IR 05000400/1995019
| ML18012A124 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/26/1996 |
| From: | Darrell Roberts, Shymlock M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18011B129 | List: |
| References | |
| 50-400-95-19, NUDOCS 9602120047 | |
| Download: ML18012A124 (34) | |
Text
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++*++
Report No.:
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 303234 I99 50-400/95-19 Licensee:
Carolina Power
& Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 License No.:
NPF-63 Facility Name:
Harris
Inspection Conducted:
December 10, 1995 - January 6,
1996 Inspectors:
o erts, c
ng en>or es ent nspec or f~~/zc a e gne Other Inspector:
W. Kleinsorge, Reactor Inspector, Region II Approved by:
ym oc
,
Reactor Projects Branch
Division of Reactor Projects I
a e gne SUMMARY Scope:
This routine inspection was conducted in the areas of operations, maintenance, surveillance, engineering, plant support, review of licensee event reports, and licensee action on previous inspection items.
Numerous facility tours were conducted and facility operations observed.
Results:
Pla t 0 e t ons Operations were performed satisfactorily.
An Unusual Event was declared when a
CP&L train carrying an empty spent fuel cask derailed on plant property, paragraph 3.b.
The licensee's reaction to the event included a thorough root cause investigation.
A plant startup was performed well with reactor criticality occurring close to estimated critical 'conditions, paragraph 3.a.(2).
Control room personnel responded well to a letdown system transient, paragraph 3.a.(2).
The plant was generally prepared for the current cold weather season, paragraph 3.c.
No violations or deviations were identified in the Plant Operations area.
9602120047 960i26 PDR ADOCK 05000400
PDR Enclosure
Maintenance Workmanship was good with proper use of procedures, correct replacement parts installed, and proper verification of restored equipment, section 4.
Inattention to detail resulted in a deficient surveillance procedure for the Auxiliary Feedwater flow control valves, paragraph 4.c.
No violations or deviations were identified in the Maintenance area.
En ineerin System engineering activities were adequate to resolve a potential service water system single failure issue, paragraph 5.
No violations or deviations were identified in the Engineering area.
Plant Su ort Plant housekeeping and material condition of components was satisfactory, but with room for improvement, paragraph 6.a.
The licensee's adherence to radiological controls, security controls, fire protection requirements, emergency preparedness requirements and TS requirements in these areas was satisfactory.
A Nuclear Assessment Section report on Engineered Safety Features Actuation System response time testing was thorough, paragraph 6.f.
No violations or deviations were identified in the Plant Support area.
Enclosure
REPORT DETAILS PERSONS CONTACTED Licensee Employees
- D. Alexander, Supervisor, Licensing and Regulatory Programs D. Batton, Superintendent, On-Line Scheduling D. Braund, 'Superintendent, Security J. Collins, Manager, Training J.
Dobbs, Manager, Outage and Scheduling J.
Donahue, General Manager, Harris Plant R. Duncan, Superintendent, Mechanical Systems W. Gautier, Manager, Maintenance H. Hamby, Supervisor, Regulatory Compliance
- H. Hill, Manager, Nuclear Assessment D. HcCarthy, Superintendent, Outage Management
- W. Robinson, Vice President, Harris Plant
- G. Rolfson, Manager, Harris Engineering Support Services
- S. Sewell, Superintendent, Design Control
- T. Walt, Manager, Performance Evaluation and Regulatory Affairs B. White, Manager, Environmental and Radiation Control A. Williams, Hanager, Operations Other licensee employees contacted included:
office, operations, engineering, maintenance, chemistry/radiation control, and corpo} ate personnel.
NRC Personnel W. Kleinsorge, Reactor Inspector, Region II
- D. Roberts, Acting Senior Resident Inspector, Harris Plant D. Thompson, Physical Security Specialist, Region II
~Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph.
PLANT STATUS AND ACTIVITIES Operating Status of the Plant Over the Inspection Period.
The plant began the period operating in Mode I (power operations).
On December 27, the unit was taken off line ending 50 days of power operations since startup on November 7, 1995.
The shutdown to Node 3 was performed to allow repairs on the "48" Feedwater Heater.
The plant was further cooled to Mode 4 conditions on December 29 to allow troubleshooting of a perceived problem on the SSPS system.
The problem was discovered to be a procedural error in a surveillance test vice a hardware deficiency.
Following the SSPS troubleshooting and feedwater heater repairs, operators heated the plant to Node 3 on December 30 and took the reactor Enclosure
critical on December 31.
The plant continued in power operations throughout the remainder of the inspection period.
b.
Other NRC Inspections or Meetings at the Site.
Mr.
W. Kleinsorge, a Reactor Inspector from the Region II office, was onsite from December 18-22, 1995 inspecting routine maintenance activities.
The ins'pector discussed findings with selected licensee representatives prior to leaving on December 22.
His findings are included in this report.
Mr. D. Thompson, a, Physical Security Specialist from the Region II office, was onsite from December 18-22, 1995 inspecting the licensee's security program.
The inspector conducted an exit meeting on December 22, 1995 and his findings were documented in NRC IR 400/95-20.
3.
OPERATIONS a.
Plant Operations (71707)
(1)
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'o violations or deviations in shift logs and facility records.
(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.
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 shift turnovers to verify Enclosure
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continuity of plant status, operational problems, and other pertinent plant information.
The inspector observed the reactor startup from the forced outage on December 30, 1995.
The reactor was taken critical just after midnight on December 31.
Criticality occurred close to estimated boron concentration and control rod
.positions.
Operator performance during this startup was good.
The inspector also observed operator response to a plant transient involving a failed letdown system pressure controller.
The, pressure controller failed, allowing the associated pressure control valve, 1CS-38 (PCV-145), to shut, and causing letdown pressure to increase sufficiently to lift a relief valve, 1CS-10, in the system.
Approximately 110 gallons of CVCS water was relieved into the pressurizer relief tank inside containment.
The letdown system pressure controller had failed earlier that day, but operators were able to detect the first failure before letdown system pressure increased above the relief valve's lift setpoint.
The second failure occurred during troubleshooting of the controller's driver card (with the controller placed in manual).
Following the second incident, operator's secured normal letdown, placed excess letdown in service, and maintained charging to the reactor coolant pump seals.
The plant remained stable at 100 percent power during both letdown system transients.
The pressure controller failure was attributed to a bad logic card which the licensee replaced.
Licensee performance during the above operations was satisfactory.
Theinspector's only comment was that the normal letdown system remained in service following the first controller failure and that precautions to place excess letdown in service prior to the troubleshooting effort could have prevented the second challenge.
The inspector's comment was discussed with"plant management who acknowledged it.
No violations or deviations were identified in this area.
b.
Onsite Response To Events (93702)
A Notice of Unusual Event was declared at 5:45 p.m.
on December 14, 1995 when a railcar carrying an empty spent fuel cask derailed on plant property during preparations for shipment offsite.
The derailment occurred earlier that day between 1;45 and 2:00 p.m.
while plant personnel were transporting the railcar at "walking speed" along a plant spur on tracks used to bring shipments in and out of the Harris plant.
At the time of the event, the railcar Enclosure
was coupled with another car carrying an empty fuel cask.
The two cask cars were also connected to two empty, flatbeds and a caboose for a total of five railcars altogether.
Only four wheels on the affected cask car derailed from the track.
The car itself remained in an upright and stable position during and after the event.
These railcars are owned by CPKL and are used to transport spent nuclear fuel from the Brunswick and Robinson nuclear plants to the Harris plant for semi-permanent storage.
The derailment happened as the railcar traveled over a railroad crossing as it was being prepared for shipment back to Brunswick.
Weakened crossties buried under the crossing allowed the rails to separate under the car's weight.
As 'the rails separated out of gage, four of the car's wheels came off track.
When maintenance personnel noticed the unusual car movement, they immediately stopped the cars, decoupled the caboose and one of the flatbeds to move them to a remote location,'and notified their management.
The licensee later contracted with a railroad repair company to fix the damaged tracks.
Repairs to the tracks included returning the rails to within gage requirements (4 feet - 8 inches to 4 feet - 10 inches distance between rails),
and replacing damaged crossties and spikes.
Another company was contracted to get the car's wheels back on track by use of a standard train wheel jack..
The wheels were all inspected and one pair of wheels was replaced.
Once repairs to the track and railcar were completed, shipment to Brunswick was further delayed due to schedule conflicts created by-the event.
a The inspector discussed this event with contractor personnel hired by the licensee. for track inspection and repairs.
The contractor stated that the tracks had been inspected on December 8 just six days before the event.
The portion of the track that failed was buried and therefore not inspected during the routine inspection in December 1995.
The buried crossties, however, were scheduled to be repaired/replaced in January 1996.
During the December inspection the contractor identified other specific crossties for replacement in January 1996.
The contractor assured the inspector that the tracks conformed to the latest Department of Transportation Track Safety Standards and that the tracks could still be used until the January repairs.
The inspector requested a copy of the track inspection results, but no written copies were available.
The licensee relied on verbal communication of the results from the vendor along with local markings on the tracks.
The inspector's review of the USDOT standards and review of the track markings (green paint on each crosstie in need of replacement)
confirmed that the track was within operating specifications.
The inspector also reviewed track load limits and the -loading created by the shipment.
The weight of the total package railcar plus empty spent fuel cask assembly - was Enclosure
185,000 pounds.
This was within weight limit specifications of 273,000 pounds for the track.
There were no radiological consequences from this event.
As stated above, the car and cask remained in an upright and stable position throughout the incident.
The cask was empty of fuel as it had already been offloaded into the Harris spent fuel pools.
The radioactivity inside the cask was about 434 Curies compared to approximately I million Curies when loaded with fuel.
The shipping container was not disturbed by the derailment.
Consequently, no radioactivity was released.
The NOUE was declared and exited simultaneously since the train was maintained in an upright stable position and presented no threat to public health or safety.
The licensee issued no press releases, however, a courtesy notification was made to the Federal Railroad Administration.
The inspector concluded that the event was caused by track failure and was not due to personnel error or negligence.
The licensee completed a thorough root cause analysis of the event.
Necessary corrective actions were taken to prevent recurrence.
The NRC was still reviewing details of the event declaration and associated delays at the end of this inspection period.
This review will be discussed in NRC IR 400/96-01.
Cold Weather Preparations (71714)
The inspector reviewed the licensee's program and implementation thereof for protecting plant systems against extreme cold weather conditions.
The licensee's actions for cold weather protection were primarily controlled under administrative procedure AP-301, Revision 7, Adverse Weather Operations.
The procedure contained specific guidance for operators to verify operability of freeze protection panels and heaters when ambient temperatures dropped below 35 degrees F.
When these conditions were met, Attachment
to the procedure was completed and maintained by control room operators for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> until either another checklist was completed or temper atures rose above 35 degrees F.
Nore specific instructions were contained in auxiliary operator's rounds guidance sheets, including actions to notify the control room shift supervisor immediately if electric heaters associated with TS-required boric acid flowpaths were found deficient.
Other heat trace circuits were specifically called out in the rounds guidance including those protecting RWST level and turbine first stage pressure instrumentation.
AP-301 actions had already been implemented several times during the current cold season.
In addition to routine walkdowns conducted by operators, the plant employed a variety of means for protecting equipment against cold Enclosure
weather.
For instance, personnel erected plastic tents over the instrument air compressors in the turbine huilding, which is exposed to weather.
Electric heater units were installed inside the instrument air compressor tents to maintain system temperatures above dew point conditions.
The plant listed all work requests associated with AP-301 systems on the Daily Status and Schedule Review, a report used by management for tracking important events and issues.
The inspector noted that less than 10 heat trace work tickets were on the list.
This information, combined with a subsequent walkdown by the inspector, confirmed that much of the backlog from previous years had been eliminated.
During a plant walkdown, the inspector focused on the general condition of heat tracing, electric unit heaters, and licensee identification/correction of deficiencies associated with those and other keepwarm systems.
The inspector identified few deficiencies which were not already being tracked by the licensee's program.
Two heat trace panels had deficiency tags dated mid-December, 1995, which were not included on the DSSR report.
They involved a low current reading for one heat trace circuit, and a tripped circuit breaker for another.
This finding was communicated to work control center personnel who immediately added the tickets to the report.
Other findings, all minor in nature, included a blown indicating lamp on one heat trace electrical panel and a thermostat set off-scale low on an electric heater in the "A" diesel generator room, both of which had not been identified by the licensee.
These observations were provided to licensee personnel for correction.
The inspector concluded that the plant was generally prepared for the cold weather season.
Heater units in areas with boric acid systems were in good condition.
Space heaters were functioning in instrument cabinets.
Heat trace lagging was in generally good condition preventing circuits from being exposed to weather.
Heating equipment in outlying areas including the diesel building and the service water intake structure was in good condition.
Operators were knowledgeable on which heating systems were important and what attributes to observe while conducting rounds, as well as required actions for noted deficiencies.
No violations or deviations were identified in this area.
Review of LERs (92700)
(Closed)
LER 95-013-00, Technical Specification Violation Due to Not Performing Off-Site Power Verification as Required by Action Statement.
This LER discussed the TS violation identified in NRC IR 400/95-18 as NCV 400/95-18-01.
Corrective actions for the TS violation were completed before the NCV was issued and were determined to be Enclosure
acceptable.
VIO 400/95-18-02 was issued for this LER not being written within 30 days of the event.
The licensee's corrective actions for the late LER will betracked under the cited violation.
This LER is closed.
Follow-up - Operations (92901)
1I (1)
(Closed) Violation 400/94-10-01, Failure to Establish and Implement Procedures.
This violation concerned the licensee's failure to initiate appropriate procedure changes prior to performing plant operational activities.
By letters dated July 5, 1994 and July 18, 1994 the licensee admitted the violation as cited, attributed the violation to inadequate procedures and personnel errors, and committed to procedure revisions and personnel training to be completed prior to the September 1995 refueling outage.
The inspector surveyed the licensee's actions and concluded that the licensee had determined the full extent of the violation.
The inspector interviewed licensee personnel, reviewed eight revised operations procedures, revised lesson plans and training records.
The inspector determined that the licensee had taken appropriate and timely actions to correct the violatio and prevent a recurrence of similar,circumstances.
(2)
This violation is closed.
CJ (Closed) Violation 400/95-10-01, Inoperable Steam Generator PORV for Greater than 4 Hours.
This violation concerned the licensee's failure to recognize that a steam generator PORV was inoperable for more than four h'ours.
By letter dated August 7, 1995 the licensee admitted the violation as cited; attributed the violation to personnel errors related to electrical design and configuration control; and committed to walkdown inspections, a wiring modification, a drawing revision and personnel training, all to be completed by August 28, 1995.
In addition to the August 7, 1995 letter, the licensee reported this issue in LER 95-004-00 dated June 23, 1995.
The inspector verified the above corrective actions and concluded that the licensee had determined the full extent of the violation'and taken appropriate and timely corrective actions which should prevent recurrence of similar circumstances.
Enclosure
I
This violation is closed.
Overall, operations were 'performed satisfactorily..
A NOUE was declared when a train carrying an empty spent fuel cask derailed on'lant property.
The licensee's reaction to the event included a thorough root cause investigation.
Control room personnel responded well to a letdown system transient.
The plant was generally prepared for the current cold weather season.
The inspectors identified no violations or deviations in operations.
MAINTENANCE a ~
Maintenance Observation (62703)
The inspector observed work in progress and reviewed the work packages for the following maintenance activities to verify that correct equipment clearances were in effect; work requests were issued, and TS requirements were being followed.
(1)
WR/JO ALDK 001, Loop Calibration of Reactor Coolant Pump "8" Seal Differential Pressure.
WR/JO AGLW 001, Calibration of Seal Leak Off Lo Range Flow Transmitters.
These maintenance activities were accomplished in accordance with procedures LP-P-0155, Revision 2, Reactor Coolant Pump
"1B" Seal Differential Pressure Calibration; and LP-F-0155B, Revision 3, Reactor Coolant Pump "B" Seal Leak Off Lo Range Calibration, by IKC technicians.
The inspector attended both the maintenance and health physics pre-job briefings and observed work inside containment.
The containment entry - done at full reactor power -
was well planned, coordinated, and implemented allowing the entry team to spend a minimum amount of time inside.
The technicians conducting'hese calibrations were properly qualified and knowledgeable.
Properly calibrated tools were used.
Procedure adherence was good.
The coordination of this activity between the control room and the containment building was good despite the remote location and the high noise level.
(2)
WR/JO AMJU 001, Drain and Replace Hydraulic Oil on Auxiliary Feedwater Pump "B" Discharge Flow Control Valve 1AF-34.
WR/JO AKTI 003, Lube Oil Sampling from Auxiliary Feedwater Pump 1B-SB.
Enclosure
'I
The oil draining and replacement activities were authorized by and accomplished in accordance with instructions in the work request/job orders.
The oil sampling activity was accomplished in accordance with procedure PM-H0074, Revision 1/5, Equipment Lube Oil Sampling.
These activities were conducted as part of an AFW system on-line maintenance outage.
The inspector observed field performance and reviewed the completed work package.
The maintenance department mechanics were knowledgeable and properly qualified.
Correct replacement parts and oil were installed.
(3)
WR/JO AGWM 001, Preventive Maintenance on Motor Operated Valve Actuators.
The inspector observed mechanical and I&C preventive maintenance tasks for several Limitorque actuators, including the actuator for safety injection valve 1SI-2.
The activities were conducted in accordance with procedures PH-H0014, Revision 5, Limitorque Inspection and Lubrication; and PH-I0020, Revision 6, Limitorque Operator Inspection.
While observing the work, the inspector noted that maintenance instructions for all types and sizes of Limitorque actuators were included throughout the same procedures.
The maintenance technicians had to pick and choose specific steps in the procedures for the type of actuator on which they were working.
In some cases, information for different actuator types appeared in the same procedure section or data sheet.
Discussions with maintenance personnel indicated that the procedures were sometimes cumbersome and lengthy.
The inspector noted that the licensee's method of including maintenance activities for multiple actuator types/sizes in the same procedure could lead to mistakes, as certain activities were recommended for only certain actuator styles.
Licensee management acknowledged the inspector's comments and indicated that the procedures would be improved.
Workmanship during the above activities was good.
In general, workmanship was good with proper use of procedures, correct replacement parts installed, and proper verification of restored equipment.
No violations or deviations were identified 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 Enclosure
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operability, calibrated equipment was used, and TS requirements were followed.
Test observation and data review included:
OST-1021, Revision 11, Daily Surveillance Requirements, Daily Interval, Modes 1, 2.
This procedure satisfied surveillance requirements contained throughout the Technical Specifications.
The procedure checked various tank levels, room temperatures, and other specific items required to be verified up to four times per day.
This procedure was completed by licensed operators with input provided from either control room indications or field indications obtained by auxiliary operators.
The inspector reviewed the DSR for January 5,
1996.
The inspector verified that all required entries were recorded, and all parameters were within required limits.
(2)
OST-1078, Revision 3/4, Auxiliary Feedwater Pump 1B-SB Operability Test Monthly Interval Modes 1-4.
This surveillance was conducted to demonstrate the operability of the "B" Auxiliary Feedwater Pump and AFW system valve lAF-43 after the completion of oil sampling/replacement conducted under WR/JO AKTI 003 and WR/JO AMJU 001, mentioned in report paragraph 4.a.(2)
above.
The inspector observed the surveillance activities locally at the pump and reviewed the completed work package.
The operator was knowledgeable and properly qualified.
Properly calibrated tools were used.
(3)
OST-1311, Revision 2/1, Auxiliary Feedwater Valves Remote Position Indication Test 2 Year Interval Modes 4-6.
(4)
This surveillance was conducted to 'verify proper position indication of AFW system valve IAF-43 after oil replacement activities conducted under WR/JO AMJU 001 discussed in report paragraph 4.a.(2)
above.
The inspector observed the surveillance, activities at the valve location and reviewed the completed work package.
The operator was knowledgeable and properly qualified.
MST-E0022, Revision 4/1, Emergency HVAC Heater Maintenance and KW Verification.
This surveillance was performed on emergency HVAC units EHC-72 (1B-SB)
and EHC-18 (I-4X-SB) to satisfy the requirements of TS 4.7.6.d.4.
The inspector attended the pre-job briefing, observed all of the surveillance activities locally, and reviewed the completed work package.
Enclosure
The electrical technicians were knowledgeable and properly qualified.
Properly calibrated tools were used.
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.
Effectiveness of Licensee Control in Identifying, Resolving, and Preventing Problems (40500)
CR 96-00048 was generated when test procedure OST-1045, ESFAS'rain
"B" Slave Relay Test quarterly Interval Modes 1-4, did not provide for adequate ESF response'ime testing for three AFW flow control valves.
The rocedure directed o er s to time the valves'ontrollers ns ea o t e va ves themselves.
The valves automatically open on an SI signal.
This procedure had been recently revised after the licensee's Nuclear Assessment Section identified during an audit (see report paragraph 6.f below) that the valves'uto-open feature had not been response time tested.
During performance of the test in mid-December, 1995, the three valves'ontrollers were timed to reach 100 percent demand (as indicated on the main control panel) following initiation of the test signal.
Following the test, the valves were declared operable, and the test signed off as complete.
The next day, the AFW system engineer reviewed the test procedure and identified that the valves'low controllers were timed in lieu of the valves themselves.
Since the valves'esponses are delayed from that of their controllers, the engineer determined that the AFW system response function had not been satisfactorily tested.
The valves remained fu',ly open (their safe accident position) following the test, so system operability was not affected.
However, a tracking EIR was generated until the valves could be satisfactorily tested.
The inspector noted that there have been several instances of missed or inadequate procedures related to testing of the AFW flow control valves.
One such procedural deficiency resulted in a partial safety injection in October 1995.
That incident resulted in a violation for inadequate procedure reviews.
The inspector was concerned that inadequate procedure reviews contributed to the latest incident.
After interviewing the system engineer and the procedure writers, and discussing this event with plant management, the inspector determined that the primary cause of this incident was inattention to detail on behalf of the procedure writer himself.
Standard plant practice for valve time testing was to test the valve's response to a test signal or switch Enclosure
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manipulation - not that of the valve's demand controller.
Operations management counseled the procedure writer on the importance of following standard plant practice in this regard.
The inspector concluded the licensee's corrective action to be appropriate.
d.
Follow-up - Maintenance (92902)
(Closed) Violation 400/95-10-02, Failure to Adequately Implement Procedure AP-501.
This violation concerned the licensee's failure to implement requirements of referenced documents in the performance of a maintenance procedure.
By letter dated August 7, 1995, the licensee admitted to the violation as cited; attributed the violation to personnel errors related to inadequate review of reference documents during procedure preparation; and committed to conducting an evaluation of the proscribed material, review of documents, revision of fact sheets, and personnel training all to be completed before August 28, 1995.
The licensee determined by engineering evaluation that the proscribed material was in fact acceptable for the application cited in the violation.
The August 7, 1995 response had been reviewed and found acceptable by Region II.
The inspector determined that the licensee had taken appropriate and timely actions to correct the violation and prevent a recurrence of similar circumstances.
This matter is considered closed.
Overall maintenance and surveillance activities were conducted well.
ENGINEERING Onsite System Engineering (37551)
Sin le Failure Potentiall Resultin in an Uncontrolled Release of Radioactive Materials.
The inspector reviewed ESR 95-0294, Revision 0, KYPIPE Calculation of ESW Pressures Immediately Downstream of Containment Fan.
The engineering document evaluated a single failure scenario in the ESW system in which system header pressure inside containment could drop below containment accident pressure, and below the containment pressure at which operators were directed to take restoration/compensatory actions.
During an accident resulting in high containment pressure, this scenario, coincident with a leaking containment fan cooler tube (whose cooling is supplied by the ESW system),
could result in an uncontrolled release of radioactive material through the ESW discharge canal.
Enclosure
The inspector knew that the contai"nment fan cooler tubes had leaked in the past and discussed this item with system engi;.eers.
The engineers described the scenario as a common failure affecting both the emergency service water booster pump and an orifice bypass valve in the same train.
The orifice bypass valve normally shuts on an ESW booster pump start which provides a back pressure to maintain the header above pressures accounted for in EOPs.
However, a relay contact failure could cause the ESW booster pump to remain shutoff and the associated orifice bypass valve to remain open.
This would allow service water header pressure to drop to 13 psig inside containment, which is below the containment pressure (25 psig) at which operators were directed by EOPs to take compensatory actions.
The resultant pressure differential could cause inleakage into the ESW header (from the accident containment atmosphere)
which would lead to a radioactive material release to the environment.
Because of this potential, engineers evaluated the effects of known containment fan cooler leaks from the past to determine whether or not
CFR 100 release limits would have been exceeded.
While it was determined that regulatory release limits would not be exceeded, the inspector remained concern that the above scenario could result in "any" uncontrolled release of radioactive material, since such a situation would be reportable per
CFR 50.72 requirements.
To address this concern, plant engineers referred the inspector to two procedures which covered sampling requirements for the ESW system while it was in service.
These procedures (CRC-001, Revision 013, SHNPP Environmental and Chemistry Sampling and Analysis Program; and CRC-155, Revision 9, Chemistry 'Control of Circulating Water, Service Water, and Cooling Tower Basin) directed technicians to analyze grab samples taken from the ESW discharge headers (and from their discharge points at the auxiliary reservoir)
whenever the ESW system was in service.
Additionally, the procedures both required that the sampling frequency be increased to daily whenever a service water booster pump failed while discharging to the auxiliary reservoir.
The chemistry department was notified any time ESW was placed in service by operations personnel as directed by operating procedure OP-139, Revision 6, Service Water System.
To address the problem with operator actions following the single failure, Emergency Operating Procedure EOP-FRP-J. 1, Revision 9, Response to High Containment Pressure, was developed to have operators verify the ESW booster pump is running and its orifice bypass valve shut when containment pressure reaches 10 psig.
In the response-not-obtained column of this step, operators are directed to have the ESW system sampled.
This action would thus occur before containment pressure exceeded the service water header pressure of 13 psig calculated for the failure scenario.
Enclosure
The inspector concluded that the licensee's sampling program sufficiently minimized the potential for uncontro'.led radioactive releases from the above scenario.
Additionally, the licensee's action to revise the functional restoration procedure EOP-FRP-J.
1 was appropriate.
System engineering activities were performed adequately.
The inspectors identified no violations or deviations in the systems engineering area.
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 hazards existed.
On two occasions, the inspector observed ladders not stored in their designated locations.
These ladders were placed near safety-related equipment and not tied off.
The inspector informed plant personnel who moved the ladders to their proper storage racks.
These incidents were minor in significance and have not been a recur ring problem.
However, the inspector noted that more attention to plant guidelines in this area was warranted.
During routine maintenance and surveillance observations discussed in report paragraph 4, the inspector identified several other material deficiencies including blown out illuminating lamps, latching dogs on HVAC panel doors missing, and mounting screws for fan belt guards missing.
Specific findings were communicated to plant personnel who initiated repairs.
Although the above were all relatively minor material condition deficiencies, their shear number related to a small number of activities observed and demonstrated a weakness in the licensee's program to identify and correct minor material deficiencies.
b.
C.
Overall, housekeeping in the plant and specifically in the containment building was satisfactory.
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.
No radiological findings were identified.
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 properly installed.
Enclosure
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 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 inspectors observed fire protection activities, staffing 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.
There were no emergency preparedness exercises or drills conducted this inspection period.
Licensee Self Assessment (40500)
The licensee's Nuclear Assessment Section completed an assessment of the licensee's implementation of ESF response time testing requirements.
The inspectors reviewed the report, H-TS-95-01, ESF Response Time Testing, dated December 19, 1995, and concluded that the assessment was thorough and resulted in substantive issues.
One finding resulted in a pending LER to be described in NRC IR 400/96-01.
Those issues not related to safety significant findings discussed programmatic weaknesses in need of improvement.
The plant has launched several corrective actions or root cause investigations to address the concerns brought forth by this assessment.
The inspectors identified no violations or deviations in the Nuclear Assessment area.
Follow-up - Plant Support (92904)
(Closed)
URI 400/95-13-01, Potential Falsificati'on of Radiological Survey.
The NRC completed its review of this incident described in detail in NRC IR 400/95-13.
As discussed in a NRC letter to the licensee dated December 13, 1995, the NRC will take no enforcement action Enclosure 4'-'
~
with respect to CP8L.
This decision was based on the licensee's self-identification, thorough investigation, an'd prompt corrective actions.
The violation also appeared to be the isolated act of one individual who held a low level position in the licensee's overall organization.
The NRC issued a letter to the involved individual re-enforcing the agency's expectat'ions regarding completeness and accuracy of information.
This item is closed.
The inspectors found plant housekeeping and material condition of components to be satisfactory, except as noted above.
The licensee's adherence to radiological controls, security controls, fire protection requirements, emergency preparedness requirements and TS requirements in these areas was satisfactory.
A Nuclear Assessment Section report on ESFAS response time testing was thorough.
The inspectors identified no violations or deviations in the plant support area.
EXIT INTERVIEW VIO 'ailure to Establish and Implement Procedures, paragraph 3.e.(1).
The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on January 12, 1996.
During this meeting, the inspectors summarized the scope and findings of the inspection as they are detailed in this report.
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 t'o and Refe ence 94-010-01 Closed 95-010-01 95-010-02 Closed Closed VIO VIO Inoperable Steam Generator PORV for Greater than 4 Hours, paragraph 3.e.(2).
t Failure to Adequately Implement Procedure AP-501, paragraph 4.d.
95-013-00 Closed LER Technical Specification Violation Due to Not Performing Off-Site Power Verification as Required by Action Statement, paragraph 3.d.
Enclosure
95-013-01 Closed
URI Potential Falsification of Radiological Survey, paragraph 6.g.
ACRONYMS AND INITIALISMS AFW CFR CP&L CR CVCS DSR DSSR EIR encl EOP ESF ESFAS ESR ESW FR HVAC IKC IR LER MST NCUC NCV NOUE NPF NRC NRR OST PCV PDR PORV PSIG RI I RWST SI SSPS TS URI USDOT-VIO WR/JO-Auxiliary Feedwater Code of Federal Regulations Carolina Power 5 Light Condition Report Chemical and Volume Control System Daily Surveillance Requirement Daily Status and Schedule Review Equipment Inoperable Record Enclosure Emergency Operating Procedure Engineered Safety Feature Engineered Safety Feature Actuation System Engineering Service Request Emergency Service Water Federal Register Heating, Ventilation and Air Conditioning Instrumentaion and Control
[NRC] Inspection Report Licensee Event Report Maintenance Surveillance Test [procedure]
North Carolina Utilities Commission Non-Cited Violation Notice Of Unusual Event Nuclear Production Facility [a type of license]
Nuclear Regulatory Commission Nuclear Reactor Regulation Operations Surveillance Test [procedure]
Pressure Control Valve Public Document Room Power Operated Relief Valve Pounds per Square Inch, Gauge Region Two
[NRC Office]
Refueling Water Storage Tank Safety Injection Solid State Protection System Technical Specification [part of the facility license]
Unresolved Item United States Department of Transportation Violation [of NRC requirements]
Work Request/Job Order Enclosure
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