IR 05000400/1995011
| ML18011A989 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/04/1995 |
| From: | Darrell Roberts, Verrelli D NRC Office of Inspection & Enforcement (IE Region II) |
| To: | |
| Shared Package | |
| ML18011A988 | List: |
| References | |
| 50-400-95-11, NUDOCS 9508090344 | |
| Download: ML18011A989 (24) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 303234199 Report No.:
50-400/95-11 Licensee:
Carolina Power 8 Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
License No.:
NPF-63 Inspection Cond ted June ll - July 8, 1995 Inspectors:
D.
oberts, Acting enior Resident Inspector Other Inspector:
.
El od, Senior Resident Inspector Approved Py:
D.
er elli, Chief Reacto Projects Branch lA Division of Reactor Projects ate Signed Date Signed SUMMARY Scope:
This routine inspection was conducted in the areas of plant operations, maintenance, surveillance, engineering activities, plant support, review of licensee event reports, and licensee action on previous inspection items.
Numerous facility tours were conducted and facility operations observed.
Results:
Plant 0 erations Operations were performed adequately.
Spent fuel movement was performed well, paragraph 3.a.(2).
An inspector followup item was opened concerning the resolution of a containment isolation valve deficiency, paragraph 3.b.
Maintenance Work performance was satisfactory with proper documentation of removed components and independent verification of the reinstallation.
95080'70344 950804 PDR ADCICK 05000400
En ineerin One non-cited violation was identified involving inadequate design control activities associated with a design change, paragraph 5.a.(l).
Otherwise, engineering activities were performed well, especially system engineering activities associated with the Auxiliary Feedwater System Terry Turbine, paragraph 5.b.
Plant Su ort Plant support activities were adequate.
Improved housekeeping was noted in the Reactor Auxiliary Building 236 foot elevation, paragraph 6.a.
The licensee effectively demonstrated Technical Support Center setup during a
drill, paragraph 6.e.
A lapse in personnel performance was noted when an individual acquired someone else's thermoluminescent dosimeter upon entering the protected area, paragraph REPORT DETAILS PERSONS CONTACTED Licensee Employees D. Batton, Superintendent, On-Line Scheduling D. Braund, Hanager, Security
- J. Collins, Manager, Training J.
Dobbs',
Manager, Outage and Scheduling
- J. Donahue, General Manager, Harris Plant R. Duncan, Manager, Technical Support C.
Rose, Acting Manager, Maintenance
- M. Hamby, Manager, Regulatory Compliance H. Hill, Manager, Nuclear Assessment D. McCarthy, Superintendent, Outage Management R. Prunty, Manager, Licensing and Regulatory Programs
- W.'obinson, Vice President, Harris Plant
- G. Rolfson, Manager, Harris Engineering Support Services
- T. Walt, Manager, Regulatory Affairs B. White, Manager, Environmental and Radiation Control A. Williams, Manager, Operations Other licensee employees contacted included:
office, operations, engineering, maintenance, chemistry/radiation control, and corporate personnel.
NRC Personnel S. Elrod, Senior Resident Inspector, Harris Plant
- D. Roberts, Acting Senior Resident Inspector, Harris Plant
"Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph.
PLANT STATUS AND ACTIVITIES
'a ~
b.
Operating Status of the Plant During the Inspection Period.
The plant continued in power operation (Mode I) for the duration of this inspection period.
The unit ended the period in day 241 of power operation since startup on November 8, 1994.
Other NRC Inspections or Meetings at the Site.
C.
Payne, Senior License Examiner, NRC RII, was on site from June 26-29 administering operator license examinations.
He was accompanied by NRC contractors T. Vehec and A. Lopez, both of Battelle Pacific Northwest Laboratories.
The examiners were
previously on site from June 12-16 for an examination preparation visit.
They conducted an exit meeting on June 29 and their findings will be documented in IR 95-300.
OPERATIONS a ~
Plant Operations (71707)
Shift Logs and Facility Records The inspector reviewed records and discussed various entries with operations personnel to verify compliance with the TS and the licensee's administrative procedures.
In addition, the inspector independently verified clearance order tagouts.
The inspectors found the logs to be legible and well organized, and to provide sufficient information on plant status and events.
The inspectors found clearance tagouts to be properly implemented.
The inspectors identified no violations or deviations in the shift logs and facility records area.
(2)
Facility Tours and Observations Throughout the inspection period, the inspectors toured the facility to observe activities in progress, and attended several licensee meetings to observe planning and management activities.
The inspectors made some of these observations during backshifts.
During these tours, the inspectors observed monitoring instrumentation and equipment operation.
The inspectors also verified that operating shift staffing met TS requirements and that the licensee was conducting control room operations in an orderly and professional manner.
The inspectors additionally observed several shift turnovers to verify continuity of plant status, operational problems, and other pertinent plant information.
Licensee performance in these areas was satisfactory.
On July 3, the inspector observed spent fuel handling operations at the Fuel Handling Building operating floor.
These operations involved offloading spent fuel (received from the Brunswick plant) from the SF-300 shipping cask and transporting the fuel to predetermined rack locations in the
"B" spent fuel pool.
Operators performed the fuel handling activities in accordance with procedures FHP-014, Rev. 6, Fuel and Insert Shuffle Sequence; and FHP-020, Rev.
6, Fuel Handling Operations.
The inspector observed that the
operators adequately implemented these procedures and moved the fuel assemblies in accordance with good operating practices.
Spent fuel assemblies were placed in appropriate rack locations as prescribed in procedure FHP-014.
The inspectors identified no violations or deviations in the facility tours and observations area.
Effectiveness of Licensee Control in Identifying, Resolving, and
,Preventing Problems (40500)
The licensee recently revised its corrective action program as delineated in procedure AP-615, Rev.
12, Condition Reporting.
Changes to the program included renaming Adverse Condition and Feedback Reports (ACFRs)
as Condition Reports (CRs).
Additionally, certain administrative responsibilities once belonging to the CAP/OEF Hanager were transferred to the Section/Unit Coordinators for various subprograms (e.g.,
maintenance, operations, and engineering).
The inspector reviewed ACFR 95-1463, which was generated when questions were raised concerning the control room position indication for PASS system valve 1SP-209.
Specifically, a
deficiency tag was initiated on Hay ll against containment isolation valve 1SP-209 when operators opened the valve from a main control room panel and received mid-position instead of full open indication.
Three weeks later, on June 1, another operating shift determined that the questionable position indication rendered the valve inoperable (since Hay 11) because the full open position could not be verified during subsequent TS surveillance tests.
The surveillance test procedures required that the valve be stroke-timed (with position verification) from full open to full closed.
Plant management later dispositioned the issue by declaring that the valve was not inoperable because the valve's safety function was to be closed
-
a position which was not in question following the incident on Hay ll. Additionally, the valve was within its surveillance frequency and was not due to be tested until later in June, at which time it could be declared inoperable until successfully tested.
On June 12, based on main control room indication, the valve was successfully stroked from full open to full closed and considered operable.
In discussions with various plant personnel, the inspectors were told that no maintenance or troubleshooting was performed on the valve between Hay ll and June 12 to investigate the questionable valve indication.
On June 7 the inspector had observed an operator opening the valve and witnessed the mid-position indication.
Again on July ll the inspector witnessed an operator opening the valve and this time the full open position was indicated on the control panel.
The inspector determined that further NRC review of this matter was warranted.
This NRC review will include determining the valve's operating characteristics,
its specific system function, and what verification techniques, if any, were used to conclude that the valve was indeed fully opened during surveillance testing on June 12.
The inspector will follow this issue as IFI 95-11-01, guestionable Position Indication for Containment Isolation Valve 1SP-209.
C.
d.
Followup - Operations (92901)
(Closed)
IFI 94-22-01, Root Cause Determination for TDAFW Pump Overspeed Events.
The licensee's event review team formed after the October 1994 overspeed trip concluded that the most likely cause was a loose power connection between the electronic governor and the ramp generator signal convertor logic card.
The problem was believed to have been corrected when the logic card was replaced in October.
The team recommended no further corrective actions for the pump, which itself had performed well in over two dozen starts since October.
The system engineer has planned several enhancements for future monitoring of the Terry Turbine governor valve's performance.
The system engineer was also monitoring system performance in accordance with the upcoming NRC Haintenance Rule, which the licensee had already proceduralized.
As mentioned in paragraph 5.b of this report, the inspector considered the system engineer's activities to monitor and track the performance of this component to be exemplary.
This item is closed.
Review of LERs (92700)
(Closed)
LER 95-004-00, Technical Specification Violation Due to Not Identifying Inoperable Condition for 1HS-62, S/G "C" PORV.
This LER was submitted to report actions cited in NRC IR 95-10.
The LER sufficiently described the conditions and actions.
This item is closed and corrective actions will be inspected against VIO 95-10-01.
The inspectors identified no violations or deviations in the plant operations area.
HAINTENANCE a ~
Haintenance Observation (62703)
The inspector observed the maintenance and reviewed the work packages for the following maintenance activity to verify that correct equipment clearances were in effect, work requests were issued, and TS requirements were being followe WR/JO 95-AGTB1 Modify HCC 1A31-SA, Compartment 14D, in Accordance with ESR 95-00568.
HCC Cubicle 1A31-SA-14D housed electrical components associated with the hydraulic pump power and alarm circuitry for "C" steam generator PORV 1MS-62.
Following the prior identification of a design deficiency which resulted in NRC Violation 95-10-01, the licensee initiated ESR 9500568 to bring the system into compliance with design drawings.
Errors in developing ESR 9500568 and the associated acceptance test procedure were identified during
<<
performance of WR/JO 95-AGTBl and are discussed further in paragraph 5.a of this report.
The inspector observed the technicians determinate wires, remove an extra relay, fuse, and blue indicating lamp, and reterminate wires in accordance with instructions contained in the ESR.
OC personnel located at the job site witnessed all wiring changes as required by the work ticket.
The technicians appropriately performed independent verifications as well.
The responsible maintenance foreman was periodically available and witnessed ongoing work.
When problems were encountered concerning a wire that was double-counted in the design package installation instructions, the technicians appropriately stopped work until the design package was corrected.
This decision was supported by their foreman.
Workmanship was excellent with proper documentation of removed components and independent verification of the reinstallation.
The inspectors identified no violations or deviations in this area.
Surveillance Observation (61726)
The inspector observed several surveillance tests to verify that approved procedures were being used, qualified personnel were conducting the tests, tests were adequate to verify equipment operability, calibrated equipment was used, and TS requirements were followed.
Test observation and data review included:
(1)
HST-I0204, Rev. 3/1, Refueling Water Storage Tank Level (L-0990) Operational Test.
The licensee performed this surveillance test to meet part of the requirements of TS 4.3.2. 1, ESFAS Instrumentation Surveillance Requirements.
The RWST level channels provided input to RHR and Containment Spray pump switchover logic (to containment sump suction) following ESFAS actuation, as well as input to control room indication and alarm logic.
The test satisfied the TS requirement to perform a monthly operational test'.
The inspector verified that technicians performing the test used calibrated M&TE, that the technicians followed the latest revision of the approved
procedure, and that as-found data was within allowable ranges specified on the data sheets.
The inspector concluded that the technicians competently and effectively performed the surveillance procedure.
HST-I0270, Rev. 3, LO-LO TAVG P-12 Interlock (T-0432)
Operational Test.
This surveillance test satisfied part of the monthly operational test requirement contained in TS 4.3.2.1.
The P-12 permissive was designed to allow steam dump operation only when two out of three loop sensors indicated that reactor coolant TAVG was greater than the LO-LO setpoint.
This feature would prevent undesired cooldown transients.
During the surveillance test, technicians electronically simulated a
LO-LO TAVG input (equivalent to 553 degrees F)
to the channel comparator card.
Technicians then verified that the appropriate bistable tripped and reset within allowable ranges of predetermined setpoints.
The inspector verified that technicians used calibrated HKTE and the appropriate procedure.
The inspector concluded that the technicians performed this procedure well.
Acceptance Test EPT-704T, Rev.
0 and Rev.
1, Temporary Procedure for Testing Control Circuitry of 1HS-62.
This acceptance test verified that control circuitry for the 1HS-62 hydraulic pump motor and associated control room alarm functioned in accordance with design drawing CWD 2166-B-401-1257, Rev. 8.
As discussed in paragraph 5.a of this report, ESR 9500568 modified this circuitry because of previous design deficiencies.
The acceptance test simulated loss of control power, low nitrogen gas pressure, low hydraulic accumulator oil pressure, and low oil reservoir level.
The test verified that the control room alarm annunciated on all of these inputs.
The procedure also verified that the hydraulic pump started on low accumulator oil pressure (proceduralized by opening a bleed valve on the accumulator),
and that the control room trouble alarm functioned after a specified time delay.
The procedure then verified that the pump stopped within two minutes of technicians closing the accumulator bleed valve.
Finally, the test verified that the pump did not operate when oil reservoir level was low.
During the test, a procedure discrepancy was discovered concerning the setpoint for the time delay associated with the control room alarm on low accumulator pressure.
Step 7.4.4 of the procedure directed technicians to verify that the control room annunciator alarmed after approximately 18 seconds.
In late 1994, a design change (ESR 9400035)
had changed the time delay relay setpoint to
50 seconds.
Technicians discovered the discrepancy during the test when low oil pressure was simulated and the control room alarm annunciated after about 50 seconds based on stopwatch indication.
Technicians informed the engineer controlling the procedure.
The engineer subsequently researched the HNP Setpoint Document, acquired the correct time delay relay setpoint, and changed the test procedure.
The technicians later completed the procedure with no further problems.
The inspectors found satisfactory surveillance procedure performance with proper use of calibrated test equipment, necessary communications established, notification/authorization of control room personnel, and knowledgeable personnel having performed the tasks.
The inspectors observed no violations or deviations in this area.
Review of LERs (92700)
(Open)
LER 95-003-00, Inadequate Testing of Air Handling Unit AH-86 Cooling Water Supply Valves.
This LER documented deficiencies in the testing methodology for components that perform safety-related support functions or receive ESF signals indirectly, through another component's actuation.
The deficiencies affected components in the ESW, containment spray, and feedwater systems.
For example, under the licensee's previous testing philosophy, ESW valves were stroke tested on a quarterly basis but the testing did not utilize the ESW pump actuation circuitry and associated contacts.
The licensee determined on Hay 18, that the previous testing methodology did not comply with TS surveillance requirements and that this condition was reportable.
Licensee personnel continued a thorough review of other surveillance procedures and identified similar testing deficiencies involving an ESW screen wash system valve, containment spray pump suction valves, and valves receiving feedwater isolation signals.
For all of the identified deficiencies, the licensee appropriately entered TS 4.0.3 which allowed them 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform the proper surveillance tests.
In each case, the questionable components
- mostly auxiliary contacts
- were verified to operate properly.
The licensee attributed the deficient TS surveillance procedures to an old management philosophy to test only those components that received safety-related signals directly.
The licensee and inspector concluded that the safety significance of this error was minimized by the satisfactory testing once the conditions were
discovered.
Additionally, the satisfactory performance of the valves during IST testing provided a high confidence level that the systems were previously capable of performing their safety functions.
This LER will remain open until the licensee completes further corrective actions to revise affected procedures.
ENGINEERING
'a ~
Design and Installation of Plant Hodifications (37551)
ESRs involving the 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.
ESRs documenting engineering evaluations were also reviewed.
The following engineering evaluations, modifications and/or testing in progress were inspected.
(1)
Engineers issued ESR 9500568 to correct design deficiencies associated with the hydraulic pump motor control circuit for valve 1HS-62, the "C" steam generator PORV.
The ESR specifically removed certain unused remote shutdown components which had been installed in the HCC cubicle, rewired the HCC cubicle to match the intended design shown on CWD 2166-B-401, Sheet 1257, Rev. 8.,
and corrected the CWD to reference the proper HCC EHDRAC drawing.
Additionally, the ESR specified acceptance testing requirements which were implemented by temporary test procedure EPT-704T (also see paragraph 4.b.(3) of this report).
ESR 9500568 contained several errors discovered during modification implementation and acceptance testing.
The errors were attributed to lapses in personnel performance and resulted from inadequate attention to detail, an inadequate technical review, and inappropriate handling of a deficient design drawing.
These items are discussed separately in the following paragraphs.
Wire Counted Twice in Installation Packa e
While installing the modification, technicians discovered that wire 31, identified in the ESR installation instructions and applicable engineering sketches as being connected from fuse FU1/1257 to fuse FU2, did not exist.
Technicians discovered this while walking through the installation instructions prior to actually determinating or reterminating any wires.
They consulted with the cognizant engineer who was at the job site.
The engineer indicated
that he had miscounted wire number 31 while developing the ESR (another wire labeled 31 was shown connecting fuse FU2 to transformer point Xl).
In the plant, fuse FUl/1257 was hard connected (with no wire) to transformer points Xl and XF.
The engineer indicated that he had made the counting error while reviewing personal notes taken during his as-built walkdown.
These notes listed HCC cubicle components and any wires associated with them.
Notes for the transformer and for fuse FU2 appropriately listed wire 31 connecting one to the other.
However, notes for fuse FUl/1257 mistakenly listed wire 31 since both that fuse and the wire were terminated to the same point on the transformer.
This was actually the wire that connected fuse FU2 to the transformer.
Upon discovery, the engineer issued Rev.
1 to the ESR correctly identifying wire 31.
The technicians subsequently completed the installation.
This particular design error was considered minor because there was no functional difference between the actual configuration and that depicted in the original ESR installation sketches.
Additionally, technicians appropriately stopped work until the ESR was corrected.
However, in aggregation with other errors discussed in subsequent paragraphs of this report section, the double-counted wire error illustrated a need to use better attention to detail while developing design packages.
Deficient Desi n Drawin Referenced in ESR The inspector observed technicians referring to two drawings while investigating the double-counted wire problem.
These were CWD 2166-B-401, Sheet 1257 and EMDRAC drawing 1364-020991.
The CWD depicted how the cubicle would look post-modification.
The EHDRAC drawing was a generic vendor document showing how cubicle lA31-SA-14D and certain other NCC cubicles were originally designed.
Both drawings were referenced in ESR 9500568, Section E, Installation Considerations.
This section of the design package contained a note that the drawings
"may prove useful as references during the implementation of this ESR."
Based on this information, the technicians had acquired controlled copies of the drawings prior to coming to the job site.
While the technicians reviewed the EHDRAC drawing, the design engineer pointed out that it contained certain errors.
Specifically, fuse FUI/1257 was shown on the drawing as connected to termination 13 and transformer point Xl.
In the plant, it was actually connected to transformer points XF and Xl.
A normally closed contact on relay 74-2 was shown wired to termination 19, when it was actually wired to termination 13 in the field.
Termination 19 was
not used in the field.
The inspector recalled a discussion a month earlier in which the engineer had identified these same drawing discrepancies.
The inspector concluded that these known deficiencies should have been annotated on the drawing via the licensee's normal document change process when they were initially discovered, and the deficient drawing should not have been included in ESR 9500568 installation package as a "useful reference."
The licensee informed the inspector that since these errors only affected one of the four HCC cubicles to which this drawing applied, the process for changing it would be cumbersome.
The licensee had also stated its intentions to remove this particular series of EHDRAC drawings from the controlled document program.
Therefore, the engineer did not feel compelled to change the drawing previously or following implementation of ESR 9500568.
Although the licensee verbally considered the EHDRAC series as reference drawings merely duplicating information on the plant's "true" design drawings - the CWDs, the licensee's program at the end of the inspection period required that the EHDRACs be treated as design documents.
Specifically, plant procedure PLP-202, Verify Working Document Program, Rev.
1 defined
"Design Documents" as those documents li'sted in the Harris NRCS Design Document Menu and included EMDRAC drawings.
Plant procedure PLP-650, Rev. 3, Engineering Service Request, required in Section 4.4, Program Requirements, that appropriate documents are identified for revision, revised and approved as a'result of any change.
The licensee's handling of deficient drawing EHDRAC 1364-020991 was contrary to those requirements.
Additionally, incorporating a drawing with known deficiencies into the 1HS-62 hydraulic circuit modification package was considered contrary to design control requirements contained in
CFR 50, Appendix B, Criterion III, Design Control.
Following discussions with the inspector, the engineer initiated ESR 9500619 to have the HCC EHDRAC drawings voided as controlled documents.
This is the first example of Non-Cited Violation 95-11-02, Failure to Implement Adequate Design Control Measures for 1HS-62 Hydraulic Pump Circuit Modification.
Wron Acce tance Criteria Stated in Test Procedure A third error identified during the implementation of ESR 9500568 was contained in acceptance test procedure EPT-704T, Rev. 0.
Specifically, step 7.4.4 of this procedure verified that the SG PORV trouble annunciator in the main control room alarmed (after a time delay)
on low hydraulic accumulator oil pressure.
The time delay reduced
nuisance alarms in the control room when the hydraulic oil pump cycled on and off to recover small losses in accumulator pressure.
The time delay acceptance criteria in procedure EPT-704T was stated as 18 seconds.
During testing, the annunciator alarmed at about 50 seconds.
The technicians informed the system engineer who researched the HNP Setpoint Document and determined that the time delay relay was actually set at 50 seconds.
This setpoint had been increased from 18 seconds in late 1994 to further reduce the number of nuisance alarms in the control room..
The system engineer corrected the procedure step to reference the appropriate time delay criteria and the test was successfully completed.
The inspector discussed the time delay error with the two system engineers who separately authored and performed the technical review for this procedure.
Both indicated that they had relied on memory for this step and failed to research any related plant design documents.
Harris procedure ENP-005, Rev.
2, ESR Modification Implementation, Attachment 7 required that, among other items, the HNP Setpoint Document be used in developing acceptance tests.
The engineers'ctions while developing EPT-704T were contrary to those requirements and resulted in an inadequate acceptance test procedure.
CFR Part 50, Appendix B, Criterion III, Design Control, required that measures be established to assure that design bases are correctly translated into design documents.
The licensee's Corporate guality Assurance Manual, Section 3.0, set forth requirements for control of design activities affecting systems, components, and structures.
The licensee's gA manual required that sufficient design verification shall be performed to substantiate that the final design documents meet the appropriate design inputs.
Based on the noted errors, the inspector concluded that adequate measures were not performed to ensure the accuracy of design package ESR 9500568 and its associated acceptance test.
The licensee's performance in this area is considered to be a violation of the above requirements.
This licensee-identified and corrected violation is being treated as a
Non-Cited Violation, consistent with Section VII of the NRC Enforcement Policy.
This is the second example of Non-Cited Violation 95-11-02, Failure to Implement Adequate Design Control Measures for 1MS-62 Hydraulic Pump Circuit Modificatio The licensee corrected the design package errors prior to completing the modification.
Additionally, the cognizant system engineer initiated CR 95-1694 to address the performance issues and licensee management counseled the involved individuals.
(2)
(3)
ESR 9500503 performed an engineering evaluation allowing radiological shielding to be placed on various piping systems in the RAB mechanical penetration room.
The lead blanket shielding was necessary to reduce radiological exposure to workers during a long-term painting project.
The affected piping systems included RHR, low-head safety injection, and excess letdown.
The ESR specified which lines could have direct shielding placed on them and which lines could be "shadow shielded" using other surrounding structures (due to pipe loading concerns).
Lead blanket weight distribution limits were imposed for each section of piping.
Supporting pipe-load calculations were also referenced in the ESR.
The inspector walked down the RAB mechanical penetration area and verified that shielding had been installed as instructed in the ESR.
The inspector concluded that this ESR and its implementation were examples of good licensee performance.
ESR 9500125 contained instructions for removing a large
"white iron" steel structure from the area near the containment building equipment hatch.
This structure had been previously constructed to support a 50-ton bridge crane used for removal of items from the containment building.
The steel was deemed no longer necessary as the licensee now planned to use a different crane for this purpose.
The ESR contained a thorough safety analysis which considered various implications of the steel removal project.
It included a seismic stability analysis of the structure during transitional periods with pieces removed, considered potential impact on underground radioactive waste gas decay tanks located in the area, and provided a safe-load path which prevented the nearby RWST from being adversely impacted.
The inspector observed some of the steel removal activities and verified that the safe-load path instructions were followed.
This ESR and its implementation were conducted well.
The inspector concluded that, with the exception of ESR 9500568, those engineering division products reviewed were of good quality.
ESR 9500568 illustrated lapses in performance in this area.
One Non-Cited Violation was identified in the design and installation of plant modifications are b.
Onsite System Engineering (37551)
While closing IFI 94-22-01, the inspector reviewed system engineering activities associated with the TDAFW pump.
The system engineer had developed his own methodology for monitoring and tracking pump and system performance.
The engineer also demonstrated that he was aware of industry problems with the Terry Turbine and had accordingly initiated design changes for his system.
Because of the engineer's progress in trending system performance and evaluating industry operating experience, licensee management informally designated the AFW system as the pilot to be used in determining future NRC Maintenance Rule implementation activities.
The inspector considered the system engineer's progress in this area to be beneficial to the licensee's overall system engineering program.
The inspectors identified no violations or deviations in the systems engineering area.
The inspectors concluded that, except for the development of ESR 9500568, those engineering activities reviewed were performed adequately.
One Non-Cited Violation was identified in the engineering activities area.
6.
PLANT SUPPORT
~
~a.
Plant Housekeeping Conditions (71707) - The inspectors reviewed storage of material and components, and observed cleanliness conditions of various areas throughout the facility to determine whether safety or fire hazards existed.
The inspector concluded that housekeeping in the RAB 236 foot elevation (mechanical equipment area)
had significantly improved since the licensee completed its material upgrade project for that area this spring.
While the upgrade project (which included new flooring, pipe insulation, and system color coding)
was continuing for other plant locations at the close of the inspection period, the mechanical equipment area demonstrated that this project was beneficial to the overall appearance and upkeep of the plant.
b.
Radiological Protection Program (71750)
- The inspectors reviewed radiation protection control activities to verify that these activities were in conformance with facility policies and procedures, and in compliance with regulatory requirements.
The inspectors also verified that selected doors which controlled access to very high radiation areas were appropriately locked.
Radiological postings were likewise spot checked for adequacy.
On June 27, a plant employee accidentally picked up the inspector's TLD upon entering the protected area.
All of the TLDs were located in storage racks in the security building at the main entrance to the plant.
The individual's TLD was located in the slot just above the inspector's in the storage rack.
The
I
inspector discovered the situation when he attempted to locate his TLD later that morning.
Licensee personnel were able to quickly locate the individual and the TLD, which was later returned to the inspector.
Licensee personnel verified that the individual had not attempted to enter the RCA with another person's TLD.
The individual initiated CR 95-1632 to document his mistake.
The inspector discussed the incident with licensee management who indicated that this had not been a recurring problem.
The inspector observed that the potential for this type of incident had increased since the licensee implemented its new policy of having employees acquire their own TLDs upon entering the plant.
Previously, the TLDs were attached to plant badges and issued by security personnel.
The inspector concluded that the above incident represented a lapse in performance which licensee management handled appropriately.
Security Control (71750)
- During this period, the inspectors toured the protected area and noted that the perimeter fence was intact and not compromised by erosion or disrepair.
The fence fabric was secured and barbed wire was angled.
Isolation zones were maintained on both sides of the barrier and were free of objects which could shield or conceal an individual.
The inspectors observed various security force shifts perform daily activities, including searching personnel and packages entering the protected area by special purpose detectors or by a physical patdown for firearms, explosives and contraband.
Other activities inspected included vehicles being searched, escorted and secured; escorting of visitors; patrols; and compensatory posts.
In conclusion, the inspectors found that selected functions and equipment of the security program complied with requirements.
Fire Protection (71750)
- The inspector observed fire protection activities and equipment to verify that fire alarms, extinguishing equipment, actuating controls, fire fighting equipment, emergency equipment, and fire barriers were operable.
During plant tours, the inspector looked for fire hazards.
The inspector concluded that the fire equipment and barriers inspected were in proper physical condition.
Emergency Preparedness (71750)
- The inspectors toured emergency response facilities to verify availability for emergency operation.
Duty rosters were reviewed to verify appropriate staffing levels were maintained.
The inspector observed an emergency preparedness drill to verify response personnel were adequately trained.
The licensee conducted a
TSC "Setup Drill" on July 6 to demonstrate that the TSC could be set up and activated within the emergency plan requirement of 75 minutes.
The TSC was under a
planned renovation throughout the inspection period and, as such, had been stripped of much equipment including tables, chairs, log
boards, and procedures.
Necessary setup equipment was temporarily stored in auxiliary locations elsewhere in the building.
Phones were stored on the TSC floor but had to be plugged into their respective phone outlets.
The inspector noted that the licensee's key players were already on site when the drill started, thereby creating an advantage.
However, the licensee demonstrated that it could setup the TSC to facilitate emergency response activities within a half hour of a staff callout.
The inspector concluded that the TSC could be expeditiously set up and considered the drill to be effective in demonstrating actual TSC setup.
f.
Effectiveness of Licensee Control in Identifying, Resolving, and Preventing Problems (40500)
The licensee's Nuclear Assessment Section completed a two week assessment of the emergency preparedness program on June 2.
The findings were discussed in NAS report H-EP-95-01, Emergency Preparedness Program Assessment.
The inspectors reviewed the report and concluded that the assessment was thorough and resulted in substantive findings.
The inspectors identified no violations or deviations in the Nuclear Assessment area.
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, emergency preparedness requirements, and TS requirements in these areas was satisfactory.
The inspectors identified no violations or deviations in the plant support area.
EXIT INTERVIEM The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on July 14, 1995.
During this meeting, the inspector summarized the scope and findings of the inspection as they are detailed in this report, with particular emphasis on the Non-Cited Violation and Inspector Followup 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 Status Descri tion and Reference 95-11-01 Open IFI guestionable Position Indication for Containment Isolation Valve 1SP-209, paragraph Closed Closed Open Closed
NCV Failure to Implement Adequate Design Control Measures for 1MS-62 Hydraulic Pump Circuit Modification, paragraph 5.a.(1).
IFI Root Cause Determination for TDAFW Pump Overspeed Events, paragraph 3.c.
LER Inadequate Testing of Air Handling Unit AH-86 Cooling Water Supply Valves, paragraph 4.c.
LER Technical Specification Violation Due to Not Identifying Inoperable Condition for 1MS-62, S/G "C" PORV; paragraph 3.d.
ACRONYMS AND INITIALISMS ACFR AFW CAP CFR CR CWD EMDRAC-encl ENP EPT ESF ESFAS-ESR ESW FHP HNP IFI IR IST LER MSTE MCC MST NAS NCV NPF NRC NRCS OEF Adverse Condition and Feedback Report Auxiliary Feedwater Corrective Action Program Code of Federal Regulations Condition Report Control Wiring Diagram Ebasco Manufacturers Drawing Revision and Control Enclosure Engineering Procedure Engineering Periodic Test Engineered Safety Feature Engineered Safety Feature Actuation System Engineering Service Request Emergency Service Water Fuel Handling Procedure Harris Nuclear Plant Inspector Followup Item
[NRC) Inspection Report Inservice Testing Licensee Event Report Measuring and Test Equipment Motor Control Center Maintenance Surveillance Test Nuclear Assessment Section Non-cited Violation Nuclear Production Facility [a type of license]
Nuclear Regulatory Commission Nuclear Revision Control System Operating Experience Feedback
PLP PORV QA QC RAB RHR RWST SG TAVG TDAFW-TLD TS TSC VIO WR/JO-
Plant Program Power Operated Relief Valve Quality Assurance Quality Control Reactor Auxiliary Building Residual Heat Removal Refueling Water Storage Tank Steam Generator
[also S/G]
Average Reactor Coolant Temperature Turbine Driven Auxiliary Feedwater Pump Thermoluminescent Dosimetry Technical Specification [Part of the Facility License]
Technical Support Center Violation [of NRC Requirements]
Work Request/Job Order