IR 05000400/1994003

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Insp Rept 50-400/94-03 on 940110-14.No Violations Noted. Major Areas Inspected:Design Changes & Plant Mod,Engineering & Technical Support Activities
ML18011A308
Person / Time
Site: Harris 
Issue date: 02/10/1994
From: Casto C, Matt Thomas, Whitener H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18011A307 List:
References
50-400-94-03, 50-400-94-3, NUDOCS 9402230108
Download: ML18011A308 (19)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 30323.0199 Docket Nos.:

50-400 facility Name:

Harris

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Report Nos.:

50-400/94-03 Licensee:

Carolina Power and Light Company P. 0.

Box 1551 Raleigh, NC 27602 License Nos.:

NPF-63 Inspection Conducted:

Inspector:

H. Thomas-January 10-14, 1994 Date Signed Accompanying Inspectors:

H. Whitener G.

Wiseman

/

Approved by:

. Casto, Chief Test Programs Section Engineering Branch Division of Reactor Safety Date Signed SUMMARY Scope:

This routine, announced inspection was conducted in the areas of design changes and plant modifications, engineering and technical support activities, and followup on previously identified inspection findings.

Results:

In the areas inspected, violations or deviations were not identified.

One inspector followup item was identified to review the licensee's corrective actions for adverse condition feedback report (ACFR)93-560 concerning the renewal of temporary modifications installed greater than 90 days.

The licensee has implemented a process for reviewing, prioritizing, and scheduling plant modifications that addresses nuclear safety.

In general, plant change requests (PCR) reviewed were technically adequate with sufficiently detailed safety evaluations.

The PCRs were implemented in accordance with licensee 'requirements.

However, some PCRs lacked detailed justifications.

9POPP30108 S'ooo400 PDR ADOCK

The licensee recently initiated a Project guality Team to address Nuclear. Generation Group configuration management issues.

Licensee management has implemented initiatives'o reduce the backlog of items for selected areas.

The various engineering groups provide adequate and timely support to the plant for day-to-day activities and emergent issues.

In general, the Nuclear Assessment Department (NAD) assessments and most of the various engineering groups'elf assessments were effective in identifying areas for improvement in engineering and technical support.

However, some Nuclear Engineering Department self assessments lacked detail in indicating whether corrective actions were being taken to address the observations and recommendations,

REPORT DETAILS Persons Contacted Licensee Employees e

  • D. Batton, Manager, Work Control
  • B. Christiansen, Manager, Haintenance
  • A. Cockerill, Manager, Electrical/IKC Unit, Harris Engineering Support Section (HESS)
  • J. Collins, Manager, Training
  • J. Dority, Manager, Maintenance Programs
  • C. Gibson, Manager, Programs and Procedures
  • W. Habermeyer, Vice President, Nuclear Services Department/Acting NAD
  • W. Helms, Project Engineer, HESS
  • D. HcCarthy, Manager, Regulatory Affairs
  • V. McKay, Manager, Engineering/Technical Support Assessment, Harris Project Assessment Section (HPAS)
  • J. Nevill, Manager, Projects
  • R. Prunty, Manager, Licensing
  • L. Rowell, Project Engineer, Licensing
  • W. Seyler, Manager, Project Management
  • W. Slover, Manager, Mechanical Unit, HESS V. Stephenson, Manager, Civil Unit, HESS
  • W. Szuba, Manager, Modification Management

"D. Tibbitts, Manager, Operations R.

Van Metre, Acting Manager, HESS, Nuclear Engineering Department

  • H. Wallace, Senior Specialist, Regulatory Affairs
  • B. White, Manager, Environmental and Radiological Control
  • A. Williams, Manager, Shift Operations
  • L. Woods, Manager, Technical Support
  • A. Worth, Manager, Plant Project/Program, HESS
  • R. Zula, Manager, Component Engineering Other licensee employees contacted during this inspection included engineers, operators, gA personnel, craftsmen, and administrative personnel.

NRC Resident Inspectors

  • D. Roberts, Resident Inspector J.

Tedrow, Senior Resident Inspector

  • Attended exit meeting Acronyms and initialisms used throughout this report are listed in the last paragrap Design Changes and Plant Modifications (37700)

'a ~

Plant Modifications to Improve Reactor Safety The inspectors reviewed the initiatives taken by the licensee to identify and implement plant modifications to improve reactor safety and plant operation.

Plant modification packages were prepared by the Nuclear Engineering Department (NED) located both onsite and offsite at corporate headquarters.

Design changes that led to modifications were primarily requested and processed through the plant Technical Support Department located onsite.

The licensee had a corporate program that addressed modificat'ions for all three CPKL nuclear sites.

The modification manual provided complete and detailed instructions for plant modifications.

Several site specific plant change requests (PCR)

were reviewed by the'nspectors to determine the adequacy of the modification process.

The modification and design control procedures reviewed were:

AP-600 AP-612 Plant Change Request Initiation Plant Review Group HAP-001 Outage Management and Modifications Section, Conduct of Operations MAP-005 Nuclear Plant Modification Program (NPHP)

Hodifications MOD-103 Engineering Evaluations MOD-204 NGGH 305-08 PLP-627 Modification Implementation Plant Modification Screening and Selection Nuclear Plant Prioritization Program The Nuclear Plant Prioritization Process (NPPP)

was the process used for identifying, screening, evaluating, and approving emergent work.

This was also the process by which PCRs were initiated and approved.

All identified problems were screened by Technical Support System Engineering utilizing NGGH 305-08 criteria for technical merit to determine if the problem required a modification solution.

If a modification is required, Technical Support System Engineering recommended the PCR for.further evaluation by the Plant Review Group (PRG).

The PRG was a project management group comprised of primary Unit Managers established to evaluate major plant modification requests and make recommendations to the appropriate authorization level for development, deferral or cancellation of the reques Prioritization under the NPPP review and approval process involved cost benefit analysis, assignment of schedule index for implementation activities based on six areas that included nuclear safety, industrial safety, unit availability and reliability, unit capacity, radiation exposure (ALARA), and plant enhancement to improve operation. or maintenance.

The inspectors reviewed selected PCRs identified in the PRG meeting minutes of November 4,

and 15, 1993, to verify that they were prioritized and categorized in accordance with AP-612.

The inspectors noted that 145 PCRs scheduled for 1994 implementation were reviewed by the PRG during this period.

The PCRs were prioritized and categorized by the PRG according to the nuclear safety significance of the plant change.

At the time of this inspection,'53 PCRs reviewed remained for implementation in 1994, 42 were re-dispositioned for future review or deferred and 50 were voided/cancelled.

The inspectors reviewed voided PCRs 999, 4621 and 5575 to determine if the basis for cancellation was acceptable.

PCR 4621 contained an adequate description of the basis for cancellation.

The description of the bases and technical justifications for cancellation of PCRs 999 and 5575 lacked adequate detail.

However, based on a review of these design change packages, the inspectors concluded that cancellation of these PCRs did not adversely affect plant reliability or safety.

Based on discussions with licensee engineering personnel, and review of the above documentation, the inspectors concluded that the licensee has an adequate prioritization and review process for identifying and implementing plant design changes in a

sat'isfactory manner.

However, documented justifications for previously cancelled PCRs by the PRG lacked detail.

Planning, Development, and Implementation of Plant Modifications The inspectors reviewed the PCRs listed below to: (1) determine the adequacy of the safety evaluation screenings and the

CFR 50.59 safety evaluations; (2) verify that the modifications were reviewed and approved in accordance with TS and applicable administrative controls; (3) verify the modifications were installed and had proper signoffs; (4) verify that applicable design bases were included and design documents (drawings, plant procedures, FSAR, TS, etc.)

were revised; (5) verify that the modifications were properly turned over to operations; (6) verify that both installation testing and post modification test requirements were specified and that adequate testing was performed.

The following plant modifications were examined:

PCR 516, Motor Speed Changes on Emergency Diesel Generator (EDG) Building Ventilation Fans

PCR 5475, Setpoint Changes of Low Level Alarms for EDG Fuel Oil Day Tank PCR 5519, Install a Local Level Gauge for EDG Jacket Cooling Water PCR 5588, Fire Dampers and Relocation of Duct Modification PCR 6140, CSIP Oil Hist Problem PCR 6403, Change MOV 1CT-26 Closure Control from Limit Switch to Torque Switch to-Achieve Leak Tight Valve Seal PCR 6655, Add Automatic Drain Air Traps and Filters on EDG Starting Air Dryer The inspectors'eview of the above PCR packages indicated that the modification packages were complete, contained a work instruction package, contained additional information such as the design basis, and required that Category A (operator/control room significant) drawings be revised before turnover to operations.

The inspectors also verified that affected FSAR drawings, tables and figures had been updated to accurately reflect the modifications.

The inspectors identified no significant findings for the modifications reviewed and concluded the documentation of the modifications packages was satisfactory.

The inspectors noted however, that PCR NO. 6140 had not been fully effective to achieve the desired result of preventing oil intrusion into the charging pump electric motor, This item is discussed further in paragraph 5.b. of this report.

Temporary Modifications The inspectors reviewed the licensee's temporary modification (TH)

process to determine its adequacy for controlling and tracking temporary changes to the plant's configuration.

THs are prepared by the system engineers within the Technical Support Unit.

Modification Procedure MOD-206, "Temporary Modifications,"

provides requirements and controls for the installation and removal of THs.

The requirements listed previously in paragraph 2.b.

above for permanent modifications were also applicable to THs and were reviewed accordingly.

The THs were examined to verify that:

(1) adequate safety evaluations and technical reviews were performed; (2) testing was specified and performed where applicable; and (3)

THs installed greater than 90 days were reviewed and renewed 'in accordance with HOD-206.

The following THs were reviewed:

PCR 5121, Cooling Tower Makeup Hi Hi Screen Trip PCR 6465, ESCWS Chiller 1B-SB Differential Pressure Switch Troubleshooting

PCR 6659, Eme'rgency Diesel Generator 1A-SA 46X Trip

'nnunciator Circuit PCR 6736, Plugging of Solenoid Operated Equalization Valves The inspectors noted one discrepancy during review of the above THs.

PCR 6736 was installed in January 1993 and was renewed in April 1993; The next renewal date was scheduled for July 1993.

However, the TH was not renewed until October 1993.

Renewal of

, the TH (PCR 6736) in April 1993, and again in October 1993, resulted in one 90 day renewal not being performed; This was not in accordance with procedure HOD-206.

The inspectors reviewed this item further and found that adverse condition and feedback report (ACFR)93-560 was written in December 1993 to identify an instance where the 90 day renewal was not performed for a different TM (PCR 6927) that was installed.

This ACFR was still open and the corrective a'ctions had not been completed at the conclusion of this inspection.

Licensee personnel indicated that the missed renewal date for TH PCR 6736 will be reviewed and addressed in the corrective actions for ACFR 93-560.

The inspectors will review the licensee's corrective actions for ACFR 93-560 during a future inspection; This item will be tracked as Inspector Followup Item 50-400/94-03-01, Corrective Actions for ACFR 93-560 Concerning Temporary Modification Renewals not Being Performed.

The inspectors concluded that, except for the discrepancy discussed above, the licensee'.s process for the installation, control, and removal of temporary modifications was considered adequate.

Drawing Control The inspectors reviewed the licensee's program and procedures that were developed and implemented to maintain drawing control.

The program and procedures were examined to ensure that design control was maintained and drawings were updated in a timely manner to reflect the as-built plant.

The procedures and systems reviewed for drawing control included the following:

'ED Procedure 3041,

"SHNPP Drawing Maintenance,"

Revision 0, dated August 26, 1993.

  • Plant Programs Procedure PLP-601,

"Plant Configuration Control Program," Revision 5, dated April 28, 1992.

  • Plant Operation Manual RMP-002,

"Document Control and Distributi'on," Revision 1, dated July 5, 1990.

The licensee had recently initiated a

NED Project guality Team to address configuration management issues identified by the Configuration Hanagement Task Force.

The Team had chartered a

plan to establish and implement a Configuration Management Program for CP&L's Nuclear Generation Group.

However, due to the recent-initiation of this program the inspectors could not evaluate the performance effectiveness at this time.

The NRC will re-evaluate the effectiveness of management oversight and configuration control during a future inspection.-

The inspectors concluded that the NED drawing control program for Harris plant was adequate.

The licensee had recently initiated a

Project guality Team to address Nuclear Generation Group configuration management issues.

The inspectors could not evaluate the performance effectiveness of these activities at this time.

This will be reviewed during a future NRC inspection.

Within this area no violations or deviations were =identified.

Engineering and Technical Support Activities

'a ~

Organization and Staffing Engineering and technical support were provided by both onsite and corporate organizations.

Onsite technical support was provided mainly by the Technical Support Unit (which include's the system engineers),

and the Component Engineering and Maintenance Programs Subunits within the Maintenance Unit.

Corporate and onsite support were provided by the Nuclear Engineering Department's (NED)

HESS.

The inspectors held discussions with licensee personnel and reviewed documentation of selected plant activities to evaluate the engineering involvement and support of day-to-day plant operations.

This support included equipment performance trending, preparing PCRs for permanent and temporary installation, responding to ACFRs, performing safety evaluations, failure analysis, etc.

The inspectors reviewed staffing levels resulting from the recent reorganization.

There were major reductions in the number of contractor engineering personnel and there were also efforts to reduce the number of permanent staff as the workload 'decreases.

Licensee personnel indicated that, although there will be some instances during peak workload when contractor personnel will be used to supplement the HESS staff, their goal is to develop the engineering experience and expertise in-house and reduce the reliance on contractor support.

This goal was further emphasized in the resources budgeted to provide technical training for engineering personnel in 1994.

The amount budgeted for training in 1994 was nearly twice the amount for 1993.

The inspectors determined that the current staffing levels within the various engineering groups appear adequate to provide support to the plan Technical Support Unit The inspectors reviewed the duties and responsibilities of the Technical Support Unit personnel as described in the Technical Support Management Manual (THH) procedure THM-100, "Technical Support Conduct of Operations,"

dated July 29, 1993.

The'nspectors noted that the Harris Nuclear Project underwent a

reorganization in August 1993 that changed some of the duties and responsibilities previously assigned to the Technical Support Unit.

One of the changes involved moving the Component Engineering Subunit from Technical Support to the Maintenance Unit.

Component Engineering activities are discussed in greater detail in paragraph 3.e. of this report.

Procedure TMM-100 was in the process of being revised to reflect the changes in organization and responsibilities.

The inspectors focused primarily on the responsibilities of the system engineers within Technical Support.

The system engineers perform system walkdowns in accordance with procedure THH-117,

"System Engineer Walkdown Procedure," for their assigned systems.

The walkdowns are performed to observe the material condition of the systems and to document any problems found.

The system engineers also perform operability evaluations, surveillance and periodic tests assigned to Technical Support, trend selected system parameters, review ACFRs, review test results and procedure changes for adequacy, review work requests and post maintenance test requirements for assigned systems on a daily basis, and prepare temporary modifications.

Temporary modifications are discussed in greater detail in paragraph 2.b. of this report.

Technical Support Unit management indicated that a procedure was being developed to provide better guidance for performing and documenting operability evaluations.

The inspectors held discussions with selected system engineers and found that the system engineers were technically knowledgeable of their assigned systems were actively involved in the open issues applicable to their systems.

Harris Engineering Support Section The inspectors reviewed selected activities performed by the HESS and HESS's interface with the Projects Subunit at the site in the PCR process.

Some of these activities are discussed in paragraph 2.b. of this report.

Other activities reviewed included the following:

En ineerin PCR Backlo The inspectors reviewed exception report summary data and trending plots of exceptions to turned over PCRs (File HS-932910 dated December 17, 1993) to determine if plant modifications were maintained at manageable levels and processed in a timely manne Sixty-three PCRs remained active pending the closure of 93 PCR

'xceptions.

Forty-four of these active PCRs had only one open exception.

There were

PCRs that had been active awaiting closeout for longer than 6 months.

Hanagement's implementation of the identification and tracking process for open PCRs "and backlog exception items was adequate.

The management expectation was to eliminate the 6 month backlog by Harch 1994.

I En ineerin Drawin and Calculation Backlo The inspectors reviewed NED Harris Engineering Support Section information summary data and trending plots of engineering backlogs

{dated January 11, 1994) to determine if engineering backlog workloads are maintained at manageable levels.

CP&L Corporate Improvement Initiative CII-11, backlog reduction goal is 0 for calculations and drawings to be accomplished by December 1994.

The total number of NED backlog items in 1993 has shown a

reduction during this year.

In January 1993, the number of backlog items'was about 1,837.

As of December 1993, with contractor assistance the number had reached about 709 (446 calculations and 243 lower Category 8 and C drawings),

The current rate of backlog reduction was acceptable.

Problem Identification and Resolution The inspectors reviewed a sample of ACFRs to evaluate engineering involvement in plant problems.

ACFRs are one method of identifying plant problems for engineering review to determine operability 'and problem resolution.

The inspectors reviewed the following ACFRs to evaluate the adequacy of the operability assessments and problem resolutions:

ACFR No.

Problem Sub'ect 93-18 Overheated and burned-open heat trace cable for boric=acid line.

93-56 93-230 Procedure PIC-E026 does not allow a tested circuit to be de-energized causing potential exposure to a live circuit.

Plant scaffolding may not be qualified by seismic evaluation.93-560 Renewals for Temporary Hodifications were not performed.

The inspectors.concluded that, in general, operability assessments and engineering responses to ACFRs were adequate with reasonably detailed,and descriptive evaluations, The corrective actions for

ACFR 93-560 had not been completed.

This item was identified as an IFI for further review and is discussed in greater detail in paragraph 2.b. of this report.

e.

Component Engineering In the recent reorganization Component Engineering was moved from Technical Support to the Maintenance Unit where in conjunction with the Maintenance Programs Support group, component engineers perform a large number of tasks to support maintenance and plant operation.

The inspectors reviewed the duties and functions of the Component Engineering and Maintenance Program Support groups as described in MMM-001, "Maintenance Conduct of Operations,"

which was in the process of revision to reflect the reorganization.

These groups provide support to maintenance and system engineering on component problems, perform engineering evaluations, develop load release for rigging, support maintenance in use of freeze plugs, provide bolt torquing requirements, identify new PMs, coordinate MOV program, perform root cause failure analysis, evaluate transmitter drift problems, coordinate on-line leak repairs, provide outage support, resolve feedback reports on equipment, develop and revise maintenance procedures, review technical information for effect on maintenance procedures, manage the repetitive failure program, perform diagnostic test and analysis including.the vibration, oil sample and thermography analysis program, and other maintenance oriented functions.

The inspectors held discussions with selected engineers and found that they were technically knowledgeable in their assigned areas and were actively involved in support of day-to-day plant operations and maintenance.

Examples of involvement examined by the inspector included plant support and problem resolution by vibration analysis, oil sample analysis and the repetitive failure programs.

Violations or deviations were not identified in the areas inspected.

guality Assurance (gA) Assessment and Oversight The inspectors reviewed assessments performed by the HPAS and NAD of the HESS, NED, and various site engineering safety related activities.

The assessments were part of the overall CPKL quality assurance program at Harris.

The inspectors reviewed results of the following quality assurance activities that were either completed or in progress:

The Nuclear Assessment Department (NAD) has the responsibility to assess plant performance and provide management the oversight needed in pursuit of quality performance.

The NAD conducts performance based assessments of corporate and all CP&L plants in various safety related areas on a

scheduled, periodic basis.

The findings from these assessments are generally categorized as strengths, issues and weaknesses (i.e.,

items for management consideration).

To evaluate NAD performance the

inspectors discussed the self assessment program with Harris NAD personnel and reviewed NAD assessment reports, procedures and schedules.

Documents reviewed in this inspection included but was not limited to.

the following:

ASHT-02, Revision 0, Assessment Process NGGN 405.08, Response to NAD Identified Issues C-NED-93-01, Nuclear Engineering Department Assessment H-ISI-92-01, In-Service Inspection Assessment H-QC-93-01, Quality Control Assessment H-SP-93-04, Outage Preparation Assessment H-Out-92-01, Outage Assessment H-'CA-92-02, Harris Corrective Action Program Assessment H-CA-93-01, Harris Corrective Action Program Assessment The inspectors concluded that NAD has identified plant performance deficiencies of reasonable significance and was useful in providing a

performance oversight to management.

The following statements from NAD assessment reports are examples which characterize the nature of NAD findings:

Lack of adequate procedural guidance for administering a safety related program.

Procedures contain unclear or confusing instructions.

Failure to follow procedures/failure to correct procedures.

Lack of communication of management expectations.

Use of non-approved subprograms which do not capture the requirements of the corrective action program, Post maintenance test requirements program did not ensure adequate post maintenance modification testing in RFO 84.

Feedback process and corrective action program were not effective in preventing repeat problem occurrences.

Reliability of the "A" EDG was challenged by excessive equipment failures and personnel errors.

Proper radiological, radiation, contamination and contaminated area controls were not applied in some instances.

Industrial safety practices were not aggressively pursued.

In addition.to the general oversight assessments, NAD also performed self assessments of the NAD organization.

These self assessments were actually performed by an external, independent organization.

The most

recent assessment was performed August 2,to September 3,

1993.

The assessment covered corporate and all CP&L sites.

In this assessment one issue, two weaknesses and seven strengths were identified.

The issue pertained to followup of assessment issues that were identified as not always timely and thorough.

In response to the assessment findings NAD management specified the corrective actions to resolve the problems in a

letter to senior management on October 13, 1993.

The corrective action involved a review of identified issues/weaknesses to verify accuracy, thorough documentation, and scheduled followup.

The overall finding from the independent audit was that NAD was meeting its commitments and providing useful performance information for management oversight, The inspectors also reviewed self assessment activities performed by the various engineering groups.

Most engineering groups had recently begun performing self assessments.

Licensee personnel indicated that a plant procedure was currently being developed to address self assessment activities.

The inspectors reviewed several NED Engineering Program self-assessments ("Interfaces with Other Organizations" (NED-H-5802, August 9, 1993), "Modification guality" (NED-H-5792, July 21, 1993),

and "Conduct of Design Engineering" (NED-G-8231, May 4, 1993).

The inspectors also reviewed. the self assessment of the Component Engineering subunit.

This group had approached the self evaluation process in a unique way, Rather than across the board monitoring of activities, this group had identified functional areas that are potential performance problems and conducted an indepth review of the functional area, The inspectors reviewed the results of the licensee's.

reviews of vendor manuals and prev'entive maintenance (PM) procedures.

Vendor manuals were updated with the latest information, and out of date information purged.

Areas where the plant conforms to vendor recommendations were identified.

Those areas where the plant does not conform to the vendors'ecommendations were identified and the basis and justification for the deviations were incorporated into the manuals.

The group has also reviewed the PM program.

About 18,000 PMs were

'eviewed, considering vendor recommendations, feedback from the crafts, and maintenance history, to identify the PMs necessary for reliable plant operation and reduce maintenance cost where practical.

The review addressed frequency, outage based or on-line, content, possible combination or elimination, and the need for new PMs.

The inspectors concluded that Component Engineering self evaluation was effective in increasing the efficiency and reliability of maintenance and reducing maintenance costs.

Based on these reviews, the inspectors concluded that, in general, the self assessments were effective in identifying areas for improvement.

However, the inspectors noted that there was no documentation that indicated whether corrective actions were being implemented to address the observations and recommendations identified in some of the NAD assessments of HESS and some of the HESS self assessments.

Violations or deviations were not identified in the areas inspecte Licensee Actions on Previous Inspection Findings (92701)

(Closed)

Inspector Followup Item 50-400/92-21-01, concerning the condition that no formal program requirement existed for documenting the review and closeout of items identified as weaknesses in assessment reports.

Some weaknesses identified in assessment reports were of a significance which merited a formal closeout.

The licensee revised procedure 100-03,

"Assessment Process,"

to require that NAD track, schedule, re-assess and formally closeout identified weaknesses in an assessment report.

Procedure 100-03 was subsequently replaced by procedure ASMT-02, Revision 0,

"Assessment Process,"

which contains these same requirements and also requires that the effectiveness of corrective action be evaluated.

b.

During the review of NAD assessment reports, the inspectors observed examples of the formal documentation of the closeout of previously identified weaknesses in assessment reports H-CA-93-01, H-SP-93-04, and C-NED-93-01.

The inspectors concluded that a

formal closeout process has been implemented by NAD, (OPEN) IFI 50-400/93-07-01, Follow the Licensee's Activities to Prevent Oil Intrusion Into Charging Pump Motors or Establish a

Periodic Motor Cleaning Schedule:

In 1992 modification PCR-6140 was implemented to stop one source of oil leakage.

This modification added new air breathers to the speed increaser vents.

This was intended to entrap any oil droplets and direct them back to the oil sump.

From NRC resident inspector's observations, the modification failed to achieve the desired design intent.

During this inspection, the NRC inspectors discussed with the licensee engineers the potential adverse affects for the continued presence of an oil film in the electric motor windings, such as the fire hazards, environmental qualification problems, and general housekeeping.

The licensee indicated that the previous modifications were only about

percent effective in entrapping the oil droplets.

The licensee is presently evaluating three new proposed changes to solve the oil intrusion problem.

These included replacement of the oil filters with filter coils, installation of a breather shroud, and a curved path breather element.

This issue remains open pending NRC review and evaluation of the licensee's corrective action Exit Interview The inspection scope and results were summarized on January 14, 1994, with those persons indicated in paragraph 1.

The inspectors described the areas inspected and discussed in detail the inspection findings.

Proprietary information is not contained in this report.

No dissenting comments were received from the licensee.

One IFI was identified.

.IFI 50-400/94-03-01, Corrective Actions for.ACFR 93-560 Concerning Temporary Modification Renewals not Being Performed Acronyms and Initialisms ACFR ALARA CFR CII CP&L CSIP

,EDG ESCWS FSAR HESS HPAS MOV NAD NED NGGM NPPP PCR PM PRG gA SHNPP TM TMM TS Adverse Condition Feedback Report As Low As Reasonably Achievable Code of Federal Regulations Corporate Improvement Initiative Carolina Power and Light Company Charging Safety Injection Pump Emergency Diesel Generator Essential Services Chilled Water System Final Safety Analysis Report Harris Engineering Support Section Harris Project Assessment Section Motor Operated Valve Nuclear Assessment Department Nuclear Engineering Department Nuclear Generation Group Manual Nuclear Plant Prioritization Process Plant Change Request Preventive Maintenance Plant Review Group guality Assurance Shearon Harris Nuclear Power Plant

= Temporary Modification Technical Support Management Manual Technical Specifications

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