, for the other licensee nuclear plants but had not yet decided to implement this system for the Harris plant.

Through discussions with licensee personnel, the inspector was informed that a significant backlog of TS required reviews existed.

Based on the present rate of closure, there exists about 10 months of backlog.

This matter was previously identified as a weakness in NRC Inspection Report 50-261/89-25 in November 1989.

Licensee personnel stated that efforts were underway to reduce this backlog by dedicating more of the reviewer's time to these required reviews.

If the backlog continues after this action, additional resources would be requested from other departments.

In conclusion, the independent review activities performed by CNS/ONS are high quality and valuable assets to plant safety.

However, the significant review backlog, the lack of a mechanism to determine repetitive problems, and the reliance on memory for tracking the status on recommendations, impede the usefulness of this oversight activity.

The licensee was encouraged to expeditiously decrease the review backlog to obtain the full benefit of timely independent reviews and their effect of enhancing plant safety.

Review of Actions Regarding Loss of Decay Heat Removal (92701)

(Closed) TI 2515/101:

This inspection was performed to verify the licensee's preparations for lowered RCS inventory operation in accordance with the expeditious actions recommended in NRC Generic Letter No. 88-17, Loss of Decay Heat Removal.

The inspector reviewed and verified implementation of the licensee's actions as stated in their submittals dated December 21, 1988 and January 3, 1989.

Following review of these submittals, correspondence dated May 10, 1989, was issued containing comments and observations by the NRC staff regarding the licensee's actions.

The licensee subsequently documented additional information concerning these comments in an internal memorandum dated August 8, 1989.

The licensee has been proactive in reviewing this matter, having completed many of the recommended expeditious actions prior to the July 1988 refueling outage which occurred before the issuance of the generic letter.

(Open) TI 2515/103:

This inspection was performed to review the licensee's long term programmed enhancements which were recommended by the generic letter.

In correspondence dated February 1, 1989, the licensee stated which enhancements they were considering.

This correspondence is presently under review by the NRC staff.

Several of the enhancements presented in the licensee's response remain to be accomplished:

Plant modifications will include the installation of a level transmitter in the RCS standpipe to provide control room indication (PCR-4491, RCS Standpipe Level Indication in Control Room).

To enhance the monitoring of RHR system operation, the licensee initially decided to install indications of RHR pump'uction pressure.

The licensee has subsequently decided to add RHR pump differential pressure to the control room indications (PCR-4489, RHR Pump Performance Monitoring During Nid-Loop Operation)

instead.

Audible alarms/indications of abnormal RHR system conditions will be evaluated and installed (PCR-4489).

WOG interim guidance on RCS mid-loop operation has been incorporated into plant procedures, however the WOG is preparing detailed guidance on step sequencing and identification of continuous actions.

This action should also provide the necessary analysis to support the recommended actions.

Evaluation of TS changes to permit a second CSIP to be operable during reduced inventory operation (PCR-4488, Two CSIP Available for Mid-Loop Operation/Evaluation)

and to remove the RHR valve automatic closure interlock (PCR-2898, Suction Valve Auto Closure Deletion and Replacement).

Analysis of RCS vent capability and RWST flow path resistance to the RCS (PCR-4488).

As part of these inspections, the following procedures/items were reviewed:

OP-ill, Residual Heat Removal System LP-RTT-89-032, Real Time Training Lesson Plan for Precautions Related to Reduced Inventory RHR Operation AOP-020, Loss of RCS Inventory or Residual Heat Removal While Shutdown PG0-054, Control of Plant Activities During Reduced Inventory Conditions WOG Interim Guidance on Nid-Loop Operations GP-008, Draining the Reactor Coolant System GP-009, Refueling Cavity Fill, Refueling, and Draindown of the Refueling Cavity No violations or deviations were identified.

8.

Licensee Action on Previously Identified Inspection Findings (92702

92701)

a ~

(Closed) IFI 89-06-01:

Review the licensee's action regarding auxiliary feedwater pump overspeed problems.

The licensee has

implemented the task force recommendations to resolve this recurring problem.

These recommendations included:

Clean pump steam traps and establish preventive maintenance frequency Increase the electrical overspeed trip to 115 percent Long term data collection on pump variables Development of preventive maintenance inspections on the pump to inspect governor valve stem corrosion, trip linkage alignment and worn parts, governor valve packing Check for loose electrical connections Check low suction pressure trip setpoints Due to another overspeed trip which occurred on October 9, 1989 (discussed in LER 89-17), the licensee decided to eliminated the pump's electrical overspeed device (PCR-4935, Turbine Driven Auxiliary Feedwater Pump Electrical Overspeed Removal) which was believed to have caused spurious pump trips.

(Closed) IFI 400/90-06-05:

Review the licensee s investigation into repeated loss of power to the "A" emergency bus while performing undervoltage testing.

The licensee has issued LER 90-12 on this event documentin the planned corrective action.

For record purposes, losed and future action tracked by the LER.

b.

the IFI will be c 9.

Exit Interview (30703)

Item Number Descri tion and Reference The inspectors met with licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on Hay 18, 1990.

During this meeting, the inspectors summarized the scope and findings of the inspection as they are detailed in this report, with particular emphasis on the Violations addressed below.

The CNS backlog was identified as a weakness.

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.

90-08-01 90-08-02 NCV:

Failure to perform an isotopic analysis of reactor coolant following a reactor power change greater than

percent.

NCV:

Failure to sample secondary liquid waste during a

continuous release.

10.

Acronyms and Initialisms AOP

-

Abnormal Operating Procedure CCTV

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Closed Circuit gelevision CFR

-

Code of Federal Regulations

CNS CSIP CST ESW GP IFI LER HST NCV NI NRC ONS OP OST PCR PGO PORV PSIG QA QC RCS/RC RHR RWP RWST SI/SIS SOOR TI TS WOG WR/JO Corporate Nuclear Safety Charging Safety Injection Pump Condensate Storage Tank Emergency Service Water General Procedure Inspector Follow-up Item Licensee Event Report Naintenance Surveillance Test Non-cited Violation Nuclear Instrumentation Nuclear Regulatory Commission Onsite Nuclear Safety Operating Procedure Operations Surveillance Test Plant Change Request Plant General Order Power Operated Relief Valve Pounds per Square Inch Gage Quality Assurance Quality Control Reactor Coolant System Residual Heat Removal Radiation Work Permit Refueling Water Storage Tank Safety Injection Signal Significant Operational Occurrence Report Temporary Instruction Technical Specification Westinghouse Owner's Groups Work Request/Job Order

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