IR 05000400/1991001
| ML18009A834 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/01/1991 |
| From: | Christensen H, Shannon M, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18009A832 | List: |
| References | |
| 50-400-91-01, 50-400-91-1, NUDOCS 9103120034 | |
| Download: ML18009A834 (15) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report No.:
50-400/91-01 Licensee:
Carolina Power and Light Company P.
0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
d'or ess ent nspecto M.
hannon, Resident Inspector Approved by:
.H.
ristensen, Section
>e Division of Reactor Projects Inspection Conducted:
J nuary 26 - February 22, 1991 Inspectors:
e row, License No.:
NPF-63 3r gl a
e
~gne 3/~/ F(
Date Signed Nl ate
>gne 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, design changes, spent fuel shipping program, preparations for refueling, licensee event reports 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:
One violation was identified:
failure to properly fill the RVLIS reference leg, paragraph 9.d.
A non-cited licensee identified violation concerning a failure to periodically test two check valves in the control room HVAC system was identified, paragraph 5.
9103120034 910304 PDR ADOCK 05000400 G
REPORT DETAILS 1.
Persons Contacted Licensee Employees
- P. Beane, Manager, guality Control
- J. Collins, Manager, Operations
- C. Gibson, Director, Programs and Procedures
- C. Hinnant, Plant General Manager
- D. McCarthy, Manager, Site Engineering
- B. Meyer, Manager, Environmental and Radiation Mopitoring
- T. Morton, Manager, Maintenance
- J. Nevill, Manager, Technical Support
- A. Powell, Harris Training Unit Training Manager C. Olexik, Director, Reguilatory Compliance
- R. Richey, Vice President, Harris Nuclear Project H. Smith, Manager, Radwaste Operation E. Willett, Manager, Outages and Modifications
- W. Wilson, Manager, Spent Nuclear Fuel Other licensee employees contacted included office, oper'ations, engineering, maintenance, chemistry/radiation and corporate personnel.
- Attended exit interview
. Acronyms and Initialisms used throughout this report are listed in the last paragraph.
2.
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 procedures.
The following records were reviewed:
Shift Foreman's Log; Control Operator's Log; Night Order Book; Equipment Inoperable Record; Active Clearance Log; Jumper and Wire Removal Log; Temporary Modification Log; Chemistry Daily Reports; Shift Turnover Checklist; and selected Radwaste Logs.
In addition, the inspector independently verified clearance order tagouts.
No violations or deviations were identifie b.
Facility Tours and Observations Throughout the inspection period, facility tours were conducted to observe operations, surveillance, and maintenance activities in progress.
Some of these 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; turbine building; fuel handling building;.
emergency service water building; battery rooms; electrical switchgear rooms; and the technical support cente During these tours, the'following observations were made:
( 1)
Nonitoring 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, operational 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.
The licensee has recently completed construction of a permanent contaminated tool storage area in the waste processing building.
This facility will provide additional storage capability for specialized tools.
(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 requirements.
The inspectors also reviewed selected radiation work permits to verify that controls were adequat During plant tours the inspectors noticed that several drip bags had been installed under various system flanges and valves to contain any radioactive liquid leakage.
Licensee personnel were questioned to obtain the status of repair efforts.
An informal tracking list had been generated which depicted drip bag location, date installed,'nd work request number to repair.
The licensee presently has approximately 63 drip bags installed, most of which have work in progress or scheduled to be worked during the upcoming refueling outage.
The licensee was encouraged to continue their efforts to minimize system leakage.
'FI (400/91-01-01):
Review licensee's progress to repair flanges and valves and minimize system leakage.
(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 which included:
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.
(7)
Contaminated Areas. - The licensee has greatly reduced the total square footage of contaminated areas.
Presently there is 1750 square feet of recoverable contaminated area following the recent decontamination of 3600 square feet of plant area, which includes areas in the fuel handling building noted in para-graph 8.
The cleanup allows greater access to plant equipment and has improved overall plant appearance.
No violations or deviations were identified.
Review of Nonconformance Reports Adverse Condition Reports (ACRs)
were reviewed to verify the following:
TS were complied with, corrective actions as identified in the reports were accomplished or being pursued for completion, generic items were identified and reported, and items were reported as required by the TS.
No violations or deviations were identifie,
Surveil l ance Observati on (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:
CRC-524 CRC-100 MST-I0128 Boron Using The Nettler DL40RC Memotitrator Reactor Coolant System Chemistry Control Main Steam Line Pressure'perational Test MST-I0182 Containment Spray Additive Tank Level Loop Calibration MST-I0108 PORV ( 1) Actuation Channel Calibration MST-I0109 PORV (2) Actuation Channel Calibration EPT-172 Control Room Area HVAC Check Valve Full Flow Test
'o violations'r deviations were identified.
4.
Maintenance 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, for the mini RHR Train "A" outage, were reviewed for the following maintenance (WR/JO) activities:
89-AKKZ1 88-ANPP1
"A" recirc valve packing replacement Low head SI train "A" to hot leg crossover isolation valve packing replacement RHR header
"A" isolation valve to CSIP suction packing replacement RWST to RHR pump 1A-SA isolation valve packing replacement
"A" recirc FCV-602 inspection No violations or deviations were identified.
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.
(Open)
LER 91-01:,
This LER reported that two check valves in the control room HYAC system were not periodically tested as required by TS 4.0.5.
The
. licensee discovered this matter during a
procedure review by operations personnel.
The licensee attributed the cause for this event to be due to a
procedure deficiency and has revised the procedure accordingly.
The check valves were tested satisfactorily on January 16, 1991.
This matter is considered to be a licensee identified NCY 'and is not being cited because the criteria specified in section V.G.1 of the NRC
- Enforcement Policy were satisfied.
.NC4(400/91-01-02):
Failure to periodically test two check valves in the control room HYAC system.
Additional corrective action planned by the licensee will include reviewing this event with operations procedure group personnel and performance of a
comprehensive procedure review by inservice testing personnel to identify similar problems.
The LER will remain open pending completion of this additional corrective action.
Design Changes and Modifications (37828)
Installation of new or modified systems were reviewed to verify that the changes were approved in accordance with 10 CFR 50.59, that the changes were performed in accordance with technically adequate and approved procedures, that subsequent testing and test results met acceptance criteria or deviations were resolved in an acceptable manner, and that appropriate drawings and facility procedures were revised as necessary.
This review included selected observations of modifications and/or testing in progress.
Modification PCR-5562, ECCS Flow Measurement (High Head Safety Injection Balancing Orifices) was reviewed.
No violations or deviations were identifie Review of the Spent Fuel. Shipping Program (71707)
As a followup to the observations and a violation documented in recent NRC inspection reports, the inspectors continued to review spent fuel pool cleanup activities.
The problems associated with the BWR fuel crud appear to be under control although no BWR fuel assemblies have been received for three months.
The Unit 1 transfer canal, main transfer canal and
"B" spent fuel pool have been cleaned and the crud sediment on the floor of the unit 2-3 transfer canal is presently being filtered.
The licensee is experiencing a filter breakthrough of small particles now that they are trying.-to clean up the worst part of the crud buildup.
This has caused difficulties in the cleanup process.
Further problems with fuel pool water chemistry have been noted, in that the silica concentration of 1400 PPB exceeds the RCS limit of 1000 PPB.
The installed demineralizers are not designed to remove the silica and preliminary plans called for draining of the transfer canal and refilling with higher quality water which was completed on February 20, 1991.
A major improvement was noted with the reduction of the contaminated areas in the fuel handling building.
The floor areas around the "A" and
"B" fuel pools and the majority of the laydown area between the
"B" and
"C" fuel pools has been decontaminated and excess material has been removed.
This has greatly improved the appearance of the fuel handling building and affords easier plant staff access.
No violations or deviations were identified.
Preparations for Refueling (60705)
This inspection was performed to ascertain the adequacy of licensee procedures and administrative controls for refueling operations and for controlling plant conditions during refueling.
Licensee procedures and activities were reviewed/observed in the following areas:
receipt inspection and storage of new fuel, fuel handling, core verification, core internals handling, periodic monitoring of spent fuel cooling parameters, surveillance testing and refueling equipment checkout, and casualty response.
In addition, licensee actions in response to industry events related to refueling operations were reviewed.
These events included those discussed in NRC Information Notices 86-58, Dropped Fuel Assembly, and 90-77, Inadvertent Removal of Fuel Assemblies From the Reactor Core.
Supplement
to Information Notice 90-77 was recently issued on February 4, 1991.
Licensee personnel are presently reviewing this supplement to determine an appropriate method to verify that fuel assemblies are not inadvertently lifted out of the core during the removal of the upper internals assembly.
Presently an underwater camera propelled by a
mini-submarine with attached lighting is being considered to positively verify no fuel assemblies are inadvertently lifted.
As part of this inspection, the following procedures were reviewed:
PLP-616 Fuel Handling Operations GP-009 Refueling Cavity Fill, Refueling, and Dr aindown of the Refueling Cavity FHP-003 Unpacking and.Handling of New Fuel Assemblies, Fuel Inserts and New Fuel Shipping Containers FHP-005 Spent Fuel Handling Tool Operation FHP-010 Core Mapping Following Fuel Loading FMP-014 Fuel and Insert Shuffle Sequence FMP-020 Fuel Handling Operations FMP-106 New Fuel Receipt Inspection CM-M0094 Integrated Reactor Vessel Head and Upper Internals Removal CM-M0165 Reactor Vessel Head and Upper Internals Installation AOP-013 Fuel Handling Accident-AOP-.031 Loss of Refueling Cavity Integrity In conclusion, the inspector found the licensee's procedures to be satisfactory with inclusion of valuable lessons learned from industry events.
No violations or deviations were identified.
Licensee Action on Previously Identified Inspection Findings (92702
92701)
(Closed)
IFI 400/88-12-01:
Adequacy of Manual and Computerized Dose Projection Systems.
b.
co Followup of this item will be part of the routine evaluation of the 1 icensee
'
emergency response acti vities.
'I (Closed)
IFI 400/88-34-04:
Follow the licensee's plan to reduce the large backlog of overdue procedure revisions.
The licensee has reduced the number of overdue maintenance procedure revisions from 700 to less than 60.
The licensee is presently committed to completing the.required procedure
~ revisions by the end of 1991.
An improved computer/word processing system is now being used to process procedure revisions and it will eliminate future problems in this area.
(Closed)
URI 400/89-35-02:
Testing of PORV Channel.
During the review of this item it was noted that the licensee performed automatic PORV testing during mode 1 and was documented in NRC Inspection Report 50-400/90-08.
The performance of surveillances MST-I108, PORV (1) Actuation Channel Calibration, and MST-I109, PORV (2) Actuation Channel Calibration, when the RCS is greater than 2000 PSIG, eliminates the concern of inadequate PORV testing.
The licensee has coranitted to revising the appropriate procedures to insure that the automatic function of the PORV circuitry will continue to be properly teste (Closed)
URI 400/90-24-01:
Failure to refill the RVLIS reference leg.
Inspection Report 400/90-24 identified the licensee's failure to fill the RVLIS reference leg following the 1989 refueling outage.
The failure to refill the reference leg could result in both channels of RVLIS being in error by as much as 36 inches.
Both 'channels use a
common reference leg and therefore would indicate up to 36 inches higher than actual reactor ve'ssel level during low pressure conditions.
The failure to refill the RVLIS reference leg during the 1989 refueling outage resulted in a non-conservative RVLIS indication during subsequent reduced RCS inventory conditions.
This item was identified as URI (400/90-24-01)
pending an evaluation by the RVLIS manufacturer.
In a letter dated February 15, 1991, the manufacturer indicated that the reference leg for RVLIS needed to be filled and identified two places in the RVLIS technical manual where filling and venting was discussed.
The manufacturer's letter also discussed loss of coolant scenarios and instrument inaccuracies due to improper reference leg filling.
The manufacturer stated that design basis inaccuracies for RVLIS would be six percent at high temperatures.
The highest possible error due to inadequate filling would result in a positive ten percent error in RVLIS indication, which clearly exceeded the design accuracy of the RVLIS system.
The letter went on to state that the RVLIS error would not violate the RVLIS uncertainty requirements because the use of RVLIS in the Westinghouse ERGs, following a large break LOCA, was for trending purposes only.
The letter failed to address the critical safety function for core cooling, which uses a
39 percent indication by RVLIS to determine a red path item.
The determination of a red path item is also a vital input used for determining emergency classification between alert, site area emergency, and general emergency.
The manufacturer's letter also stated, for a non-design basis LOCA, that the total RVLIS error due to air in the reference leg would be limited to 15 inches or about three percent.
On November 14; 1990 following plant shutdown and depressurization, it was documented that the entrapped air bubble did replace the water in the reference leg, which resulted in a 20 inch RVLIS indication error, or a four percent error.
This four percent error added to the instrument uncertainties error of three percent also exceeded the design error of six percen The critical safety function status tree identifies
percent indication on RVLIS as a determining point for a red path item.
The significance of a critical safety function red path item is that it forces the operator to take steps to combat a specific critical event.
It is imperative that.the operators combat the event when required.
The 39 percent RVLIS level indicates that approximately one fourth of the reactor core would be uncovered.
An additional ten percent error due to entrapped bubble, would result in the core being approximately two thirds uncovered before the op'erator would be directed to respond to the red path item.
In response to GL 88-17, Loss of Decay Heat Removal, the licensee implemented several administrative controls.
One of the controls consisted of the requirement to maintain two operable methods of monitoring vessel level; RCS standpipe and'VLIS.
Due to improper reactor vessel venting, the standpipe level was in error.
'he operators considered RVLIS to be unreliable at low RCS pressure,due to previous indication problems.
Both of the above concerns were identified as a weakness in Inspection Report 50-400/90-24.
The operations procedure for placing the reactor coolant system in mid-loop operation requires that at least one channel of, RVLIS be operational as an initial condition.
This procedural step is based on the licensees commitment to Generic Letter 88-17, which addresses the NRC's concern with the loss of RHR during mid-loop operations.
A RVLIS instrument error of 20 inches could have resulted in a loss of RHR during mid-loop operation due to vortexing caused by the lower than expected levels.
RVLIS indication is used for accident conditions and normal plant conditions to inform the control room operator of reactor vessel water level.
The apparent reactor level error noted during mid-loop operation indicates that reactor level errors could exist during accident conditions with detrimental effects.
In order for the reactor level indication to be accurate the reference leg of the RVLIS instruments must be properly filled. If'the RVLIS instruments are not accurate and are found to be outside their design accuracy they cannot be considered operational.
The failure to maintain an operational RVLIS channel as required by OP-111, section 8. 1. 1.3 is a
failure to follow procedure and is considered to be violation.
Violation (400/91-01-03):
Failure to properly fill the RVLIS reference leg.
One violation and no deviations were identifie.
Followup of Onsite Events ('93702)
At 3: 12 p.m.
on February 15 an unusual event was declared due to a loss of
. the main plant computer (ERFIS) for four continuous hours.
During maintenance on the computer room HVAC the
"A" data disc overheated and caused the shutdown of the ERFIS computer.
An alternate cooling method used previously failed to maintain the computer room temperature.
The normal ventilation system was returned to service and subsequently the computer was returned to service.
The unusual event was terminated at 9:10 p.m.
on February 15.
Exit Interview (30703)
The inspectors met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on February 22, 1991.
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 Violation, Non-cited Violation, and Inspector Follow-up item addressed below.
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.
Item Number Descri tion and Reference 400/91-01-01 400/90-01-'2 400/91-01-03 12.
Acronyms and Initialisms IFI:
Review licensee's progress to repair flanges and valves and minimize system leakage, paragraph 2.b.(4).
NC4:
Failure to periodically test two check valves in the control room HVAC system, paragraph 5.
YIO:
Failure to properly fill the RVLIS reference leg, paragraph 9.d.
AC ACR AFR ALARA AOP ASME BWR CCTV CFR CM CNS CRC Alternati ng Current Adverse Condition Report Auxiliary Feedwater As Low As Reasonably Achievable Abnormal Operating Procedure American Society of Mechanical Engineers Boiling Water Reactor Closed Circuit Television.
Code of Federal Regulations Corrective Maintenance Corporate Nuclear Safety Chemistry Radiochemistry
CS CSIP ECCS EDG EPT ERFIS ERG EST FCV FHB FHP FMP FSAR GL GP HVAC IFI IST LER LOCA MST NCR NCV NED NRC ONS OST PCR PLP PORV PPB PSIG QA/QC RCS/RC RHR RVLIS RWP RWST SER SI SOOR TS URI VIO WR/JO ation System tioning on System Report Containment Spray Charging/Safety Injection Emergency Core Cooling System Emergency Diesel Generator Engineering Performance Test Emergency Response Facility Inform Emergency Response Guideline Engineering.Surveillance Test Flow Control Valve Fuel Handling Building Fuel Handling Procedure Fuel Management Procedure Final Safety Analysis Report Generic Letter General Procedure Heating, Ventilation and Air Condi Inspector Follow-up Item Inservice Testing Licensee Event Report Loss of Coolant Accident Maintenance Surveillance Test Non-Conformance Report Non-Cited Violation Nuclear Engineering Department Nuclear Regulatory Commission Onsite Nuclear Safety Operations Surveillance Test Plant Change Request Plant Program Power Operated Relief Valve Parts per Billion Pounds per Square Inch Gauge Quality Assurance/Quality Control Reactor Coolant System Residual Heat Removal Reactor Vessel Level Instrumentati Radiation Work Permit Refueling Water Storage Tank Safety Evaluation Report Safety Injection Significant Operational Occurrence Technical Specification Unresolved Item Violation Work Request/Job Order