IR 05000400/1992011
| ML18010A677 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/30/1992 |
| From: | Crlenjak R, King L, Mellen L, Shackelford J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18010A676 | List: |
| References | |
| 50-400-92-11, NUDOCS 9207140088 | |
| Download: ML18010A677 (15) | |
Text
1PR REC0 (4
-:.,y Report No.:
UN ITE0 STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 50-400/92-11.
Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Licensee No.:
NPF-63 Facility Name:
Shearon Harris Inspection Conducted:
June 1 through June 4,
1992 Inspectors L.
ellen, T
Lpader
/
~z~7 ~
Date Signed hack ford, Rea or Inspector
.,King, Reactor spector Accompanying Personnel:
C.
Rapp, Reactor Inspector Date Signed
~ zS/r~
Date Signed Approved By:
R. Crlenjak, Chief Operational Progra s Section Division of Reactor Safety SUMMARY Scope:
This inspection was conducted in the area of engineering and technical support for operations, maintenance, outages, testing, and surveillances.
Results:
Based on the review of Engineering and Technical Support (ETS), the inspectors
'concluded:
ETS aggressively identifies and resolves emergent issues for both operations and maintenance.
9207140088 920630 PDR ADOCK 05000400 G
The ETS trending and tracking program is adequate, but could be more proactive.
System Engineers take ownership of their systems.
Their level, of knowledge of both system history and performance is commendable.
Very little system problem and performance history is preserved in a formal manner that would allow a new system engineer to take over rapidly for a system engineer that leaves.
ETS engineers adequately initiate actions based on emerging technical issues.
Occasionally they perform well beyond the minimum expected.
PRA/IPE or other related risk-based insights are not used for any substantive risk management, No violations or deviations were identifie REPORT DETAILS Persons Contacted Licensee Employees D.
H.
C.
B.
C.
J.
J.
- J W.
- J
- C B.
- C A.
- D B.
- T J.
- J C.
L.
- A.
R.
D.
H.
C.
M.
- G E.
- W.
- L R.
Alexander, Senior Engineer Avinger, System Engin'eer Bach, Senior Engineer Boisvert, Senior Engineer Brown, Manager, NSSS Burne, Senior Engineer Burns, ISI Engineer Collins, Manager, Operations Cooper, System Engineer Cribb, Hanager, guality Assurance Gibson, Manager, Programs and Procedures Hall, Senior Engineer Hinnant, General Manager, Harris Plant Klemp, Senior Specialist, Electrical Knepper, Manager, Site Engineering Heyer, Manager, Environmental and Radiation Monitoring Morton, Hanager, Maintenance Hoyer, Manager, Project Assessment Nevill, Manager, Technical Support Olexik, Manager, Regulatory Compliance Olson, Manager, EDBS/Spare Parts Powell, Manager,'arris Traini'ng Unit Rabold, Senior Engineer Rodden, Component Engineer Smith, Manager, Radwaste Operation Thomas, Senior Engineer Turner, Senior Engineer Vaughn, Vice President, Harris Nuclear Project Willett, Manager, Outages and Modifications Wilson, Manager, Spent Nuclear Fuel Woods, Manager, System Engineering Zulu, Manager, Engineering Support
.,Other licensee employees contacted included engineers, mechanics, technicians and office personnel.
NRC Representatives
- J. Shackelford, Inspector
- L. King, Inspector
- K. Rapp, Inspector
- L. Mellen, Inspector
- H. Shannon, Resident Inspector
- Attended exit interview Acronyms are listed in the last paragrap.,
Technical Support Work Activities A.
Control of Technical Support Activities.
The inspectors reviewed TMM-400, Test Results, Evaluation, Revision 4.
The inspectors discussed this procedure with the Technical and Engineering Support staff members responsible for performing the procedure's attachments, The. purpose section stated
"THH-400 details the actions to be performed by the designated Technical Support personnel to accomplish the evaluation of test results data generated by other plant procedures.
These evaluations are for the purpose of determining operability, compliance, and reportability."
None of the Technical and Engineering support staff members interviewed actually used this procedure for "the purpose of determining operability, compliance, and reportability."
The procedure's purpose section continued
"This procedure is intended to be used primarily for the evaluation of data from Maintenance and Operations Surveillance Tests, but may be used for evaluation of other tests as deemed necessary."
There were no procedural steps or attachments for performing "evaluation of other tests as deemed necessary."
The procedure appeared to serve the function oF a convenient location for two disjointed data gathering and evaluating attachments.
The procedure further states "It is the responsibility of other plant groups, such as Maintenance and Operations, to perform their tests and supply the appropriate Technical Support System Engineer with the required data to complete this procedure."
There are no clear procedural steps to implement this requirement and there are no procedural requirements for the dispatch of the data gathered by "other plant groups".
TMM-100, Technical Support Management Manual, Revision 4, states
"All Technical Support work shall be performed in accordance with the contents of this procedure and any procedure referenced by this procedure."
TMM-100 references TMH-109, System and Component Trending Program, Revision 3, which in turn references TMM-400.
The inspectors found no evidence that this cumbersome system had caused any inappropriate Technical Support actions.
However, the inspectors said that work should be accomplished according to procedures, and not despite them.
The licensee management said they would revise the procedures to inclOde appropriate instruction for data evaluation, and the procedure would be revised to include appropriate.instructions for determining operability, compliance, and reportability."
The systems engineers do not maintain formal systems notebooks which contain critical system data for their area of cognizance.
This type of formal record keeping would enh'ance predictive maintenance activities by maintaining trending data on selected system
parameters.
Additionally, such record keeping would also enhance the turnover process between systems engineers when it is desired to rotate personnel.
System Engineer Certification Although the system engineer certification process has been in place since January 1991 there are only nine certified system engineers.
This has left many plant systems without a certified system engineer.
Of the 201 identified systems only 17 have certified system engineers.
Eight additional systems have certified backup engineers, but do not have certified primary engineers.
The inspectors found no examples of a system that had both a certified primary'nd backup engineer.
There is little incentive or management
'emphasis on certifying as a system engineer, Although,the individual syste~ engineers have a very high knowledge level, a formal certification process or at least a
qualification journal would serve to standardize the performance expectations for the positions.
Additionally, the engineers who were interviewed indicated they had not received any specialized training related to their specifi'c positions.
Incorporation of some aspects of vendor recommended training would be a positive benefit.
Work Load The engineering department is adequately staffed to accomplish the workload.
The accessibility of a comprehensive computer system which has access to all equipment information, spare parts, and work orders reduces the amount of time necessary for engineers to provide maintenance planning with detailed information.
The engineers are provided with details of work planned for their system in advance of the scheduled work date.
This enables them to attend the plan of the day meetings and provide input where necessary.
Maintenance planning is also provided with enough information from the computer'o determine the requirements for post maintenance testing.
Trending The Engineering Support group provides technical as'sistance to maintenance and does trending analysis on non-IWP/IWV components.'he system engineers are required to trend system performance; however, the level of trending is dependent on the preference of the individual system engineer.
The trending program is effective in identifying potential problems.
The NPRDS reportable items are also sent to the system engineers to fill out the necessary data to report.
quarterly failure rate trends, based on the automated maintenance management system, are sent to systems and component engineers.
A quarterly report, entitled Component Failure Analysis Report (CFAR), covering an eighteen-month period is
distributed to systems engineers.
The CFAR report contains comparisons of the performance of standard component types at Harris.to similar components industry wide.
Configuration Management The Technical Support organization is heavily involved in the temporary modifications program at the facility, The on site Systems Engineering group maintains primary cognizance over all of the temporary modifications efforts at the unit.
The inspectors reviewed the implementing instructions which govern the Plant Change process as well as the documentation related to the temporary modifications which are installed at the site.
Additionally, several temporary modifications were reviewed in-depth to determine the adequacy and extent of the systems engineers'nvolvement in the temporary modifications process.
The licensee had 41 active temporary modifications and approximately one-half of these modifications were slated to be rolled over into permanent modifications.
The Systems engineering organization personnel were highly organized and efficient in the administration of the temporary modifications process.
The individual systems engineers are tasked with the'rimary responsibility for the planning and review of the temporary modifications which are associated with their systems.
All of the engineers which were interviewed were very knowledgeable concerning the specific details of the modifications associated with their area of responsibility.
Additionally, several of the modifications which were reviewed were noted to
'rovide tangible benefits to the operating organization.
In particular, PCR-3315, Containment Temperature Monitoring, was initiated to provide data to support equipment qualification concerns.
The modification involves the installation of RTDs at various locations throughout the containment to verify that local temperature conditions do not exceed technical specification limitations.
The data derived from this modification is being used to resolve operational considerations concerning equipment qualification considerations.
This particular modification is being rolled over into a permanent change in order to continue the monitoring program.
Several other modification packages were reviewed with the systems engineers, and in all cases the engineer involved was very knowledgeable with regards to the details associated with the modification, Additionally, the systems engineering personnel are tasked with the monthly verification of all administrative and material aspects of the temporary modifications which are associated with their area of responsibility.
The inspectors observed that the engineers had satisfactorily maintained their walkdown and audit responsibilities with regards to the temporary modification progra The inspectors concluded that the licensee had an adequate program to control the temporary modifications process.
Further, it was concluded that the Systems Engineering personnel were a primary contributing factor to the overall success of this particular program.
Technical Support Interface With Other Organizations The process by which the engineering and technical support organization interfaces with other site organizations was observed during the course of the inspection. It was determined that the ETS personnel had demonstrated very effective interdisciplinary communications in the conduct of its activities.
In particular, the temporary modifications process requires extensive contact with a variety of other plant and corporate organizations.
The implementation of temporary modifications at the Harris facility requires the initiation of the modification by the cognizant system engineer.
The engineer is then responsible for ensuring that the appropriate cross-disciplinary reviews are conducted.
Additionally, the actual field installation of the modification is overseen by the engineer which also requires extensive communications with other site organizations.
In the event that a
given temporary modification is determined to be implemented as a
permanent modification, then interfaces with the corporate engineering organization are also required.
In addition to the
'ommunications with other technical organizations, the ETS group also provides the necessary support to the licensing/compliance group in support of the LER process when applicable.
In those circumstances where a particular system or component which was under the cognizance of a system engineer was involved in a reportable event, the ETS organization was tasked with providing the appropriate input into the processing of the LER. This type of input ranges from the actual initiation of the LER:in situations of component failure to that of technical reviews in other situations.
The inspectors concluded that the ETS organization had implemented adequate communications with the appropriate organizations in the conduct of its activities.
Post-Haintenance Testing The inspectors reviewed the licensee's equipment database system, the automated-maintenance management system, and the supply inventory system.
These three systems allowed the licensee to access most information required by the maintenance planners for filling out work requests.
The planner.is also told by the system engineer what post-maintenance testing needs to be reviewed by the ISI engineering staff.
The maintenance planners determine the post-maintenance testing requirements when the WRM is initiated.
These requirements are identified based on a guide in, PLP-400.
This guide insures the design basis envelope of the system is maintained.
If the planner has questions about requirements, the system responsible engineer or Engineering Support is asked to
review the PHT requirements.
requirements if the component Support
- ISI then identifies procedures for the components Surveillance Observation (61726)
The planner also identifies ISI is in the ISI program.
Technical the procedures or portions of in programs administered by ISI.
The inspectors reviewed maintenance surveillance test HST-10055, Reactor Coolant Flow Instrument Calibration, to determine how the maintenance feedback reports were dispositioned.
The systems engineer feedback report was reviewed for adequacy of response and no problems were found.
There was no formal method used by the system engineer to determine that technical specification requirements were met.
The experience level of the systems engineers was relied upon to assure tha't an acceptable method was used. It was necessary for the inspectors to'obtain a copy of HNP-I/INST-1002, Reactor Coolant Loss of Flow Error Analysis, to determine that the method used was acceptable."
ISI reviews all test results from the testing of components in the IMP/IWV program.
This review is used to determine if increased surveillance testing is necessary under the ASHE Section XI criteria.
System engineers do not normally review ISI surveillance test results.
However, in the event of an ISI surveillance test failure, the system engineer is requested to review the test data.
Engineering Support could also be involved if a particular component fails repeatedly.
System engineers review the acceptance criteria to ensure the system or component will operate within 'the design basis.
Engineering does review surveillance procedure changes to ensure the procedure will adequately test the system or component.
Signoffs are provided on each change notice for Engineering to review for changes to testing requirements.
Emergent Technical Issues A.
Operational Events The Reactor/Performance Group trends daily plant operational data.
The system engineers are given a
CLOGAS report for secondary side performance.
This report contains minimum and maximum values for certain plant data points for the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />..
The CLOGAS database is only 180 points out of the 1600 point EFRSI database.
The information that can be derived from the HIN/HAX is very limited due to,the small number of data points in the CLOGAS database.
Hore secondary side points are available, however, the software is not able to accept any additional points.
Also, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting capability limits the engineers ability to perform real-time trending and trouble shooting.
The licensee has temporally installed a system called SHARTNET.
This instrumentation provides for more accurate indication of secondary side parameters such as feedwater temperature and flow.
This instrumentation is used by Operations for daily calorimetric
calculations.
However, the more accurate SHARTNET data is not available to the system engineers.
The licensee has recognized the limitations of SHARTNET and CLOGAS and is planning to upgrade secondary side performance monitoring.
A software package called PHAX will be installed on a standalone workstation.
This workstation will have access to all ERFIS database. points and provide real-time display of secondary and primary side database points.
Additionally, the SHARTNET instrumentation will be tied into the plant-wide computer network.
PRA/IPE Risk Hanagement The inspectors observed that selected system areas within the ETS organization have been tasked to review certain areas of the licensee's individual plant examination (IPE) submittal.
Several of the systems engineers who were interviewed were in the process of reviewing the draft systems notebooks from the upcoming IPE.
These reviews were intended to validate the technical adequacy and certain fundamental assumptions concerning system operation as analyzed by the study.
However, no actual reliability data from the PRA was being used in the daily conduct of ETS activities.
Although none of the engineers who were interviewed had received any formal training in the concepts of PRA technology, the inspectors found that positive benefits were being achieved by this type of review.
The ETS involvement in the development of the IPE should provide an added measure of content validity to the final PRA analysis and several technical issues had already been raised by the systems engineers during these reviews even though the process was still in a preliminary phase.
The inspectors viewed the ETS involvement in the IPE process as a positive initiative.
Outage Planning The inspectors examined the conduct of the ETS organization with respect to its involvement in the outage planning process.
The ETS organization was found to be actively involved in a number of activities which were related to outage related preparations.
The ETS organization had several systems engineers who were designated as the coordinator for various major outage activities including steam generator work and electrical bus outages.
The individuals who assumed these responsibilities were found to be knowledgeable and organized with respect to their specific responsibilities.
In addition to these designated coordinators, many other systems engineers are involved in other aspects of outage planning activities as related to the individual components associated with the systems under their cognizance.
The inspectors viewed the ETS involvement in the outage planning process to be a positive
benefit.
Exit Interview (30703)
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.
Dissenting comments were not received from the license Acronyms ACR CFR ECCS ERFIS
. FSAR FWH IFI LER NRC PCR RAB RCS RHR RWST TS WPB Adverse Condition Report Code of Federal Regulations Emergency Core Cooling System Emergency Response Facility Information Final Safety Analysis Report Feed Water Heater Inspector Followup Item Licensee Event Report Nuclear Regulatory Commission Plant Change Request Reactor Auxiliary Building Reactor Coolant System Residual Heat Removal Refueling Water Storage Tank Technical Specification Waste Processing Building