ML18005A385

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Insp Rept 50-400/88-06 on 880220-0320.Violation Noted.Major Areas Inspected:Licensee Action on Previous Enforcement Matters,Operational Safety Verification,Monthly Surveillance Observation & Monthly Maint Observation
ML18005A385
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 04/01/1988
From: Fredrickson P, Maxwell G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18005A383 List:
References
50-400-88-06, 50-400-88-6, NUDOCS 8804120087
Download: ML18005A385 (12)


See also: IR 05000400/1988006

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report No.:

50-400/88-06

Licensee:

Carolina

Power and Light Company

P. 0.

Box 1551

Raleigh,

NC

27602

Docket No.:

50-400

Facility Name:

Harris

1

License No.:

NPF-63

'nspection

Conducted:

February

20

March 20,

1988

Inspector:

G.

F.

axwell

Approved by:

6

-Ql+

P.

E.

edri ckson,

Section Chief

Division of Reactor Projects

silas

Date Signed

~ 1)SS

Date Signed

SUMMARY

Scope:

This routine,

announced

inspection

involved inspection

in the areas

of

Licensee Action on Previous

Enforcement Matters,

On-Site Follow-up of Events

and Subsequent

tltritten Reports of Nonroutine Events,

Operational

Safety Verifi-

cation, Monthly Surveillance Observation,

and Monthly Maintenance

Observation.

Results:

In the areas

inspected,

one violation was identified, "Failure to

Require

EOPs to be Consistent with the

FSAR" - Paragraph

3.b.

8804120087

SS0401

PDR

ADOCK 05000400

9

DCD

REPORT DETAILS

1.

Persons

Contacted

Licensee

Employees

J.

M.

G.

L.

J.

L.

C.

S.

D. L.

R.

B.

R. A.

Collins, Manager,

Operations

Forehand,

Director,

QA/QC

Harness,

Plant General

Manager

Hinnant,

Manager of Maintenance

Tibbitts, Director, Regulatory

Compliance

Van Metre, Manager,

Harris Plant Technical

Support

Watson,

Vice President,

Harris Nuclear Project

Other

licensee

employees

contacted

included

technicians,

operators,

mechanics,

security

force

members,

engineering

personnel

and office

personnel.

2.

Exit Interview

The inspection

scope

and findings were

summarized

on March 21,

1988, with

the Plant

General

Manager,

Operations.

The inspector described

the areas

inspected

and discussed

in detail

the inspection

findings listed below.

Dissenting

comments

were

not received

from the

licensee.

Proprietary

information is not contained in this report.

Note:

A list of abbreviations

used

in this report

is contained

in

Paragraph

8.

3.

Licensee Action on Previous

Enforcement Matters (92701)

a

0

(Closed)

Unresolved

Item" 50-400/88-03-01,

ESW Seal

Water.

The

licensee

reported

and

documented

a condition

on

LER 88-006

concerning

both

emergency

service

water

systems

potentially

being

inoperable

due to isolation

valve failures

and

a design deficiency.

The initial NRC notification identified only the inoperability of the

seal

water

booster

pump

isolation

and

check

valves.

However,

subsequent

licensee

evaluation of the design

of the

ESW seal

water

booster

pumps revealed

the following:

Both

ESW

seal

water

booster

pumps

are

nonsafety-related

and

nonseismically designed..

"Unresolved

items are matters

about which more information is required to

determine

whether they are acceptable

or may involve violations or deviations'

Those

sections

of the

ESW seal

water booster

pump system which

are

nonsafety

and

nonseismic

include

the

pump

casings,

the

piping

between

the

pump

suction

and

the

suction

isolation

valves,

and

the

piping

between

the

pump

discharge

and

the

discharge isolation check valves.

The field initiated design

changes

which ultimately authorized

the installation of the

ESW seal

water booster

pump system.

The

design

included

a

cross

connect

piping which

was installed

between

the manually-operated

pump discharge

isolation valves

and the

solenoid-operated

isolation

valves.

This cross

connect

piping did

not have

an isolation valve, therefore

both of the safety train

ESW

seal

water piping

systems

could

have

been

affected

by

a

single

passive

failure because

the emergency'safety)

supplied

seal

water

trains

were

connected

to

each

other

through this

cross

connect

piping.

The licensee

reported

preceding

supplemental

information to the

NRC

Outy Officer on February

25,

1988,

and has included it as

a part of

its evaluation

concerning

the event

which was initially reported

on

February

8.

The

resident

inspector

discussed

the

above

design

configuration with NRC RII and

NRR management

and concluded that the

licensee's

assessment

as described

in

LER 88-006 is acceptable,

.that

is, their conclusion that the potential for a passive failure in the

ESW seal

water system is improbable

and unrealistic.

The licensee

has

made design

changes

to remove both of the nonsafety

and

nonseismic

ESW

seal

water

booster

pumps

from the

seal

water

system.

The

inspector will monitor the

progress

of the

changes

which are

planned for this system.

This item is closed.

(Closed)

Unresolved

Item

50-400/88-03-02,

Emergency

Operating

Procedures.

The inspector

evaluated

the information contained

in

LER 88-001

and

interviewed

site

technical

support

personnel

and

other

licensee

representatives

who were familiar with the details of this

LER.

As a

result

the

inspector

determined

that

on

September

24,

1986

the

licensee

revised

Table

6.3.2-6

of the

FSAR,

per advice

from site

technical

support

personnel.

The

FSAR

was

revised

to

require

isolating

one

of the

two

low pressure

safety

injection

header

containment

valves

1SI-340 or 1SI-341, if the plant had experienced

a

LOCA and the

RHR system

was taking

a suction

on the containment

sump

and discharging into the reactor coolant cold legs

and

was simulta-

neously

supplying

the

high

head

safety injection

pumps.

The

FSAR

revision

was

recommended

after

site

technical

support

personnel

calculated

the

pumping capabilities

of

a

single

RHR

pump.

They

determined that one

pump

may not

be capable

of supplying sufficient

flow to both cold legs

and two SI pumps.

The calculations

show that

the

RHR pump curves

run out at about

4500

gpm, for a single

RHR pump.

The most conservative

calculations

reveal

that the flow rate

needed

to be approximately

5000

gpm with the valve configuration

allowing both

1SI-340

and

1SI-341

to

be

open

and

both

SI

pumps

running.

After the

FSAR was revised to include the

new val've configuration

(closing

1SI-340 or 1SI-341),

the affected site

procedure

EOP-EPP-

010, titled, "Transfer to Cold Leg Recirculation",

was then required

to be revised also,

to be consistent with the

FSAR.

On December

22,

1986 the

EOP was revised.

The procedure

remained

unchanged,

leaving both

1SI-340

and

1SI-341

open with two SI

pumps

running with each of the

pumps

and

valves

being

supplied'y

a

single

RHR

pump.

The

licensee

failed

to

recognize

that the

EOP

had not

been

properly

revised

until

about

December

3,

1987.

The potential

significance of the error

was

not

realized until

ONS followed-up on

an

INPO notification and found that

this deficiency existed in the

EOP.

On December

10,

1987

an Advanced

Change

was

made to the

EOP consistent with the September

1986 require-

ments of the

FSAR, Table 6.3.2-6,

The inspector

reviewed site Administrative Procedure

AP-006,

Rev. 7,

titled "Procedure

Review

and Approval".

Section

5.7 requires

that

the "procedures

must

be technically accurate

to safely perform the

intended activity".

Failure to require

EOP-EPP-010

to be consistent with the

FSAR for

the time between

September

24,

1986 until December

10,

1987, could

have resulted

in the plant's safety injection system

being in a

valve

configuration

which

may

have

resulted

in

an

unsafe

plant

condition without operator

action.

Unresolved

Item 50-400/88-03-02

and its associated

LER 88-001

are closed,

and

a violation will be

issued,

Failure

to

Require

EOPs

to

be

Consistent

with the

FSAR,

50-400/88-06-01.

4.

On-Site

Follow-up of Events

and

Subsequent

Written Reports of Nonroutine

Events

(92700,

93702)

The inspector

evaluated

the following LERs to determine if the details

complied

with

licensee

requirements,

adequately

described

the

event,

identified the root cause

of the event,

described

appropriate

corrective

action,

and

addressed

any potentially generic

implications.

When

the

licensee

identified violations,

those

LERs

were

reviewed

in accordance

with the

NRC Enforcement Policy.

a.

(Closed)

LER 87-034,

LER 87-52

and

LER 87-55,

T.S.

Violation

Containment

Personnel

Air Lock.

The conditions

which

caused

these

LERs

have

been

documented

and

identified

as

violations

in

Inspection

Reports

50-400/87-21

and

50-400/87-40.

These

LERs are

considered

closed

and will be tracked

as Violations 50-400/87-21-01

and 50-400/87-40-01.

(Closed)

LER 87-041,

Plant Trip Due to Loss of Instrument Air Caused

by Improperly Prepared

Valve Restoration

Lineup; Personnel

Error.

This

Event

was

documented

and identified

as

a violation in RII

Inspection

Report 50-400/87-31.

This

LER is considered.

closed

and

will now be tracked

as Violation 50-400/87-31-01.

(Closed)

LER 87-042,

Reactor Trip Incorrect

Fuse Pulled;

Personnel

Error.

This

Event

was

documented

and identified

as

a violation in RII

Inspection

Report 50-400/87-26.

This

LER is considered

closed

and

will be tracked

as Violation 50-400/87-26-02.

(Closed)

LER 87-045,

Personnel

Error

Caused

Injection of Safety

Injection Accumulators During Plant Cooldown and Depressurization.

This

LER has

been

upgraded

to

a violation and is documented

in RII

Inspection

Report 50-400/87-26.

This

LER is considered

closed

and

will now be tracked through

as

a Violation 50-400/87-26-01.

(Closed)

LER 87-053,

Plant Operating

in

an Unanalyzed Condition

Due

to a Failed

Open

Blowdown Isolation Valve.

This Event involved

a steam generator

blowdown valve being inoperable

(stuck open) for at least

29 days while the plant was at power.

The

Event was documented

and identified as

a Violation in RII Inspection

Report

50-400/87-34.

This

LER is closed

and will be

tracked

as

Violation 50-400/87-34-01

(Closed)

LER 87-058,

Reduction

in Reactor

Coolant

Inventory

Due to

Valve Failure in the

RCS Head Vent System During Testing.

This Event was documented

in two RII Inspection

Reports,

50-400/87-37

and 50-400/87-40.

The specific violations which identified the valve

failures are

50-400/87-37-01

and

50-400/87-40-,03.

Therefore,

this

LER is considered

closed.

(Closed)

LER 87-062

and

LER 87-063.

Both

of

these

Events

involved

either

operator s

not

following

procedures

or not having

an adequate

procedure.

They were documented

and identified in RII Inspection

Report

50-400/87-40.

This

LER is

closed

and will be tracked

as Violation 50-400/87-40-02,

Failure to

Follow Operations

Procedures.

h.

(Cl osed)

LER 88-001,

Emergency

Operating

Pr ocedure

Deficiency

for

Switchover to Recirculation After a Loss of Coolant Accident.

The details for the closure of this

LER are

contained

in Paragraph

3.b, of this report and will be tracked

as Violation 50-400/88-06-01.

5,

Operational

Safety Verification (71707,

71710)

Plant Tours

The inspector

conducted

routine plant tours during this inspection

period to verify that the

licensee's

requirements

and

commitments

were

being

implemented.

These

tours

were

performed to verify that

systems,

valves

and breakers

required for safe plant operations

were

in their correct position; fire protection equipment,

spare

equipment

and materials

were

being

maintained

and

stored

properly;

plant

operators

were

aware of the current plant status;

plant operations

personnel

were

documenting

the status

of out-of-service

equipment;

security

and

health

physics

controls

were

being

implemented

as

required

by procedures;

there

were

no

undocumented

cases

of unusual

fluid leaks,

piping vibration,

abnormal

hanger

or seismic restraint

movements;

and all

reviewed

equipment

requiring

calibration

was

.currents

Tours

of

the

plant

included

review of site

documentation

and

interviews with plant personnel.

The inspector

reviewed

the shift

foreman's

log, control

room operator's

log, clearance

center tag out

logs,

system

status

logs,

and control

status

board.

During these

tours the inspector

noted that the operators

appeared

to be alert and

aware of changing plant conditions.

The inspector evaluated

operations shift turnovers

and attended shift

briefings.

These briefings

and turnovers

provided sufficient detail

for the next shift crew.

The

inspector verified that various

plant

spaces

were

not in

a

condition

which would

degrade

the

performance

capabilities

of any

required

system or component.

Site security

was evaluated

by, observing

personnel

in the protected

and vital areas

to ensure that these

persons

had the proper authori-

zation

to

be

in

the

respective

areas.

The

security

personnel

appeared

to be alert and attentive to their duties

and those officers

performing

personnel

and

vehicular

searches

were

thorough

and

systematic.

Responses

to security

alarm conditions

appeared

to

be

prompt and adequate.

b.

Main Feedwater

Regulating

Yalve

On March 9,

1988, while operating

at

100 percent

power, the reactor

tripped.

The licensee

reported the event to the

NRC Duty Officer as

required

by 10 CFR 50.72.

The cause of the event

was attributed to

a

loose

cap

on

one of the replaceable

fuses

which protects

the

"B"

steam generator

feedwater regulating valve's modulating circuit.

The

loose

fuse

cap

demonstrated

the

same

symptoms

as

an

open circuit

would have,

in that the modulating circuit lost power which allowed

the

regulating

valve

to fail shut.

When

the

valve failed shut,

feedwater

was lost for the "B" steam generator,

resulting in low "B"

steam

generator

level.

The reactor protective circuits reacted

to

protect the plant from the

steam flow-feed flow mismatch conditions.

As

a result,

a reactor, trip signal

was generated,

causing

a reactor

trip.

When the event occurred,

all of the

required

plant

safety

equipment

started

and

performed

as

expected.

The

plant

was

stabilized

and held in hot standby

(Mode 3) until the

cause

of the

event

was discovered

and corrected.

The

licensee

replaced

all of the

"replaceable"

fuses

which were

installed in the

main feedwater

regulating circuits.

The

new fuses

have

fixed

end

caps

which

should

prevent

this

condition

from

occurring again.

The licensee is evaluating

a program to replace all

of the "replaceable"

fuses

located in the plant with fuses which have

fixed end caps.

On March

10,

1988,

the plant

was returned

to power

and

was

placed

back

on the

CPKL electrical

power grid.

6.

Monthly Surveillance

Observation

(61726,

61700)

The inspector

witnessed

the licensee

conducting

maintenance

surveillance

test activities

on safety-related

systems

and

components

to verify that

the licensee

performed the activities in accordance

with licensee

requirements.

These observations

included witnessing

selected

portions of

each

surveillance,

review of the surveillance

procedure

to

ensure

that

administrative

controls

were

in force,

determining

that

approval

was

obtained prior to conducting

the surveillance

test

and

the

individuals

conducting

the

test

were qualified in accordance

with plant-approved

procedures.

Other observations

included ascertaining

that test instrumen-

tation

used

was

calibrated,

data

collected

was within the

specified

requirements

of Technical

Specifications,

any identified discrepancies

were properly

noted,

and

the

systems

were correctly returned to service.

The following specific activities were observed:

OST-1104

was conducted

on the "C" steam generator

blowdown isolation

valve

1BD-.39.

The test

was

conducted

to assure

operability

of the

valve upon completion of valve repairs.

The test verified that the

valve could

be stroked

in less

than the

60 seconds

specified

by the

OST.

The actual

stroke time was less

than

35 seconds.

This

OST is

a

part of the

ISI valve

inspection

program

required

by

TS Section 4.0.5.

MST-I0250;

Rev.

0,

Reactor

Coolant

System

Cold Over Pressurization

Instrument

(P-0440)

Operational

Test

was

conducted.

The

test

verified satisfactory

compliance with TS Section 4.4.9.4. 1.a.

The

primary purpose of the test

was to determine that the instrumentation

loop for the cold reactor

coolant over pressure

protection

system

was

operable.

Loop Calibration Procedure

LP-F-0943,

Rev.

0, titled Loop Calibration

of Charging

Pump Safety Injection

Flow to Boron Injection Tank was

completed.

The test verified complianqe

with

FSAR Section 9.3.4;

Specifically,

the test verified that

the

instrumentation

for the

boron injection tank was operable

and accurate.

7.

Monthly Maintenance

Observation

(62703,

62700)

The inspector

reviewed

the licensee's

maintenance

activities during this

inspection

period to verify the following:

maintenance

personnel

were

obtaining

the

appropriate

tag

out

and

clearance

approvals

prior to

commencing

work activities, correct'ocumentation

was available

for all

requested

parts

and material prior to use,

procedures

were available

and

adequate

for the work being

conducted,

maintenance

personnel

performing

work activities

were qualified to accomplish

these tasks,

no maintenance

activities reviewed

wet e violating any limiting conditions for operation

during the specific evolutions;

the required

QA/gC reviews

and

gC hold

points

were

implemented;

post-maintenance

testing

activities

were

completed,

and

equipment

was

properly

returned

to service

after

the

completion of work activities.

The

following activity

was

evaluated

during

the

inspector's

routine

monthly maintenance

observation:

Maintenance

personnel

changed

one

of

the

neutron

flux incore

detectors.

The detector's

output signal

was not consistent

with the

signals

from the

remaining

four incore detectors.

The

work was

authorized

by

WR

88-ACGB1

and,

required

removing

the

"E" incore

detector

from service

and replacing it with

a

new detector.

After

completing the replacement

the

new detector

was tested

and

found to

be acceptable

and placed into service.

8.

List of Abbreviations

CPS(L

EOP

ESW

FSAR

Carolina

Power

and Light Company

Emergency Operating

Procedures

Emergency Service Water

Final Safety Analysis Report

0

GPM

INPO

ISI

LER

LOCA

MST

NRC

NRR

ONS

OST

RCS

RHR

RII

SI

TS

WR

Gallons

Per Minute

Institute of Nuclear Power Operations

Inservice Inspection

Licensee

Event Report

Loss of Coolant Accident

Maintenance

Surveillance

Test

Nuclear Regulatory

Commission

Nuclear Reactor Regulation

Onsite Nuclear Safety

Review Group

Operational

Surveillance

Test

Reactor Coolant System

Residual

Heat

Removal

Region II

Safety Injection

Technical Specifications

Work Request

P'~

i