IR 05000400/1993024
| ML18011A277 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/14/1994 |
| From: | Christensen H, Darrell Roberts, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18011A275 | List: |
| References | |
| 50-400-93-24, NUDOCS 9401250135 | |
| Download: ML18011A277 (14) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATlANTA,GEORGIA 30323-0199 Report No.:
50-400/93-24 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
Inspection Conduct d:
November 20 - December 17, 1993 Inspectors:
. Tedrow, enior Resident Inspector
.
Rob esident Inspector Approved by:
. Christensen, Chief Reactor Projects Section lA Division of Reactor Projects Licensee No.:
NPF-63 te igned
) IV~<
D te igned l /tH Date Signed 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, 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 deviation was identified:
Failure to request NRC extension for implementing corrective actions associated with NRC Violation 400/93-12-02, paragraph 6.a.
A weakness was identified during the performance of chemistry sampling procedure CRC-255, Waste Gas Decay Tank Sampling, paragraph 2.c.(7).
9401250135 940114 PDR ADOCK 05000400
Another example of poor housekeeping was observed regarding oil and dirty rags in the "A" CSIP room, paragraph 2.c.(3).
Cold weather protection activities were found to be satisfactory, paragraph 5.
Good training effort observed at plant simulator for operators in preparation for planned downpower evolution, paragraph REPORT DETAILS I.
Persons Contacted Licensee Employees
- D. Batton, Manager, Work Control
- B; Christiansen, Maintenance Manager J. Collins, Manager, Training M. Hamby, Manager, Regulatory Compliance
- D. McCarthy, Manager, Regulatory Affairs J.
Moyer, Manager, Site Assessment
- R. Prunty, Manager, Licensing W. Robinson, Vice President, Harris Nuclear Project
- W. Seyler, Manager, Project Management H. Smith, Manager, Radwaste Operation
- D. Tibbitts, Manager, Operations
- B. White, Manager, Environmental and 'Radiation Control
- L. Woods, Manager, Technic'al Support H. Worth, Manager, Onsite Engineering L
Other licensee employees contacted included office, operations, engineering, maintenance, chemistry/radiation and corporate personnel.
"Attended exit interview 2.
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 I) for the duration of this inspection period.
a 0 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; 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 identifie Operator Training The. inspector observed several training scenarios conducted on the plant simulator for one of the operating shifts to be involved in, an upcoming downpower ev'olution.
Training scenarios included plant transients which involved the failure of the "A" feedwater regulating valve while the plant was being maneuvered to 20 percent power.
The licensee's use of the simulator in this manner helped prepare operators for any unwanted plant transients associated with the valve's failure.
The inspector considered the licensee's effort to be good.
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 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.
During a tour of the reactor auxiliary building, the inspector noted oil dripping from tubing connected to the speed increaser on the "A" charging/safety injection pum The inspector also observed an oily rag lying at the foot of the speed increaser on the pump baseplate.
The main control room was notified about the leaking speed increaser.
An operator was dispatched who initiated a work ticket to have the. potential leak fixed.
Operators later verified that preventative maintenance had been performed the previous day on the coupling between the speed increaser and the pump.
'he mechanics may have over-lubricated the coupling.
During its operation, the coupling would sling the excess grease onto the coupling cover until enough accumulated to drip to the pump baseplate.
Inspector Followup Item 400/93-07-01 was previously generated and remains open pending the licensee's resolution of similar problems dealing with the accumulation of oil on the air exhaust screens for the charging pump motors.
Regarding both the oily rag and the oil on the baseplate, the inspector informed the licensee that these were continuing examples of declining housekeeping that was recently addressed in Inspection Report 400/93-22.
When informed, licensee personnel promptly cleaned up the "A" CSIP area.
Further management attention in the area of housekeeping is needed.
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 bar rier 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,'mergency equipment, and fire barriers were operable.
Sampling Program - The inspector observed activities associated with a gaseous effluent release for Waste Gas
Decay Tank "A" on November 30, 1993.
Activities observed included both the pre-release sampling required by Technical Specification 3. 11.2, and performance of radwaste operating procedure, OP-120.07, Radwaste Processing, which accomplished releasing the contents of Waste Gas Decay Tank
"A" to a vent stack.
The inspector verified that the release was performed in accordance with the associated release permit and that release information and projected dose calculations were available on the permit.
The permit identified the isotopic source of the release, the amount of radioactivity projected to be released, and the volume of the gaseous effluent to be discharged.
The inspector considered this portion of the evolution to be satisfactory.
In contrast, the inspector observed weak licensee performance during sampling evolutions that occurred prior to the tank's contents being released.
The inspector observed licensee performance of procedure CRC-255, Waste Gas Decay Tank Sampling.
This procedure accomplished taking a noble gas grab sample (Section 10.2)
and a tritium sample (Section 10.3),
both of which would be analyzed later in the chemistry lab.
Section 10. 1 of the procedure allowed for sample set-up and sample line purge.
Licensee personnel who would perform the task indicated during a pre-job discussion with the NRC inspector that Section 10.3 (tritium sample)
would be done prior to Section 10.2 (gas sample).
The inspector observed licensee personnel successfully complete the sample line purge in accordance with section 10.1.
Licensee personnel then proceeded to take a tritium sample.
However, while the technician performing the sample line valve manipulations understood he was drawing a tritium sample, the technician holding the procedure began reading off the steps in Section 10.2 for taking a noble gas sample.
The NRC inspector questioned which sect'ion of the procedure the technicians intended to perform.
The procedure holder realized his error and proceeded to section 10.3 to continue taking the tritium sample.
Later, the inspector noted that
'he last performance of a tritium sample per this procedure was in October 1992, and that a pre-job briefing for this infrequent evolution had not been performed.
During the same evolution, while attempting to collect the tritium sample, technicians manipulated several sample and purge isolation valves as required by CRC-255.
However, after performing step 6 of Section 10.3, the sampling media (demineralized water)
appeared to be drawn out of the gas sampling vessel and into the gas decay tank sampling lines.
This was. an unexpected occurrence since the sample lines were to remain dry while gas sample flow was being established to the sample media.
Technicians backed out of the procedure, performed another sample line purge per Section 10. 1, and again attempt to collect a tritium sample
per Section 10.3.
Performance of step 6 on the second attempt'ielded the same unexpected results.
The inspector and the technicians discussed the possibility that the procedure was not clearly written and that the multiple actions contained in step 6 would have,to be performed out of order to accomplish collecting a successful tritium sample.
The technicians backed out of the procedure until resolution was acquired from the procedure's author, after which the tritium sample was successfully completed.
While the above anomalies did not result in any adverse conditions, it was evident that there existed some confusion'ith regard to performing this infrequent evolution.
Procedure CRC-255 and other chemistry procedures are exempted from the requirements of plant procedure PLP-100, Conduct of Infrequently Performed Tests of Evolutions, which contains criteria for performing pre-job briefings.
The inspector concluded that a clearer procedure and the performance of a pre-job briefing were needed.
With the exception of the areas discussed above, the inspectors found plant material condition to be
, satisfactory.
The licensee's adherence to radiological controls, security controls, fire protection requirements, and TS requirements in these areas was satisfactory.
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:
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HST-I0045 Calibration of Nuclear Instrumentation System Power Range N42
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HST-I0153 Reactor Coolant Flow Instrument (F-0415) Operational Test
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HST-I0380 Waste Processing Building Stack 5A Accident Honitor RH-*IWV-3547-1 Operational Test EST-220 Type C Local Leak Rate Test 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 observe 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 were issued and TS requirements were being followed.
Maintenance was observed and work packages were reviewed for the following maintenance a'ctivities:
Remove, clean and replace lA emergency diesel engine right bank rear intake manifold constant vent cover.
Retorque in accordance with procedure HHM-010, Threaded Fastener Tightening Procedure.
Remove and rebuild 3-way pilot valve in the lA diesel engine right bank fuel oil drip leg vent.
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Replace grease on lA CSIP speed increaser couplings to motor and pump in accordance with procedure HPT-H0059, Charging/Safety Injection Pump Nonmetallic Component Replacement and Lubrication.
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Clean and inspect lA RHR pump motor in accordance with HPT-E0004, Environmentally gualified 480 VAC Motor Electrical Inspection.
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Replace closing coil in lA RHR pump breaker.
Retest in accordance with PM-E0012, Section 7. 13, 480 VAC Load Center Breaker and Cubicle Preventative Maintenance.
Bridge and megger lA CSIP motor.
Rework stripped bolt holes on 1A CSIP termination cover box in accordance with PCR-4909.
The performance of work was satisfactory with proper documentation of removed components and independent verification of the reinstallation; No violations or deviations were identified.
Cold Weather Preparations (71714)
The inspector reviewed the licensee's program for protecting safety-related systems and systems important to safety against extreme cold weather conditions.
The licensee's actions -for cold weather protection were primarily controlled under Administrative Procedure AP-301, Adverse Weather Operations.
Section 5.1 of this procedure contained guidance for operators to verify operability of freeze protection panels and that other systems were functioning properly.
Operators entered this procedure on several occasions when ambient temperatures dropped below 35 degrees F.
While operating under AP-301, operators used specific rounds guidance which listed check points for the heat trace, panels most important to continued safe operation of the plant.
The inspector observed that operators were following this guidance to identify potential deficiencies in heat trace panels and that the deficiencies were being entered into the work control syste The inspector reviewed the maintenance backlog associated with heat trace and temperature maintenance systems and identified over one hundred open work tickets which affected approximately twenty-five heat trace panel's.
Several circuits on the panels were identified as having low amperage readings.
Other panels were identified as having ground faults.
Work requests were dated as far back as 1990 and some were not scheduled to be worked until after the cold weather season ended in 1994.
This backlog had not decreased since this area was last inspected in Parch 1993.
Additionally, the inspector observed that between 14 and 18 of the 36 annunciators associated with heat trace problems were lit in the radwaste control room.
While the annunciators and open work tickets were primarily associated with heat trace systems that did not affect safety systems, the inspectors considered that more attention could be given to these deficiencies prior to the onset of the cold weather months.
The inspector noted that a couple of heat trace system PCRs were under implementation which would improve the reliability of heat trace systems and associated dr awings.
Plant change request PCR-6666 will incorporate as-built data for heat trace circuits from construction installation
'ards into the heat trace drawings.
Currently, heat trace drawings reflect inaccurate cable lengths that were based on dimensions pulled from isometric drawings of the pipes on which the heat trace circuits were installed.
The PCR-6666 as-built project will eventually correct approximately 340 heat tracing drawings.
Another PCR that has been implemented recently for several heat trace panels, PCR-3106, has relocated their temperature sensing thermostats so that they can more accurately detect ambient weather conditions and automatically energize circuits below 35 degrees F.
Other preparations for the upcoming cold weather season included the erecting of tents over the instrument air compressors and associated equipment.
Semi-permanent heaters were installed in each of the tents to keep the instrument air system warm.
The inspector concluded that safety-related systems were adequately protected from adverse weather conditions.
Licensee Action on Previously Identified Inspection Findings (92702
92701)
(Open) Violation'00/93-12-02:
Failure to properly implement plant procedures as required by TS 6.8. l.a.,
paragraphs 2.c.(3)
and 6.
The inspector reviewed corrective actions listed in the licensee's response letter dated July 30, 1993.
The licensee documented in the letter that the corrective actions for the violation associated with racking in the 6.9 KV breaker would be complete by October 1,
1993.
Corrective actions included revising procedures to incorporate an inspection of mechanism operating cell alignment after racking in 6.9 KV breakers.
Another action included placing
.visual aids, or placards, inside the breaker cubicles to indicate
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'
b.
the location for conducting the alignment verification.
The inspector noted that the procedure for racking in 6.9 KV breakers had been rev'ised by the commitment date.
Work tickets had been generated to install the placards in some'of the breaker cubicles'.
These work tickets were still open and weren't scheduled to be completed until the next refueling outage in Parch, 1994.
The licensee arrived at this decision because of the risks associated with installing the placards in 6.9 KV breaker cubicles while the plant was at power.
The inspector considered the time extension for implementing the corrective action to be appropriate and in the interest of plant and personnel safety.
However, the inspector considered the licensees actions in deferring implementation beyond the committed date without requesting an extension from the NRC to be improper.
Although the safety significance is minor, the inspector considered the deferral of corrective actions beyond the October 1,
1993 due date is a
deviation from a written commitmeht specified in the licensee's July 30, 1993 letter.
Deviation (400/93-24-01):
Failure to request NRC extension for corrective actions committed to in July 30, 1993 response to NOV.
(Closed)
Inspector Followup Item 400/93-14-02:
Follow licensee's action to develop checks of LK-16 circuit breaker closing coils.
The inspectors verified that preventative maintenance procedure PH-E0012 had been revised to incorporate visual checks of LK-16 breaker closing coils as well as resistance checks using an ohmmeter.
The inspectors considered this action adequate to close the inspector followup item.
Exit Interview (30703)
The inspectors met with licensee representatives,(denoted in paragraph 1) at the conclusion of the inspection on December 20, 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 Deviation 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 Descri tion and Reference 400/93-24-01 Deviation:
Failure to request NRC permission to extend implementation date for corrective actions committed to in July 30, 1993 response to NO Acronyms and Initial i sms CFR CSIP EST IFI KV NOV NRC OST PCR RHR TS VAC VIO Code of Federal Regulations Charging/Safety Injection Pump Engineering Surveillance Test Inspector Follow-up Item Kilovolt Notice of Violation Nuclear Regulatory Commission Operations Surveillance Test Plant Change Request Residual Heat Removal System Technical Specification Volts Alternating Current Violation