IR 05000400/1993019
| ML18011A207 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/01/1993 |
| From: | Christensen H, Darrell Roberts, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18011A206 | List: |
| References | |
| 50-400-93-19, NUDOCS 9310130129 | |
| Download: ML18011A207 (18) | |
Text
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+~*yW UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 30323.0199 Report No.:
50-400/93-19 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
Inspection Conducted:
August 21 - September 17, 1993 Inspectors:
J.
Tedrow, Senior Reside nsp tor Licensee No;:
NPF-63 ate Signed D.
Ro erts, esident Inspe r
Approved by:
H. Christensen, Chief Reactor Projects Section 1A Division of Reactor Projects Da e Si ned
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f3 Da e S gned 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 and modifications, 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:
No violations or deviations were identified.
One unresolved item was identified involving the operability of the.
containment vacuum relief system during testing of the E-6B emergency exhaust fan on August 22, 1993.
A weakness was identified in the development of Plant Change Request PCR-6895 which did not identify the effects that testing the emergency exhaust fans would have on the containment vacuum relief system, paragraph 5.
A poor fire-watch practice was observed which indicated a need for enhanced training in that area, paragraph 2.b.(6).
9310130129 931001 PDR ADOCK 05000400
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Good maintenance effort was noted for repairing containment purge isolation valve 1CP-3 following a failed local leak rate test on penetration M-58, paragraph e
REPORT DETAILS Persons Contacted Licensee Employees D. Batton, Manager, Work Control H. Casanova, Manager, guality Check
- J. Collins, Manager, Training
- C.. Gibson, Hanager, Programs and Procedures
- M. Hamby, Hanager, Corrective Action Program/Operating Experience T. Lee, Onsite guality Check Representative
- D. HcCarthy, Manager, Regulatory Affairs T.,Horton, Manager, Haintenance J. Moyer, Manager, Site Assessment W. Robinson, General Manager, Harris Plant W. Seyler, Hanager, Project Management H. Smith, Manager, Radwaste Operation D. Tibbitts, Hanager,-Operations B. White, Manager, Environmental and Radiation Control L. Woods, Manager, Technical Support H. Worth, Manager, Onsite Engineering Other licensee employees contacted included office, operations, engineering, maintenance, chemistry/radiation and corporate personnel.
Nuclear Regulatory Commission
- H. Christensen, Chief, Projects Section 1A, Division of Reactor Projects
- R. Prevatte, Senior Resident Inspector, Brunswick Nuclear Plant
- W. Stansberry, Security Inspector, Division of Radiation Safety and Safeguards
"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.
Shift Logs and Facility Records The inspectors 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; grounding device log; temporary
modification log; chemistry daily reports; shift turnover checklist; and selected radwaste logs.
In, addition, the inspector independently verified clearance order tagouts.
The inspectors found the logs to be readable, well organized, and provided sufficient information on plant status and events.
Clearance tagouts were found to be properly implemented.
No violations or deviations were identified.
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)
Honitoring 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 inspectors observed shift tur novers 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 inspectors noted that the material condition of components in the valve pit area adjacent to the motor driven fire pump had improved since June 1993 (see Inspection Report 50-400/93-12).
I
(4)
(6)
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.
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.
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.
On September 14, 1993, during a tour of the 236'levation of the RAB, the inspector noticed a security guard standing outside the
"C" CSIP room holding the door open and peaking into the room.
The inspector approached the security guard and asked what he was looking for.
The guard replied that he was performing his hourly fire watch duty for that room.
The inspector noted that the "C" CSIP and any potential fire hazards associated with it were obstructed from the guard's view by a concrete wall which split the room.
When asked as to how one could successfully perform a fire-watch from where he was standing, the guard indicated that he would be able to identify a fire hazard by smelling the air coming from the room.
He then volunteered that he was generally apprehensive about entering the CSIP rooms because of perceived radiological hazards associated with the operating pumps.
The inspector led the guard into the room and explained that the only posted contaminated area was the pump and.its foundation.
The inspector then explained that the room itself was merely posted as a radiation area and that there were no significant radiological hazards associated with walking into the room and performing a
visual check for fire hazards.
Fire Protection Procedure
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FPP-005, Duties of a Fire Watch, requires that fire-watch personnel inspect the area of the required fire watch for visible signs of fire (smoke, heat, or flames)
and that they
verify nothing has been added to the area that could cause a
fire to start.
As discussed in NRC Inspection Report 50-400/93-07, the licensee recently transferred fire-watch responsibilities to the security guard force from plant services personnel.
A review of training records and fire safety inspection logs during that inspection indicated that the transition had been appropriately implemented.
However, the above incident indicated a need for expanded training in the area of performing fire safety inspections in rooms involving potential radiological hazards.
The inspector related this concern to licensee management.
Upon further investigation of the above incident, the inspector discovered that the "C" CSIP room had been incorrectly posted as requiring an hourly fire-watch.
Therefore, the safety significance of this finding was minimal.
The inspectors found plant housekeeping and material condition of components to be satisfactory.
The licensee's adherence to radiological controls, security controls, fire protection requirements, and TS requirements in these areas was satisfactory.
Review of Nonconformance Reports Adverse Condition Reports were reviewed to verify that TS were complied with, corrective actions and generic items were identified and items were reported as required by I0 CFR 50.73.
No violations or deviations were identified.
Review of Emergency Operating Procedures In response to an industry event at another Westinghouse facility, the inspector reviewed the licensee's design for the high head safety injection system and Emergency Operating Procedures covering manual actions during the transfer to hot or cold leg recirculation following a large-break LOCA. It had been identified at another facility that, during such a transfer, the loss of one of two running high head safety injection pumps could create a runout condition for the remaining pump.
This condition was complicated by the fact that the other plant's EOPs did not contain steps to prevent the remaining pump from being simultaneously aligned to the RCS hot and cold legs.
Westinghouse identified that the Shearon Harris plant could potentially be affected by a similar EOP procedural deficiency.
The inspectors interviewed operations personnel and reviewed end-path procedures EOP-EPP-10, Transfer To Cold Leg Recirculation, and EOP-EPP-Oll, Transfer Between Cold Leg and Hot Leg Recirculation.
Operations personnel demonstrated on the control board and with the end-path procedures that, through a combination of valve and pump manipulations, no sing')e CSIP would be feeding
two headers or parallel RCS flowpaths during a post-LOCA transfer to hot or cold leg recirculation.
Therefore, the Shearon Harris plant is not susceptible to the same post-.LOCA recovery procedure inadequacy as the other Westinghouse facility.
No violations or deviations were identified.
e.
Review of Required Notices to Workers (71707)
The inspectors checked the licensee's official bulletin boards to verify that all required notices to workers were appropriately posted in accordance with 10 CFR 19.11.
The licensee maintained five official bulletin boards located at various conspicuous places through'out the plant to display the required information.
Designation of the bulletin board locations and information to be exhibited was specified in administrative procedure AP-002, Plant Conduct of Operations.
Specifically, this procedure required NRC Form 3, Notice to Employees, to be posted and the locations specified where the regul'ations of 10 CFR 19 and
CFR 20, license and license conditions, and plant operating procedures could be viewed.
A recently revised NRC Form 3, dated June 1993, was issued in July.
The inspector verified that the revised NRC form and all other required notices, including a recent Notice of Violation pertaining to radiological conditions at the plant, were posted.
No violations or deviations were identified.
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-I0130 Main Steam Line Pressure, Loop 2 (P-0486) Operational Test MST-I0147 MST-I0148 OST-1013 Steam Generator B Narrow Range Level Loop (L-0485)
Operational Test Steam Generator 8 Narrow Range Level Loop (L-0486)
Operational Test 1A-SA Emergency Diesel Generator Operability Test Monthly Interval
OST-1190 Spent Fuel Pool Cooling System Train B IST Testing quarterly Interval EST-220 Type C LLRT of Containment Purge Exhaust Penetration (H-58)
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 having performed the tasks.
No violations or deviations were observed.
Haintenance Observation (62703)
The inspectors observed/reviewed maintenance activities to verify that correct equipment clearances were in effect; work requests and fire prevention wor k permits were issued and TS requirements were being followed.
Haintenance was observed and work packages were reviewed for the following maintenance activities:
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Replace the closing spring charging motor cutoff limit swi tch for the "B" containment spray pump circuit breaker.
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Troubleshoot failure of the "B" containment hydrogen analyzer and retest in accordance with procedure HST-I0116, Containment Hydrogen Analyzer System Calibration, Train A or Train B.
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Replace hydrogen sensor for the "A" containment hydrogen analyzer in accordance with procedure HPT-I0117, Replacement of Hydrogen Analyzers Environmentally gualified Components, and modification PCR-6413.
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Inspect and repair containment purge exhaust valve seat on 1CP-3 following failure of penetration H-58 local leak rate test.
The inspectors noted an overall good maintenance effort on valve 1CP-3 following a failed local leak rate test.
On September 9,
1993, containment purge exhaust penetration H-58, failed a quarterly Type C
LLRT when licensee personnel could not pressurize the penetration to 44 psi as required by Technical Specification 4.6. 1.7.2 and surveillance test procedure EST-220.
The failure to pressurize the penetration created the inability to ascertain if the requirements of T.S. 3.6. 1. 1, Containment Integrity (i.e., overall local leak rate
< 0.60 La), were being met.
This situation placed the plant in a one hour LCO and subsequently a six hour action statement to either restore containment integrity or be in Hot Standby.
Plant experience with previous LLRT failures of this penetration (which is isolated by two 8-inch and two 42-inch butterfly valves)
allowed the licensee to be well-prepared for this challenge by immediately focusing in on the valve seat for valve 1CP-3 (8-inch outboard isolation valve)
as the cause of the failure.
The 8-inch valves on the purge inlet and exhaust lines are routinely cycled for purge operations prior to personnel containment entries and
are more likely to experience seat leakage than the 42-inch valves on those penetrations.
The licensee was prepared to repair the seat on 1CP-3 by having preplanned work tickets availabl.e (for all four penetration isolation valves) before the surveillance test commenced, and a new valve seat ready for installation if needed.
After the EST-220 failure, inspections were also conducted on the inboard valve (inside containment)
to verify that no other leak sources existed.
The valve seat was successfully replaced on valve 1CP-3, penetration H-58 was tested satisfactorily, and the six hour action statement was exited with hours to spare.
The performance of work was satisfactory with proper documentation of removed components and independent verification of the reinstallation.
No violations or deviations were identified.
Design Changes and Hodifications (37828)
Installation of new or modified systems were reviewed to verify 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 approved 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.
The following modifications/design changes were reviewed:
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PCR-6413 Hydrogen Analyzer Software Upgrade
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PCR-6875 Containment Vacuum Relief Actuation Setpoint
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PCR-5307 RHR/LHSI to RWST Isolation The containment vacuum relief modification was installed to restore the system to a normal configuration following the problems discussed in NRC Inspection Report 50-400/93-08.
The modification involved relocating the instrument sensing lines to measure the differential pressure between containment and the outside atmosphere and also to restore the actuation setpoint back to the original value of -2.5 INWG.
The modification was completed on August 20, 1993.
It allowed the differential pressure between containment and the outside atmosphere to be detected by connecting tubing from the reference legs on pressure differential transmitters (PDTs) in the CVRS to existing reference legs on PDTs in the RAB emergency exhaust system.
On August 22, during a
monthly surveillance test of the RAB emergency exhaust fan E-6B, operators opened a drain valve common'to the reference legs on both the emergency exhaust system and the CVRS.
This action (required by surveillance procedure OST-1049, RAB Emergency Exhaust System Train "B" Operability) would ensure proper air flow through the emergency exhaust,
'rain by forcing open a vortex damper in that system.
The test was run for a required 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the drain valve open before the E-6B fan was declared operable.
'On September 4, operators discovered that
opening the common drain valve on August 22 could have rendered the CVRS inoperable because it potentially allowed the vacuum relief reference leg sensor to sense RAB pressure rather than outside atmospheric pressure.
Shearon Harris Technical Specification 3.6.5, Containment Vacuum Relief System, requires that with one train of the CVRS inoperable for four hours, the plant must be in a hot standby condition within the next six hours.
Since licensee personnel were unaware of the potential vacuum relief system inoperability during the E-6B surveillance run, no attempts were made to take actions as required by the Technical Specifications.
Failure to place the plant in hot standby under those circumstances would constitute a Technical Specification violation if it were concluded that the CVRS was inoperable during the 10 hour-long E-6B test.
Licensee personnel documented the above situation in ACR 93-326.
Subsequently, an engineering analysis was performed to determine whether or not the CVRS was actually sensing RAB pressure.
As a preliminary precaution, procedures OST-1049 and OST-1032, RAB Emergency Exhaust System Train "A" Operability, were revised to incorporate new testing methods which would allow the common reference leg drain valve to remain closed during future E-6 fan tests.
On September 15, 1993, a successful 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> test was performed on emergency exhaust fan E-6A using the revised
"A" train procedure.
That test did not challenge the operability of the CVRS.
The inspectors considered the development of PCR-6875 to be weak in this area because the observed effects that testing the E-6 fans would have on the CVRS were not identified by the PCR process prior to the CVRS being returned to operation.
By the end of the inspection period, the licensee had not provided the resident inspectors with the results of the engineering analysis addressing CVRS operability during the August 22, 1993 test.
While the emergency exhaust surveillance test procedures have been revised to prevent the above incident from recurring, the question of whether or not a Technical Specification violation occurred on August 22, 1993, remains open pending receipt and review of the licensee's analysis.
Unresolved Item (400/93-19-01):
Review analysis regarding the operability of the containment vacuum relief system during E-6B test.
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 0 (Closed)
LER 93-02:
This LER reported the failure of air handler unit AH-92A.
This matter was previously discussed in NRC Inspection Report 50-400/93-10.
The licensee developed a new checklist for maintenance on the fan units and has analyzed the
b.
C.
bearing failure; The inspector reviewed the checklist and metallurgical analysis of the failed components.
The licensee concluded that the use of damaged parts for replacement was the most likely cause for this event.
(Closed)
LER 93-03:
This LER reported a containment vacuum relief system design deficiency.
This matter was previously discussed in NRC Inspection Report 50-400/93-08.
The licensee has subsequently issued a supplement to the LER dated August 25, 1993.
Modification PCR-6875 has been installed by the licensee to reroute the sensing lines for the differential pressure transmitter.
The inspectors reviewed the modification package and observed portions of the modification installation.
(Closed)
LER 93-05:
This LER reported an entry into TS 3.0.3 during an in-service stroke test of two CSIP discharge cross-connect valves.
This event was previously discussed in NRC Inspection Report 50-400/93-12.
Licensee action to address this issue included counseling of personnel, training on the proper use of engineering evaluations and justifications for continued operation, and a review of the use of technical support memorandums.
The inspector reviewed the implementation of these
,
corrective actions and considered it satisfactory.
The licensee continues to maintain the "B" CSIP out of service until a full flow test can be performed.
d.
(Closed)
LER 93-06:
This LER reported the failure of the automatic sampling device on the Secondary Waste Sample Tank (SWST) effluent line.
This matter was previously discussed in NRC Inspection Report 50-400/93-12.
The licensee replaced the sampling device with a modified version to ensure adequate voltage surge protection is available in the future.
Additionally, the Secondary Waste system procedure, CRC-260 was revised to include new testing and calibration methods for installed composite sampling units. *The inspectors reviewed the associated work package and'he revised procedure and considered them satisfactory.
Licensee Action on Previously Identified Inspection Findings (92702
92701)
(Closed) Violation 400/93-12-01:
Failure to maintain the IRVH bridge hoist electrical containment penetration conductor overcurrent protective device operable.
The inspector reviewed and verified completion of the corrective actions listed in,the licensee's response letter dated July 30, 1993.
Both the primary and secondary breakers were tested satisfactory.
The secondary breaker was subsequently wired into the circuit.
The licensee completed an investigation of other 480 volt breakers and for 6.9 KV and 120/208 volt penetration breakers for similar conditions.
This evaluation discovered minor deficiencies in the electrical penetration list
document PLP-106 and also found that three breakers were not included in the testing procedure for periodic testing.
The licensee's actions to correct the identified deficiencies were considered satisfactory.
As the omission of the three breakers from the testing procedure did not result in a violation of the ten percent sample surveillance requirement of TS 4.8.4. l.a, the inspector had no further questions.
L Exit Inter view (30703)
The inspectors met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on September 17, 1993.
'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 Unresolved 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.
No dissenting comments from the licensee were received.
Item Number 400/93-19-01 Descri tion and Reference Unresolved Item:
Review analysis regarding the operability of the containment vacuum relief system during E-6B test, paragraph 5.
Acronyms and Initial i sms ACR CFR CSIP CVRS EOP EPP INWG IRVH IST KV LCO LER
'HSI LLRT LOCA MPT MST NRC OST PCR PDT PLP PSI RAB RCS/RC-Adverse Condition Report Code of Federal Regulations Charging Safety Injection Pump Containment Vacuum Relief System Emergency Operating Procedures Emergency Plans and Procedures Inches Water Gage Integrated Reactor Vessel Head Inservice Testing Kilovolt Limiting Condition for Operation Licensee Event Report Low Head Safety Injection Local Leak Rate Test Loss of Coolant Accident Maintenance Performance Test Maintenance Surveillance Test Nuclear Regulatory Commission Operations Surveillance Test Plant Change Request Pressure Differential Transmitters Plant Program Procedure Pounds per Square Inch Reactor Auxiliary Building Reactor Coolant System
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RHR RWST SWST TS URI Residual Heat Removal Refueling Water Storage Tank Secondary Waste Sample Tank Technical Specification Unresolved Item