IR 05000400/1991026
| ML18010A510 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/06/1992 |
| From: | Christensen H, Shannon M, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18010A509 | List: |
| References | |
| 50-400-91-26, NUDOCS 9201270212 | |
| Download: ML18010A510 (16) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report No.:
50-400/91-26 Licensee:
Caro'lina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
Inspection Conducted:
November-16 - December 20, 1991 Inspectors:
~n-J.
e row, Sen>or. Resident Inspector License No.:
NPF-63 Date Signed Fc,g. M.
annon, Resident Inspector Date igned Approved by:
H.
rsstensen, ection se Division of Reactor Projects D te agne SUMMARY Scope:
This routine inspection was conducted by two resident inspectors in the areas of plant operations, radiological controls, security, fire protection, nonconformance reports, surveillance observation, maintenance observation, design changes and modifications, safety system walkdown, licensee event reports, onsite nuclear safety committee activities, 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:
A non-ci ted violation >>as identified regarding the failure to perform a
hydrostatic test on the CCW system, paragraph 5.
cy2Q127pg 12 p5pppqpp cy2Q1Q6 PDR ADOCK PDR
A new pipe/valve labeling program was initiated which enhances routine operations and maintenance activities, paragraph 2.b.(7).
Also, the licensee has implemented a
new program controlling infrequently performed 'tests or evolutions, paragraph 4.
Administrative controls established for radwaste operations to remove a
hose from a demineralizer filter were considered to be weak, par agraph 2.c.(2).
REPORT DETAILS 1.
Persons Contacted Licensee Employees
- P. Beane, Manager, (}uality Control J. Collins, Manager, Operations C. Gibson, Manager, Programs and Procedures C. Hinnant, General Manager, Harris Plant
- D. McCarthy, Manager, Site Engineering
- B. Neyer, Manager, Environmental and Radiation Monitoring T. Morton, Manager, Maintenance
- J. Nevill, Manager, Technical Support
- C. Olexik, Manager, Regulatory Compliance A. Powell, Manager, Harris Training Unit 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, operations, 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 I) 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 Supervisor'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.
The inspectors found the logs to be legible, well organized, and provided sufficient information on plant status and events.
Clearance tagouts were found to be properly implemented.
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 center.
. 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 accorda'nce with TS requi,rements 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.
(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 adequate.
(5)
Security Control -
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 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, 'mergency equipment, and fire barriers were operable.
(7)
Equipment Identification -
The inspectors noticed a
new pipe/valve labeling program initiative during general tours of the reactor auxiliary building and other facilities.
The licensee's program for plant component labeling was defined in plant procedure PLP-610, Equipment Identification and Numbering System.
This procedure was a'pproved by the Plant General Manager and was recently revised and implemented in August 1991.
The procedure defined requirements for color coding of safety-related system labels, label materials, attaching devices, acceptable numbering schemes and system
'abbreviations.
Procedure PLP-610 also allows for the installation of high visibility signs for those out-of-sight valves and directional flow labels for major piping and HVAC duct work.
The licensee has begun installation of high visibility and directional flow labels on systems such as CCW, ESW, ESCW, AFW, MS, and FP.
Plans are to include several waste processing systems in this effort as well.
The new piping labels'are vinyl strips with adhesive backing which include both the system designation and directional flow arrows.
Labels are uniform in size and are being used for pipe sizes ranging in diameter from 3 to 12 inches.
.System names are consistent with operating procedures and are color-coded (along with flow arrows)
in accordance with PLP-610 requirements for safety train, and non-safety color schemes.
Interviews with licensee personnel indicate that overall response to the new labeling program is favorable and routine operations and maintenance activities can only be enhanced by this piping identification system.
The inspectors found plant housekeeping and component material condition to be good.
The licensee's adherence to radiological controls, security controls, fire protection requirements, and TS requirements in these areas were satisfactory.
Review of Nonconformance Reports Adverse Condition Reports (ACRs)
were reviewed to verify the following:
TS were complied with, corrective actions as identified in the re'ports were accomplished or being pursued for completion,
Cl
generic items were identified and reported, and items were reported as required by the TS.
( 1)
.ACR 91-481 requested an engineering evaluation be performed to determine appropriate acceptance criteria for the testing of check valves in the high head safety injection flow path to the RCS.
This issue.
was identified by the licensee during a
safety review of a'hange to the test procedure.
Engineering evaluation PCR-5811, High'ead Safety Injection Check Valve Testing, concluded that the current test acceptance criteria should be revised to prove proper operation of the check valves due to a small margin allowed for system resistance changes.
A.
very narrow acceptance criteria band had been imposed on the changing/safety injection pumps to supply at least the minimum required flow to satisfy the safety analysis and limit maximum flow for pump runout considerations.
The safety analysis assumed that two pumps would supply flow through the safety injection branch lines to the RCS cold legs with the third branch line faulted.
This corresponded to a minimum required flow of 379 gpm through two branch lines.
The licensee's most-limiting preoperational test data indicated that approximately 389 gpm was available through two branch lines.
Since only a
gpm margin existed the evaluation concluded that no system resistance or degradation could be allowed and the test acceptance criteria should be based on the original start-up test results.
The licensee is therefore revising the test procedure acceptance criteria and plans to evaluate alternative methods to increase the margin for minimum pump flow.
The test procedure is scheduled to be performed during the next refueling outage in September 1992.
Due to this small margin, the inspector requested that the licensee evaluate the adequacy of the quarterly IST pump testing acceptance criteria as well.
Inspector Followup Item (400/91-26-01):
Follow the licensee's activities to increase the charging pump flow margin and evaluation of quarterly pump testing acceptance criteria.
(2)
ACR 91-534 reported the contamination of three individuals during the process of removing a
hose from a demineralizer filter.
On November 9,
1991, a radwaste operator, with health physics support, had finished loading demineralizer resin and subsequently performed a
leak test on the associated hose connections.
One connection was found to be leaking.
The hose was depressurized and following shift turnover, the hose was disconnected to replace an "0"-ring.
The replacement of the
"0"-ring was considered to be within the skill of the operator'erforming the task and therefore a procedure was not utilized.
Upon disconnection the hose blew off spraying contaminated water on the three individuals.
The licensee's investigation into this event concluded that following depressurization, isolation valves leaked by allowing the hose to become repressurize Although procedure steps were followed, the investigation concluded that these steps should be improved to prevent recurrence of this type of event.
The inspector considered the licensee's administrative controls for this process to be weak.
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:
MST-I0143 Steam Generator A Narrow Range Level Loop Operability Test MST-I0268, Low-Low Average Temperature P-12 Interlock (T-0412)
Operational. Test MST-10269 Low-Low Average Temperature P-12 Interlock (T-0422)
Operational Test OST-1039 Calculation of quadrant Power Tilt Ratio, Weekly Interval OST-1086 1B-SB Diesel Generator Operability Test OST-1107 ECCS Flow Path and Piping Filled Verification Monthly Interval OST-1216 Component Cooling Water System Operability (1A-SA and 1B-SB Pumps In Service) quarterly Interval EST-810T Temporary Procedure for Crane Chempump Pressure Test The performance of these procedures was found to be satisfactory with proper use of calibrated test equipment, necessary communications established, notification/authorization of control room personnel, and knowledgeable personnel performed the tasks.
A good pre-test brief was observed for the emergency diesel test.
No violations or deviations were identified.
4.
Maintenance Observation (62703)
The inspector observed/reviewed maintenance activities to verify that'orrect 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 followe Maintenance was observed and work packages were reviewed for the following maintenance (WR/JO) activities:
Install gags on air operated containment isolation valves 1AF-64 and lAF-81 in accordance with PCR-6146.
Inspect/replace intensifier for valves 1AF-81 and lAF-64 in accordance with procedures MPT-I0002, Ralph A. Hiller Model 125A-A029 Valve Actuator, and CN-I0001, Removal and Reinstallation of Safety Related and Seismically gualified Instruments, and post maintenance testing in accordance with procedure OST-1077, Auxiliary Feedwater Valves Operability Test quarterly Interval.
Troubleshoot/repair failed pressurizer pressure transmitter PT-'455 in accordance with procedure NST-I0119, Pressurizer Pressure P-0455.
Troubleshoot/repair failed low head safety injection/RHR flow transmitter FT-605B in accordance with procedure MST-I0079, Residual Heat Exchange B Bypass Flow.
Troubleshoot/replace power supply card for steam generator level transmitter LT-495 in accordance with procedure NST-10030, Steam Generator C Harrow Range Level (L-0495) Calibration.
Adjust packing on air operated containment isolation valve 1AF-102 in accordance with procedure MMM-017, Valve Packing Reference Guide.
Troubleshoot/replace drifted high pressure switches for lube oil on
"B" condensate booster pump.
Torque body jam nut for service air pressure regulating valve on essential services chilled water expansion tank.
Good supervisory involvement and technical support was evident during the auxiliary feedwater valve work'.
The performance of work was satisfactory with proper documentation of removed components and independent verification of the reinstallation.
The pressurizer pressure transmitter repairs were completed on the Thanksgiving holiday during which senior
.management involvement was observed.
The licensee has recently implemented procedure PLP-100, Conduct of Infrequently Performed Tests or Evolutions.
This procedure/program implemented industry recommendations to help prevent actions which could cause unnecessary plant transients or which could place the plant into a condition prohibited by the TS.
Guidance on the conduct and substance of pre-job briefings, training, and procedures to be utilized, was included.
The inspectors observed implementation of this program during pre-job briefings for many of the work activities listed above.
The additional communication and clarification of the work activity which occurred during these briefings was considered beneficial and enhanced the safe operation of the plant.
No violatiens or deviations were identifie f Design Changes and Modifications (37828)
Installation of new or modified systems were reviewed to ve'rify that the changes were reviewed and 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'nd facility procedures were revised as necessary.
This review included selected observations of modifications and/or testing in progress.
The following modifications/design changes were reviewed:
- PCR-5748, Component Cooling Water Thermal Relief Valve Deletion
- PCR-6146, Preheater Bypass Valve Gagging Device On November 22, 1991, during a review of the post modification testing requirements associated with PCR-5748, the inspector noted that an inservice leak inspection at normal system operating pressure (approximately 90 psig)
was substituted for a hydrostatic test.
The modification removed the CCW relief valve associated with the outlet from the
"B" RHR heat exchanger.
In its place, a bypass line around the heat exchanger outlet isolation valve was installed which included a flow orifice, check valve and isolation valve.
This line consisted of one inch diameter piping and was welded back into the CCW header through a two inch reducer.
The inspector checked the requirements of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code to determine appropriate testing requirements for the newly installed piping.
Although one inch piping was found to be exempt from hydrostatic test requirements, the inspector found that Articles IWA-5000 and IWD-5000, System Pressure Tests, required a hydro'static test be performed at a pressure of at least 1. 10 times the system design pressure (150 psig)
for the two inch reducer weld.
The inspector informed licensee personnel of this discrepancy; the required hydrostatic test was conducted with satisfactory results on November 22.
Since an inservice leak inspection is suitable if a hydrostatic test cannot be performed, the safety significance of this finding was considered to be minor.
This NRC identified violation is not being cited because criteria specified in Section V.A of the NRC Enforcement Policy were satisfied.
NCV (400/91-26-02):
Failure to perform hydrostatic testing on CCW piping following relief valve replacement.
Safety Systems Walkdown (71710)
The inspector conducted a
walkdown of the component cooling water system to verify that the lineup was in accordance with license
requirements
- for system operability and that the system drawing and procedure correctly reflected "as-built" plant conditions.
Additionally, an instrument calibration history was reviewed to verify that.all
'instrument calibrations were current.
Finally, the inspector reviewed a'
open and closed maintenance history for, the system to verify that the licensee had identified deficiencies, entered them into the maintenance request system, and took 'appropriate corrective actions.
No violations or deviations were identified.
Review of Licensee Event Reports (92700)
The following LERs were re'viewed for potential generic impact, to detect trends, and to determine whether corrective actions were appropriate.
Even'ts 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 91-19:
This LER reported an unplanned automatic isolation of the containment ventilation system.
The licensee is presently
investigating this event to identify the most probable cause for an inadvertent spike which occurred on a radiation monitor.
The LER will remain open pending completion of. the investigation and resultant corrective action.
Review of Plant Nuclear Safety Committee Activities (40500)
The inspectors attended selected PNSC meetings to observe committee activities and verify TS requirements with respect to committee composition, duties, and responsibilities.
Minutes from these meetings were also reviewed to verify accurate documentation.
The inspector considered the conduct and documentation of these meetings to be satisfactory.
During the December 6,
1991, PNSC meeting an internal justification for continued operation (JCO 91-003) for the "A" containment hydrogen analyzer was discussed.
The "A" hydrogen analyzer had been declared inoperable due to a
sample isolation valve which indicated closed instead of open.
A check of the analyzer's low flow alarm revealed. that it was functioning properly.
A test was performed which confirmed that the sample isolation valve could be opened enough to allow sufficient sample flow even though the valve indication was not correct.
The analyzer was therefore considered to be operable.
Licensee Action on Previously Identified Inspection Findings (92702
92701)
a.
(Closed) Violation 400/91-01-03:
Failure to properly fill the RVLIS reference le The inspector reviewed and verified completion of the corrective actions listed in the licensee's res'ponse letter dated April 3, 1991.
The licensee has completed procedure changes which require draining the RVLIS reactor head sensor when disconnected for mid-loop operation and for filling the reference leg during RCS fill and vent.
Also, a
plant modification, PCR-5599, Reactor Head Vent Valve Replacement, was installed to provide for proper venting of the reactor vessel during draindown and refilling evolutions.
b.
(Closed)
Violation 400/91-04-03:
Failure to maintain two reactor protection system'CP under frequency trip devices operable.
The inspector reviewed and verified completion of the corrective actions listed in the licensee's letter dated April 26, 1991.
The licensee has labeled appropriate breaker cubicles identifying those breakers with umbilical cords and has revised plant procedures and clearance forms for proper verification of umbilical cord connections.
c.
(Closed)
Violation 400/91-09-01:
Failure to properly establish/implement plant procedures.
The inspector reviewed and verified completion of the corrective actions listed in the licensee's response letter dated June 24, 1991.
The licensee has counseled plant personnel and has revised applicable procedures to prevent recurrence of these events.
d.
(Closed)
IFI 400/91-23-01:
Review the licensee's program for control of material stored in the spent fuel pools.
The licensee has performed the first inventory of material stored in the spent fuel pools and has completed evaluations for chemical suitability of the stored material and potential.radiological hazards.
The evaluations produced acceptable results and the inventory identified that approximately 18 items needed to be tagged.
All items were subsequently tagged by licensee personnel.
Based on the results of the evaluations and inventory, the licensee's administrative controls appear to be appropriate and necessary.
10.
Exit Interview (30703)
The inspectors met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on December 20, 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 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 inspectio Item Number 400/91-26-01 Descri tion and Reference
'I IFI - Follow the licensee's activities to increase the charging pump flow margin and evaluation of quarterly pump testing acceptance criteria, paragraph 2.c.(I).
NCV - Failure to perform hydrostatic testing on CCW
'piping following relief valve replacem'ent, pa'ragraph 5.
'
Acronyms and Initialisms ACR AFW ASME CCW CFR CM ECCS ESCW EST ESW FP gpm HVAC IFI IST JCO LER MMM MPT MS MST NCV NRC OST PCR PLP PNSC PSIG RCP RCS/RC RHR RVLIS TS WR/JO Adverse Condition Report Auxiliary Feedwater American Society of Mechanical Engineers Component Cooling Water Code of Federal Regulations Corrective Maintenance Emergency Core Cooling System Essential Services Chilled Water Engineering Surveillance Test Emergency Service Water Fire Protection gallons per minute Heating, Ventilation and Air Conditioning Inspector Follow-up Item Inservice Testing Justification for Continued Operation Licensee Event Report Maintenance Management Manual Maintenance Performance Test Main Steam Maintenance Surveillance Test Non-Cited Violation Nuclear Regulatory Commission Operations Surveillance Test Plant Change Request Plant Program Procedure Plant Nuclear Safety Committee Pounds per Square Inch Gage Reactor Coolant Pump Reactor Coolant System Residual Heat Removal Reactor'essel Level Indicating System Technical Specification Work Request/Job Order