ML18005A511
| ML18005A511 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/16/1988 |
| From: | Fredrickson P, Maxwell G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18005A505 | List: |
| References | |
| 50-400-88-11, NUDOCS 8807130322 | |
| Download: ML18005A511 (14) | |
See also: IR 05000400/1988011
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, NW.
ATLANTA,GEORGIA 30323
Report No.:
50-400/88-11
Licensee:
Carolina
Power
and Light Company
P. 0.
Box 1551
Raleigh,
NC
27602
Docket No.:
50-400
Facility Name:
Harris
1
Inspection
Conducted:
April 20
May 20,
1988
License No.:
Inspector
G.
F
Max
e
Date Signed
Approved by:
P.
E. Fredrickson,
Section Chief
Division of Reactor
Projects
Date Signed
SUMMARY
Scope:
This routine,
announced
inspection
involved inspection
in the areas
of Operational
Safety Verification, Monthly Maintenance
Observation,
and
Emergency
Response
Facilities Appraisal.
Results:
In the
areas
inspected,
one violation was identified
Failure to
Control
System
Configuration
During
a
Test
of
the
Solid
State
Protection
System
Paragraph
2.b.
8807l30322
880622
ADOCN. 05000400
8
PNU
REPORT
DETAILS
1.
Persons
Contacted
Licensee
Employees
J.
M. Collins, Manager,
Operations
G.
L. Forehand,
Director,
QA/QC
J.
L. Harness,
Plant General
Manager
C.
S. Hinnant,
Manager of Maintenance
J.
R. Sipp,
Manager,
Environmental
and Radiological
Control
D.
L. Tibbitts, Director, Regulatory
Compliance
R.
B.
Van Metre,
Manager,
Harris Plant Technical
Support
R. A. Watson,
Vice President,
Harris Nuclear Project
Other
licensee
employees
contacted
included
technicians,
operators,
mechanics,
security
force
members,
engineering
personnel
and
office
personnel.
and
initialisms
used
throughout
this
report
are
listed
in
paragraph
6.
2.
Operational
Safety Verification (71707,
71710,
93702)
Plant Tours
The inspector
conducted
routine plant tours during this inspection
period to verify that the
licensee's
requirements
and
commitments
were
being
implemented'hese
tours
were
performed to verify the
following:
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'as
current.
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,
chemistry
and
health
physics. logs,
and
control
status
board.
During these'ours
the iospector
noted that
the
operators
appeared
to
be alert
and
aware
of changing
plant
conditions.
The
inspector
evaluated
operations
shift turnovers
and
attended
shift briefings.
He
observed
that
the
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.
Solid State Protection
System Testing
On
April 22,
during
a
routine
daily
review of
EIRs,
licensee
Regulatory
Compliance
personnel
identified
an
instance
where
was violated.
The event
occur red
on April 19, with the plant
at
100% power.
The "A" train automatic trip logic, which is part of
the
SSPS,
was
being tested.
The
SSPS test
began
at
1: 10 p.m.,
and
ended at 2:26 p.m., lasting
a total of one hour,
16 minutes.
Mhen
the
"A" train
SSPS
test
was
being
conducted,
the
following
mechanical
components
associated
with the "8" train were not fully
operable:
The
"8"
emergency
service
water
pump
had its
power
supply
circuit breaker
"racked
out".
The breaker
was
racked
out to
allow maintenance
personnel
to conduct
a loop calibration
on
a
discharge
pressure
transmitter.
This work started at 10:00 a.m.,
on April 19 and was completed at 2:35 p.m.
The
control
room "8" train
emergency filtration system
was
shutdown for preventive
maintenance
on the power breaker cubicle
and
a surveillance
test to measure
heater
capacity.
Due to the
work on
the
breaker
cubicle,
the
"8" control
room
emergency
filtration system
could
not
have
functioned until its
power
breaker
wad
reclosed.
This
work started
at
8:00 a.m.,
on
April 19 and was completed at 3:45 p.m.
The
"8" train
reactor
auxiliary
building
emergency
exhaust
system
had
two outstanding
clearances
against it.
The
work
associated
with
these
clearances,had
been 'ompleted.
The
clearance
tags
were
in
the
process
of being
removed;
at
2:56 p.m.,
on April 19 they were removed.
TS Table 3.3-3,
Action Statement
14,
Page
3/4 3-26,
allows
one of
the
two
SSPS trains to
be in the test
mode for up to
two hours,
provided
the
other train
is
If the
other train
is
as
on April 19,
then
TS 3.0.3,would
apply.
when
entered,
requires
that
the associated
Action requirements
be
completed within one
hour
or
steps
should
be
taken
to place
the
plant in
a reduced
mode.
As noted
above,
the plant
was operating
under
the condition of
for greater
than
one
hour,
and
operators
failed to recognize
during that time that the plant
was
required
to begin reducing
power to change its mode of operation.
The inspector
evaluated
the shift foreman's
log
and
EIRs for each
time that
MST I001 (Train "A" SSPS Actuation Logic and Master Relay
Test)
and
MST I0320 (Train "B" SSPS Actuation Logic and Master Relay
Test)
were
implemented
during
the past twelve months
on the "A" and
"B" SSPS trains.
Records
show that the
"B" train
SSPS
tests
were
conducted
during
1987
on
May 15, July 26,
September
22,
November
16,
.'and during
1988
on January
18
and
March 21.
When these
tests
were
conducted,
all
of
the
associated
"A" train
SSPS
equipment
was
available for operation.
Records
indicate
that
the
corresponding
"A" train
SSPS
tests
were
conducted
during
1987
on
June
18,
August
18,
October
23
and
December
17,
and
during
1988
on
February
19.
The
"A" train test
on August
18,
1987,
was
conducted
between
8:55 a.m.
and
10:20 a.m.
The
EIR and shift foreman's
logs for the
"B" train equipment
show
that the "B" train
ESW pump was in an inoperable
status
from 8:57 a.m.,
on August 17,
1987, until 4:55 p.m.,
on August 19,
1987;
thus,
the
unit
had
entered
during this test
also.
The
pump
was
declared
due to
a packing
replacement
for its associated
screen
wash
pump.
The screen
wash
pump provides
seal injection flow-
for the associated
ESW pump.
Consequently,
there
have
been
at least
two separate
instances
where
the plant
was
operating
unknowingly
under
the
requirements
of
TS 3.0.3 while the
SSPS
system
was being tested.
Normally,
operations
pe'rsonnel
have
relied
on
the
following two
methods of assuring
that
a
system is not placed
in
a configuration
where
redundant
components
are
simultaneously
and/or inadvertently
out of service:
The first method
involves
the
applicatio'n
of the
Operations
Management
Manual
procedures:
OMM-001,
Rev.
4,
Operations-
Conduct of Operations,
and
OMM-003, Rev.
2, Equipment Inoperable
Record.
These
procedures
require
the shift foreman to review
Work Requests
of other activities in general,to
assure
compliance
with TS requirements.
,When carrying out this task
he normally
reviews the open
EIRs and,
when in doubt,
asks his subordinates
and peers if they
know of any
reasons
that
a job, test,
etc
,
should not be conducted.
The
second
method involves the
use of Operations
Work Procedures
when conducting
complex plant system
and logic testing.
In this
application,
an
OWP is
used
to establish initial plant/system
configuration for
a
surveillance
test;
then
once
testing
is
complete,
the
OWP returns
the plant/system
to normal.
Usually,
these
OMPs contain specific cautions either by directly cautioning
the procedure
user and/or through specific procedure application.
The procedure
may contain specific checklists or steps
which by
application
would prevent
an inadvertent
defeat of a system or
component's
safety function.
Procedure
OMM-003,
noted
under
the first method
described
above,
provides
guidance
to operations
clearance
personnel.
Its purpose is
to ensure
compliance with
LCOs.
As found in the
TS, this includes
identification,
tracking,
evaluating,
and initiating the
reports
which may be required
by the
LCOs.
However, it should
be noted that
OMM-003 does
not contain
the specific cautions
and/or checklists,
etc.,
which
may
be
contained
in
an
OWP
~
Operations
clearance
personnel
have relied
on the
OWPs to contain sufficient safety nets
to prevent
inadvertent
loss
of
two
redundant
components
during
testing.
Therefore,
they apparently
did not question
allowing the
SSPS
train
"A" tests
to
be
conducted
on
August 18;
1987,
or
on
April 19,
1988,
even
though
some
of the
"B" train
SSPS
activated
equipment
was out of service.
These
events
occurred
because
operations
personnel
did not realize
that
when- actuation
logic equipment
in
an
SSPS train is placed out
of service, all emergency
equipment for the opposite
SSPS train must
be available.
The associated
Operations
Work Procedure,
OWP-RP-17,
Reactor Protection Automatic Trip Logic,
Rev.
1,
should
have
helped
prevent
this
condition
from occurring,
but did not specifically
address
the requirement for redundant train equipment
being operable.
The inspector
evaluated, eight of the remaining
OWPs to assure that,
as
applicable,
they contained
statements
cautioning
operators
that
redundant
equipment
must
be
when
the
OWPs
are
being
conducted.
Those procedures
evaluated
are
as follows:
OWP-RP-16,
Rev.
1, Reactor Trip Breaker;
OWP-AF-Ol, Rev.
Pump
OWP-AF-02,
Rev.
Pump
OMP-AC-01,
Rev.
1,
AC Electrical Uninterrupted
Power Supply
Channel I;
OWP-CS-Ol,
Rev.
1,
Chemical
and
Volume Control
System Charging
Pump
OWP-CT-01,
Rev.
1, Containment
Spray
Pump lA-SA;
OWP-DG-01,
Rev.
1, Diesel Generator
Number
1A-SA; and
OWP-ESF-01,
Rev.
1,
Containment
Pressure - Circuit
Components.
The procedures
implemented
by the licensee failed to assure
that the
plant
was maintained
in
a
safe configuration
when the
SSPS
system
was .being
tested.
The
inspector
informed
the
licensee
that
the
preceding
examples
demonstrate
that procedures
for controlling tests
conducted
on
the
SSPS
system,
and
therefore
system
configuration
control
procedures,
are
inadequate.
This is
a violation, Failure
to Control
System Configuration
During
a Test
of the
Solid State
Protection
System,
50-400/88-11-01.
c.
Low Temperature
Over Pressure
Protection
On May 11, while the plant was operating at
100% power,
the licensee
made
a
10 CFR 50.72 report to the
NRC Duty Officer.
The notification
was to make the
NRC aware of a potential
unanalyzed
condition regarding
the
plant
low temperature
over pressure
protection
system
(LTOP).
The unanalyzed
condition was brought to the attention of the licensee
earlier during the day by Westinghouse
Electric Corporation
personnel,
the supplier for the plant
NSSS.
LTOP utilizes
the pressurizer
PORVs to protect
the reactor
vessel
from
overpressurization
when
the
plant
is
operating
at
low
temperatures
of 335 degrees
F or less.
The
LTOP system is not needed
when the temperature
is greater
than
335 degrees
F.
When the plant
is operating
at temperatures
greater
than
335 degrees
F,
the
are
controlled
to
open
at
pressures
to relieve
the
pressure
during
design
Operation
of the
minimizes
the
undesirable
opening
of the
spring-loaded
pressurizer
Code
Safety
Valves.
LTOP, at the Harris Plant,
was designed
to be automatically in effect
when the control
switches for the
two affected
PORVs are
placed
in
the
automatic
position
and
one
of the
two, affected
wide
range
temperature
detectors
indicates
a reactor coolant temperature
of 335
degrees
F or less.
The
remaining
PORV is unaffected
by the
controls.
Likewise,
the
three
Code
Safety
Valves
are
unaffected
by the
LTOP circuit.
The Westinghouse
unanalyzed
scenario
postulated
a condition where
a main
steam line break accident or major
S/G tube
rupture
accident
coincident with
a single failure of either of the
two
RCS wide range
temperature
channels
may allow the plant
temperature
in the affected
S/G to drop to
335 degrees
F or less,
thus
arming the
LTOP circuit in 'the faulted loop
and with the other
temperature
detector failed,
LTOP would actuate.
Thus, this would
even further drop
RCS pressure,
perhaps
into an unsafe
DNB condition.
0
To reduce
the likelihood of this condition from occurring,
on Nay
11
the
licensee
placed
the control
switches for the two affected
in the "shut" position
and placed
caution
tags
on the
switches
to
advise
the operators
that the
two switches
must
be manipulated
from
the main control board
by the operators if they wished to
open
the
two
PORVs thus eliminating the ability of the
LTOP system to activate
these
two
PORVs if a scenario
occurred
similar to that
proposed
by'estinghouse
above.
Also, placing
these
two switches
in the "shut"
position turned off all automatic controls for these
two PORVs.
The licensee
determined
that the plant would be in
a
more suitable
condition if the
LTOP system
was electrically disconnected
from the
normal
PORV control circuit and
the
switches for the
two affected
were
returned
to
the
"automatic" position.
On
May 13
the
control circuits for the
LTOP system
were
disconnected
(the
cards
were
unplugged)
and
the
switches
for the
affected
valves
were
returned to the "automatic" position.
Currently the licensee
plans to make
some
permanent
design
change
to
the
LTOP control
system
to allow it to
be manually turned off at
temperatures
greater
than
335
degrees
F.
The
inspector
discussed
the preceding
event with the licensee,
Region II management,
and
management.
As
a result
the inspector
'concluded
that the licensee
took satisfactory
corrective
steps
upon notification by Westinghouse
of this unanalyzed
condition.
d.
Emergency
Pump
While the plant
was operating
at
100%
power
on
May 13,
a condition
occurred
in which both
pumps
were considered
This
placed the plant in
a condition
under
which required
the
plant to begin changing
modes within one hour.
The event lasted only
ten minutes
and therefore
the licensee
was within full compliance of
this
TS requirement.
The
NRC Duty Officer was
made
aware of this
condition by the licensee.
The event resulted
from the "A" ESM seal
water booster
pump being declared
due to its suction
and
discharge
valves failing to properly shut,
thus
making the
"A"
pump
The
"B"
ESW system
had previously
been
declared
inoperable for repairs
on its
ESW booster
p'ump valves.
The techni-
cians
took
immediate
steps
to
make
adjustments
to both of the
affected
"A" ESW seal
water booster
pump valves
by cycling the valves
and flushing the valve seats.
Within ten minutes
the
"A"
ESW seal
water booster
pump,
and therefore
the "A" ESW pump,
were returned to
status.
The plant
was
then
no longer operating
under
the
condition of TS 3.0.3.
Except
as
noted
in paragraph
2.b,
no other violations or deviations
were
identified in the area's
inspected.
3.
Monthly Maintenance
Observation
(62703,
37700)
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
pri'or to
commencing
work activities, correct
documentation
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 were violating any limiting conditions for operation
during the specific evolutions;
the required
QA/QC reviews
and
QC 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 specific activities
were
evaluated:
The
inspector
evaluated
work associated
with
WR 88-AKUGl and
88-AKUT1 which required
unplugging
the electrical
control circuit
cards
on
the
system.
The circuit was
located
in process
instrumentation
cabinets
PIC-8 and PIC'-5.
Once unplugged,
the cards
were
tagged
in
accordance
with
the
controlling
Administrative
Procedure
to assure
that they were properly controlled.
The
work associated
with
88-ABSF5
was
evaluated.
The
WR was
generated
to require that repairs
be conducted
to stop
a body-to-
bonnet leak which developed
on
system
valve.
The valve
was identified as
lAF-155,
an isolation valve associated
with the
"A" steam
generator
preheater
bypass.
The valve provides
isolation
between
piping leading to the "A"
steam
generator
and the
chemical
addition
system
piping which
has
been
installed
for
the addition of hydrazine.
The
work activity
required drilling a hole in the valve bonnet
and injecting
a liquid
sealer
in accordance
with the
WR and
PCR-3068.
Upon completion of
the work the valve was tested
and returned to service.
No violations or deviations
were identified in the areas
inspected.
4.
Emergency
Response
Facilities Appraisal
(82412,
71707)
On
May 17 the licensee
conducted its annual
emergency
preparedness
exer-
cise,
which this year was
a limited scale drill.
A team of regional
based
emergency
preparedness
inspectors
were
on site to
perform
an
emergency
response facility appraisal.
e
The exercise
began
about
8:05 a.m.,
and was completed at about
1:45 p,m.
While the drill scenario
was in progress
the inspector
observed
licensee
personnel
at their exercise
stations,
both in the
TSC and in the Control
Room.
The drill started with a
RCS leak over
50
gpm in the containment building.
At about 8:24 a.m.,
an "alert" was declared,
and by 8:44 a.m.,
the
TSC was
activated.
A fire was reported
at elevation 291'n
the
Waste
Process
Building at
9:09 a.m.
The Holly Springs
Fire
Department
notification
was given
and
a simulated fire truck responded.
By 9:54 a.m.,
the plant
condition
had worsened
and the plant simulated
being in a "site emergency",
and at
10:02 a.m.,
simulated
evacuation
of the site
commenced.
Contain-
ment phase
"B" isolation
was simulated at ll:52 a.m.,
and at about
11:59
the plant
simulated
the declaration
of
a "general
emergency".
The simu-
lated conditions
then
allowed the
gradual
return of plant conditions to
normal.
The inspector
arrived in the
TSC shortly before
the
was activated
While in the
TSC the inspector
observed
the following:
Both primary personnel
and their alternates
appeared
in the
TSC very
promptly.
This allowed the
TSC to
be
ready for operation
in less
than
25 minutes.
The plant
general
manager
gave
detailed
briefings
throughout
the
drill
and
played
a
significant
role
in
keeping
the
"players"
organized
and making
sound decisions
when taking corrective
steps.
The
and the associated
diagnostic chart were available
and were
used extensively
by TSC personnel.
The status
of the plant
and supporting drill data
were promptly and
clearly posted
on the data charts
located in the
TSC.
During
the drill there
was
a
change
in players;
the
new shift
personnel
were thoroughly briefed by those
being relieved.
The inspector
also toured
the Control
Room during the exercise,
and the
following were observed:
The
players
were well
organized
and
kept
continuous
and accurate
logs
on the simulated
changing plant conditions.
The
TS
and
applicable
procedures
and
charts
were
available
where
the players
were
assembled
and
they
were
reviewed
and
referenced
continuously
by 'the players.
The shift foreman maintained
clear
and accurate
communications
when
using
the
public
address
system
and
when
speaking
to his fellow
players.
During
the
exercise
the
inspector
reviewed
the
licensee's
documented
exercise
scenario
ayd noted that it appeared
to have
an inclusive
scheme
with an unpredictable
path.
No violations or deviations
were noted in the areas
inspected.
Exit Interview
The inspection
scope
and findings were
summarized
on
May 24,
1988, with
the Plant General
Manager,
Operations.
The inspector described
the
areas
inspected
and discussed
in detail
the inspection findings listed
above.
Dissenting
comments
were not received
from the licensee.
The licensee
did
not identify as proprietary
any of the material
provided to or reviewed
by
the inspector
during this inspection.
One violation was identified:
VIO 50-400/88-11-01;
Failure to Control
System Configuration
During
Testing of the
SSPS'
paragraph
2.b.
Acronyms and Abbreviations
CPRL
EIR
F
GPM
~
LCO
NRC
OST
OWP
S/G
SSPS
TS
Carolina
Power
and Light Company
Departure
from Nucleate Boiling
Equipment Inoperable
Record
Emergency Operating
Procedure
Emergency
Fahrenheit
Gallons
Per Minute
Limiting Condition for Operation
Low Temperature
Over Pressure
Protection
Maintenance
Surveillance
Test
Nuclear Regulatory
Commission
Nuclear Reactor
Regulation
Nuclear
Steam
Supply System
Operational
Surveillance Test
Operations
Work Procedure
Plant
Change
Request
Pressure
Operated
Relief Valve
Quality Assurance
Quality Control
Reactor
Coolant System
Solid State Protection
System
Technical Specifications
Technical
Support Center
Work Request