ML18005A615

BOARD REPORT

U.S.

NUCLEAR REGULATORY COMMISSION

REGION II

SYSTEMATIC ASSESSMENT

OF LICENSEE

PERFORMANCE

NRC INSPECTION

REPORT

NUMBER

50-400/88-17

Carolina

Power

and Light Company

Shearon

Harris Unit

1

July 1,

1987 - June

30,

1988

33 f0030293

3809 1 6

PDR

ADOCK 05000400

PDC

I.

INTRODUCTION

TABLE OF

CONTENTS

Pacae

II.

CRITERIA

III.

SUMMARY OF

RESULTS

A.

B.

Overall Facility Performance

Facility Performance

Summary

IV.

PERFORMANCE ANALYSIS

A.

B.

C.

D.

E.

F

~

G.

H.I.

J.

K.

L.

Plant Operations

Radiological Controls

Maintenance

Surveillance

Fire Protection

Emergency

Preparedness

Security

Outages

guality Programs

and Administrative Controls

Affecting guality

Licensing Activities ..

Training and gualification Effectiveness ....

Engineering

Support

~

0

~

6

10

12

14

16

18

20

22

23

25

28

29

V.

SUPPORTING

DATA AND SUMMARIES

32

A.

B

~

C.

D.

E.

F.

G.

H.I.

J.

K.

Licensee Activities

Inspection Activities

.

Investigation

Review

~ .

Escalated

Enforcement Actions

Management

Conferences

Confirmation of Action Letters ..

Licensee

Event Reports

Licensing Activities

Enforcement Activities

Reactor Trips

Effluent Summary for 1987

0

~

0

~

32

33

34

35

36

I .

INTRODUCTION

The

Systematic

Assessment

of Licensee

Performance

(SALP) program is

an

integrated

NRC staff effort to collect available observations

and data

on

a periodic

basis

and

to evaluate

licensee

performance

based

on this

information.

The

program

is

supplemental

to

normal

regulatory

processes

used to determine

compliance with

NRC rules

and

regulations.

The

SALP program is intended

to

be sufficiently diagnostic

to provide

a

rational

basis

for allocating

NRC

resources

and

to provide

meaningful

guidance to licensee

management

in order to promote quality and safety of

plant construction

and operation.

An

NRC

SALP Board,

composed

of the staff members

listed below,

met

on

August 25,

1988, to re'view the collection of performance

observations

and

data

to assess,.licensee

performance

in accordance

with guidance

in

NRC

Manual

Chapter

0516,

"Systematic

Assessment

of Licensee

Performance".

A

summary of the guidance

and evaluation criteria is provided in Section II

of this report.

This report is the

SALP Board's

assessment

of the licensee's

safety

and

management

performance

at- Shearon

Harris Unit

1 for

the

period July 1,

1987,

through June

30,

1988.

SALP Board for Shearon

Harris Unit 1:

C.

W. Hehl,

Deputy Director, Division of Reactor Projects

(DRP),

Region II

(RII), (Chairman)

A.

R. Herdt, Chief, Engineering

Branch,. Division of Reacto}

Safety

(DRS), RII

D.

M. Collins, Chief,

Emergency

Preparedness

and Radiological Protection

Branch, Division of Radiation Safety

and Safeguards,

RII

D.

M. Verrelli, Chief, Reactor Projects

Branch 1,

DRP, RII

E.

G.

Adensam,

Director, Project Directorate II-1, Office of Nuclear

Reactor

Regulation

(NRR)

G.

F. Maxwell, Senior Resident

Inspector,

Shearon Harris,

DRP, RII

B.

C. Buckley, Senior Project Manager,

Project Directorate II-l, NRR

Attendees

at

SALP Board Meeting:

P.

M. Madden, Acting Chief, Technical

Support Staff (TSS),

DRP, RII

R.

E. Carroll, Project Engineer,

Project Section. 1A,

DRP, RII

W. Bradford, Senior

Resident

Inspector (Selectee),

Shearon

Harris,

DRP, RII

II .

CRITERIA

Licensee

performance is assessed

in selected

functional areas

depending

on

whether

the facility has

been

in the construction,

preoperational,

or

operating

phase

during

the

SALP review period.

Each

functional

area

normally represents

an area

which is significant to nuclear safety

and the

environment,

and

which is

a

normal

programmatic

area.

Some functional

areas

may not

be

assessed

because

of little or

no licensee activity, or

because

of

a lack of meaningful

NRC observations.

Special

areas

may

be

added to highlight significant observations.

One or more of the following evaluation criteria was

used to assess

each

functional area;

however,

the

SALP Board is not limited to these criteria

and others

may have

been

used

where appropriate.

A.

B.

C.

D.

E.

F.

G.

Management

involvement in assuring quality

Approach

to

the

resolution

of technical

issues

from

a

safety

standpoint

Responsiveness

to

NRC initiatives

Enforcement history

Operational

and construction

events (including response

to, analysis

of, and corrective actions for)

Staffing (including management)

Training and qualification effectiveness

Based

upon the

SALP Board

assessment,

each

functional

area

evaluated

is

classified

into one of three

performance

categories.

The definitions of

these

performance

categories

for the cur'rent

and previous

SALP period

in each functional

area

are

as follows:

Functional

Area

'August 1,

1986

June

30

1987

July 1,

1987

June

30

1988

Trend

Plant Operations

Radiological

Controls

Maintenance

Surveillance

Fire Protection

Emergency

Preparedness

Security

Outages

guality Programs

and

Administrative Controls

Affecting guality

Licensing Activities

Training and gualification

Effectiveness

Engineering

Support

Preoperational

and Startup

Testing

Construction Activities

2

1

2

NR

2

12.

2

1

2

1

2

N/A

Improving

Note:

NR = Not Rated

IV.

PERFORMANCE ANALYSIS

A.

Plant Operations

l.

Analysi s

Ouring this assessment

period,

inspections

were performed

by the

resident

and

regional

inspection

staffs.

The

i'nspections

included:

system

walkdowns;

procedure

reviews;

personnel

interviews;

housekeeping;

observations

of reactor

startups

and

plant

shutdowns;

operations

at

power;

and

control

room

activities which included operator

demeanor,

plant transients,

routine valve lineups,

and log keeping.

The inspectors

noted that during abnormal

conditions (ie.,

such

as

when

one of the

main feedwater valves failed closed or when

the

main

tu'rbine

automatic

controls

became

inoperable)

operations

personnel

have

been

quick

to

use

available

information and procedures

to stabilize

and control

the plant.

This

includes

the

use

of the

readi'ly available

control

room

drawings

which

are

always

maintained

current.

Routine

operational

activities were carried

out by the operators

in

a

very professional

manner.

The uniform policy for control

room

operators'ress

continues

to help distinguish

those

operators

who are

on duty in the control

room.

Shift foreman's

logs

have

been

reviewed daily

and

have

been

found to

be consistently

legible and clearly reflect the status of the plant.

Normally,

the

number of plant annunciators

which were in alarm or disabled

were

minimized

and

generally

consistent

with existing

plant

operating

conditions.

During plant

system

walkdowns,

valves

were found to be properly aligned

and positioned.

Additionally,

all

observed

inoperable

or

malfunctioning

equipment

had

deficiency tags

attached

and work requests

initiated.

This is

indicative

of operations

personnel

properly controlling the

status

of the plant

systems.

The plant

has

been

kept

very

clean.

A description

of the

plant trips

which occurred

during this

rating period is provided in Section V.J.

Of the six reactor

trips, five were

automatic

and

one

was manually initiated.

One

trip was due to equipment failure,

one was

due to design error,

one

was

due to inadequate

procedure

controls,

one

was

due to

non-licensed

operator

error,

and

two

were

due

to

licensed

operator

errors.

The

equipment

failure

was

addressed

by the

licensee's

predictive

and preventive

maintenance

programs.

The

design

problem

was

corrected

and

evaluated

by

the

design

engineering

group.

For

the

remaining

instances,

licensee

management

provided corrective

measures

which should reduce

the

plant trips caused

by personnel

error.

These

measures

included

intensified "real time" training for the operators

to acquaint

them with revisions to procedures

and lessons

learned

which have

resulted

from plant events

and incidents'lso,

in some

cases

disciplinary action (includ'ing leave without pay) was taken

when

operators failed to follow procedures.

During

the

period

the plant

experienced

several

reactor t~ips which were attributed to problems with the

condensate

and

systems.,

The

licensee

recognized

a

need to collect the reactor trip data for analysis,

and

a task

force

was formally chartered

to review

and

recommend reliable

improvements

for

the

secondary

plant.

The

task

force

recommended

permanent

changes

to the

condensate

and

systems

to alleviate the secondary

plant transients.

During

an

October

1987

outage,

the

task

force

recommendations

were

implemented.

During

the

months

following

the

plant

modifications,

the

plant

performance

significantly increased,

with

no reactor "trips being attributed

to

secondary

system

interaction.

Plant

. management

involvement

in

routine

and

nonroutine

activities became

more effective during this period.

This was

demonstrated

by their involvement in daily coordination meetings

to evaluate all plant off-normal conditions,

any

LCO conditions

which could

lead

to

a

shutdown,

plant conditions

which could

potentially affect operations,

and prioritization of maintenance

activities.

Management

has

remained

responsive

to

items of

concern

expressed

by

the

NRC

and

they

maintain

good

communications with the public and local authorities.

A review of the

LERs indicated that the licensee

submitted

about

twice as

many

LERs in the first six months

as

an

average

plant

and

was about average for the

second six months.

This level of

reportable

events

is consistant

for

a

new plant

and

shows

an

improving

trend.

Several

of

the

LERs

were

tentatively

classified

as significant by the Office of Analysis for Events

and

Opertional

Data

(AEOD)

screening

process.

These

LERs,

discussed

in Section IY.L of this report, reflect deficiencies

in design,

installation,

and fabrication which are within the

range

of startup

problems

at

new

plants.

Generally,

the

reportable

events

were

caused

by

personnel

errors

and

administrative

oversights

which were

amenable

to correction

by

increased

familiarity with

operating

the

plant

and

more

attention to detail.

The types of personnel

errors

and administrative oversights that

caused

the majority of the

LERs included missed

survei llances,

improper valve restoration

lineup, miscues

during test or plant

evolutions.

Two events

involved

opening

one of the air lock

doors while the other door was not secure.

Overall,

the

LERs

were

submitted

in

a

timely

fashion

and

generally

provided

sufficient

information

to

understand

the

event

and the unde~lying causes.

The

number of violations listed below does not indicate

a long

term poor operations

performance

record.

The majority of the

violations occurred in the first part of the assessment

period,

with

a reduction

in the

number of violations

noted

toward the

end of the period.

Nine violations were identified.

P

Severity

Level

IV violation occurred

when

a plant operator

allowed

low pressure

safety

injection to occur during

a

normal plant shutdown.

(400/87-26-01)

.

Severity

Level

IV violation for personnel

pulling the wrong

fuse during

a clearance,

which resulted

in a reactor trip.

(400/87-26-02)

C.

Severity

Level

IV violation

occurred

when

an

operator

failed to follow procedure

when returning

a compressed air

valve to normal service.

(400/87-31-01)

Severity

Level

IV violation for failure

to correctly

interpret Technical Specification

requirements

when leaving

a

steam

generator

blowdown

valve

stuck

open

with the

reactor operating at power for 29 days.

(400/87-34-01)

e.

Severity

Level

IV violation for the shift foreman allowing

reactor

vessel

head

vent

valves

to

be

manipulated

even

though

the

valves

were

known

to

operate

improperly.

(400/87-37-01)

Severi ty

Level

IV

viol ati on

for fa i lure

to fol 1 ow

operations

procedures

by incorrectly positioning

steam" dump

controls during

a reactor

heatup.

(400/87-40-02)

h.

l.

Severity

Level

IV violation for failure to promptly update

an

emergency

operating

procedure,

to

comply with

FSAR

commitments.

The revision was necessary

to assure

that the

RHR system

could supply sufficient cooling water to

keep

the reactor

vessel

core

covered

during

a

LOCA event which

may

result

in

only

one

RHR

pump

to

be

available.

(400/88-06-01)

Severity

Level

IV violation for failure to control plant

system configuration during

a test of the "A" train Solid

State Protection

System;

the "A" train was tested

when

"B"

train equipment

was inoperable.

(400/88-11-01)

Severity Level

V violation for failure of the shift foreman

to report within four hours

an

ESF actuation

to the

NRC

Duty Officer.

(400/87-31-02)

Conclusion

Category:

2

Trend:

improving

10

3.

Recommendations

An improvement

during the

assessment

period

was

recognized

in

this area

based

on

a reduction

in violations during the

second

half of the period,

an increased

emphasis

on personnel

training,

and the extended

periods of plant operation.

Continued

emphasis

should

be placed

in this functional

area.

NRC staff resources

applied to the routine inspection

program should

be maintained.

B. 'adiological

Controls

1.

Analysi s

During the assessment

period,

inspections

were performed

by the

resident

and

regional

inspection staffs.

Regional

inspections

included

two radiation

protection,

one radiological effluents,

one chemistry,

and

a confirmatory measurements

inspection

using

the

Region II

mobile

laboratory.

These

inspections

were

supplemented

by

the

resident's

routine

evaluation

of

the

day-to-day radiation work practices at the site.

The licensee's

health physics

(HP) and radwaste staffing levels

were appropriate

and

compared

well to other utilities having

a

facility of similar size.

An adequate

number of ANSI qualified

technicians

were available

to support operations.

Although the

health physics staff continued to be supplemented

by the

use of

eighteen

contractors,

the licensee

plans to eliminate,

by early

1989,

the

use of contract

HP personnel

durihg normal operations.

This was to be accomplished

by hiring six additional technicians

and qualifying twelve individuals

who

were

in the

licensee's

health physics training program.

The

knowledge

and

experience

level 'of the

HP,

radwaste,

and

radioactive

material.

transportation

personnel

continued

to

increase

during the

assessment

period

and is considered

good.

The staff

has

a

low turnover rate

and

the

general

employee

'adiation

protection

training

program

was

adequate.

The

HP

technician training program

was accredited

by the Institute of

Nuclear

Power Operations

(INPO) on September

25,

1986.

The performance of the radiation protection staff in support of

routine operations

was

adequate.

However,'he

response

of the

radiation

protection

staff to radiological

control

problems

associated

with outages

is yet to be determined

since the first

refueling

outage

is

scheduled

for late July 1988,

which is

outside the

SALP period.

The licensee's

radioactive

material

transportation

program

was.

adequate,

as

were

the radiation

work permit

and respiratory

protection

programs.

No

internal

contaminations

or

administrative

or regulatory

overexposures

occurred

during the

11

assessment

period.

The

licensee

did experience

87 personnel

contaminations

during

1987,

48

of

which

were

skin

contaminations.

The remaining

39 were clothing contaminations.

From

January

1,

through

June

30,

1988,

the

licensee

had

experienced

a total of

11 skin

and

39 clothing contaminations.

The

number of personnel

contaminations

is typical for a plant of

similar size

and age.

Licensee

management

support

of,

and

involvement

in,

the

radiation

protection

program

was

adequate.

The radiological

preparations

and

planning for the first refueling

outage

in

July 1988,

appeared

to

be

generally

complete

and

thorough.

Licensee

management

placed

emphasis

on keeping

worker doses

as

low as

reasonably

achievable

(ALARA), following procedures,

and

complying with good radiation control practices.

During calendar

year

1987,

the licensee's

collective

dose

was

33 person-rem

which was well below the

PWR national

average

of

368 person-rem.

The low collective dose

was attributable to the

fact that the facility is relatively new and that there

was

no

refueling outage

during this period.

The collective

dose

goal

for 1988,

was set at 260 person-rem with 200 person-rem of that

total

planned for the first refueling outage.

As of June

30,

1988,

the licensee

had expended

7 person-rem.

Liquid and

gaseous

radioactive effluents

were within the

dose

limits specified in the Technical Specifications

and 40'FR

190,

and within the radioactivity concentrations

specified in 10 CFR 20.

Concentrations

did not

exceed

the

10 CFR 50

Appendix I

ALARA limits.

No

abnormal

liquid or

gaseous

releases

were

reported during 1987.

A summary of 1987 effluents is listed in

Section

V.K of this report.

The chemistry

program

has

become

very effective.

The licensee

has

made

good

use of contract

chemistry

personnel,

as well

as

resources

from the corporate

training center.

In the future,

however,

the

licensee

plans

to

lessen

the

dependency

on

chemistry

contractors.

Since this plant

was

designed

in the

early

1970's,

some

of

the

physical

facilities,

such

as

laboratories,

are state-of-the-art

where

as other areas,

such

as

sample

rooms,

are

not.

However,

this

has

not

affected

acceptable

performance

by the licensee.

This was re-emphasized

by the

good

agreement

shown

between

the

licensee's

and

NRC's

sample

results

for the

NRC radiological

and

nonradiological

(chemistry) confirmatory measurements

programs'uring

calendar

year

1987,

the license

disposed

of

a total of

3,700 cubic

feet

of

solid

radioactive

waste

containing

2.6 curies

of radioactivity.

This

was

well

below

the

PWR

national

average

of 6,590 cubic feet for a single unit site, but

as stated earlier, there

was

no major outage during the period.

12

The

goal

established

for 1988

was

set at 6,500 cubic feet,

of

which 4,200 cubic feet of solid radioactive waste (including dry

active waste

shipped for supercompaction)

containing

1.37 curies

of activity had been

shipped

as of June

30,

1988.

The increased

volume of waste

shipped

in

1988

was

due to the fact that the

licensee

held

some

shipments

over from 1987.

In early 1988,

the

licensee

began

an aggressive

program to eliminate the practice

of taking

in unnecessary

items/material

into

the

controlled

area.

This was done in

a attempt to reduce

the total

volume of

waste

generated

at the facility.

In

December

1987,

the

licensee

maintained

5,200

square

feet

( 1. 1i>) of the total radiation control

area

(RCA) as contaminated

(excluding the containment).

The actual

area

being controlled

at

the

end

of

the

assessment

period

was

approximately

2,425

square

feet (0.5') of the

RCA.

No violations or deviations

were identified.

2.

Conclusion

Category:

2

3.

Recommendations

NRC staff resources

applied to the routine inspection

program

should

be maintained.

C.

Maintenance

Analysi s

During this assessment

period, inspections

were performed

by the

resident

and

regional

inspection

staffs.

The scope'f

the

inspections

included:

process,

tracking

and

implementation

of

work requests;

observation

of

maintenance

and

surveillance

testing;

witnessing

preventive

maintenance

activities,

and

modifications

and troubleshooting.

Maintenance

continues

to

be

a strong

area at Harris, with an

aggressive

maintenance

effort.

The

licensee's

work request

process

appeared

to

work very well

during this

evaluation

period.

The site-wide priority system

and

management

controls

that implement the priority system

have assured

that the safety

significance

and importance of each job are clearly communicated

and that

resources

were

applied first to the

most

important

tasks.

Inoperable

or malfunctioning

equipment

observed

during'ystem

walkdowns all

had

a deficiency tag attached

and

a work

request initiated.

All station requirements

had

been

adhered

to

in the

issuance

and completion of these

work requests.

High

13

priority items

were

completed

in

a timely manner;

however,

several

low priority items took longer to complete.

Early

in

the

assessment

period,

the

methods

used

to track

maintenance

trends

were

not

formal.

The

individual

system

engineer

made

the

determination if a fai lure

mechanism

was

repetitive

and warranted consideration

for generic applicability

or inclusion in the preventive

maintenance

program.

The lack of

a formal

program

produced

a subjective

situation that

may have

caused

errant decisions

when

a

new or

backup

system

engineer

made

the repetitive failure decision

and

as

such,

may not have

been

aware of the

number of fai lures.

Accordingly, the licensee

has

developed

procedural

controls

to continue

improving its

maintenance

feedback

program.

The

program

is

being

used

extensively

to

document

items

needing

attentions

Providing

documented

procedural

controls for the

feedback

program

has

aided

the program in that various affected departments

must

now

formally respond

to items of concern

which were identified by

the program.

Maintenance

personnel

evaluated

approximately

3000 plant system

valves

and

have

included

them

on the valve list for the "live

load"

program.

The "live load"

program

was designed

to reduce

the likelihood of valve packing

leakage

and valve stem binding.

The licensee

began this

program at the

end of the

assessment

period

and

plans

further

implementation

on

selected

valve's

during the July 1988 refueling outage.

The

maintenance

staff

continues

to

use

the

utility's

computerized

automated

maintenance

management

system

as

a part

of their maintenance

program.

This system

has

proven to be very

valuable

to maintenance

personnel,

in that its uses

included:

initiating

and

tracking

woi"k request

status,

planning

and

scheduling

work, and review 'of historic maintenance

records.

The licensee

has

appointed

a full time crew of instrumentation

and

control

technicians

to

perform all

of

the

maintenance

surveillance

tests

associated

with

the

reactor

protection

system.

The crew also

has

been

responsible

for conducting all

of the corrective

maintenance

on the protection

system.

Having

a single dedicated

crew for this

system

has

provided

improved

consistency

in preventive

and

corrective

maintenance

and

has

made the

system

more reliable.

Post-maintenance

activities'er e routinely inspected.

With the

exception of the violation identified below, testing

was

found

to

be

appropriate

for

the

maintenance

performed

and

was

conducted

in accordance

with written procedures.

Overall, Harris appears

to

have

a comprehensive

and aggressive

maintenance

program,

and

seems

to

be very

much

aware of

NRC

concerns

and initiatives.

One violation was identified.

Severity Level

IV violation for maintenance

personnel

failing to

follow

procedure

when

several

steps

in

a

maintenance

surveillance

test

procedure

on

an

emergency

diesel

generator

fuel

nozzle

were

not

completed

and

no justification

was

documented.

Also, while conducting

a reactor

coolant

system

isolation

valve test,

the test

procedure

was

changed

without

first obtaining

an

approved

temporary

change.

Both of these

were

documented

as

one

example of personnel

failing to follow

procedure

while

conducting

maintenance

activities.

(400/87-38-01)

2.

Conclusion

Category:

I

3.

Recommendations

A high level of performance

was

achieved

in this area.

It is

recommended

that

NRC staff

resources

applied

to

the

routine

inspection

program

be reduced.

Surveillance

l.

Analysi s

During this assessment

period,

inspections

were performed

by the

resident

and

regional

inspec'tion

staffs.

The

licensee's

survei

1 1 ance

schedul e

was

regul arly

eval uated

to

veri fy

survei1 lance

testing

was

performed "as

scheduled,

testing

was

conducted

in accordance

wit,h approved

procedures,

and the test

results

were

promptly

reviewed

by

super'vision.

The

routine

inspections

included

witnessing

surveillance

testing

for

electrical

systems,

pump

and

valve

in-service

testing,

mechanical

systems,

and instrumentation

systems.

Early in the first fuel cycle, the licensee's

performance

of and

procedures

for core

power distribution

monitoring,

reactor

coolant

system

leakage evaluation,

and thermal

power monitoring

and evaluation

were reviewed.

It appeared

that the licensee

had

demonstrated

a

good

understanding

of this

portion

of

the

surveillance

program.

The

licensee's

procedures

were

well

planned,

technically

accurate

and indicated

evidence

of prior

planning.

15

The

licensee

has

improved its

surveillance

test

scheduling

program.

The

program

has provided

a very reliable schedule for

routine surveillance

tests,

periodic tests

and

any additional

tests

which

may

have

been

requested.

Records

show that less

than

15 of the routine

13,000

survei llances

were

not completed

as

scheduled

during thi s

SALP period.

The daily surveillance

test

schedules

are

the

responsibility

of

the

licensee'

Regulatory

Compliance

personnel.

These

schedules

are regularly

discussed

at

each

morning meeting with the various

department

managers'ssurance

of quality,

including

management

involvement

and

control

was

evident.

In particular,

review of the

previous-

pressurizer

safety

valve

set

point test

results

indicated

evidence of prior planning.

Each pressurizer

safety

valve

was

tested

by the vendor with both nitrogen

and hot wa.er

so that in

future testing,

appropriate

compensations

can

be

made

when only

y single

medium is utilized.

This will provide flexibility and,

therefore,

simplify testing.

Once the valves

are

contaminated,

the

vendor will no

longer

be able to perform this function.

The licensee

is committed to ASME OM-1 for safety valve testing

and is currently establishing

a set point testing

program.

Review of completed

startup test

procedures

for the 75,

90 and

100% power plateaus

was completed during this appraisal

period.

All tests

were

conducted

in

a timely

and

acceptable

manner.

When required, test

changes

were properly approved,

retests

were

performed,

and

changes

or relaxations

in performance criteria

were justified.

One test,

the loss of 100io'f electrical

load,

was deleted following approval

by the

NRC.

The efforts involved

in the deletion

process

demonstrated

that the

licensee

had

a

good understanding

of the technical

issues

involved.

The licensee

also established

a program which is in response

to

the erosion/corrosion

experienced

by another

Region II licensee

on

the

main

system

piping.

This

program

was

implemented

in the fall of 1987 by the licensee

during

a brief

outage'he

program was developed

and implemented

in accordance

with Electric Power Research

Institute

(EPRI) guidelines.

Also

during this

outage

the

licensee

successfully

completed

the

required

local

leak rate

testing

for. all of the

individual

containment

penetration

isolation

valves.

To

assure

survei llances

are

performed within their required

time

frame,

management

plays

an

active role at the daily morning meeting

where the surveillance

schedule

is discussed.

No violations or deviations

were identified.

2.

Conclusion

Category:

1

j

16

3.

Recommendations

A high level of performance

was

achieved

in this area.

It is

recommended

that

NRC staff resources

as applied to the routine

inspection

program

be reduced.

E.

Fire Protection

1.

Analysi s

During this assessment

period,

inspections

were conducted

by the

resident

and regional

inspection staffs to review the licensee's

implementation

of the fire protection

program

and followup on

. previously identified enforcement matters.

The

licensee

has

issued

revisions

to

procedures

for the

administrative

control

of fire

hazards

within

the

plant,

surveillance

and maintenance

of the fire protection

systems

and

equipment,

and

organization

and training of the

plant fire

brigade.

These

procedures

were

reviewed

during

the

staff

inspections.

With the exception

of Fire Protection 'rocedure

FPP-013,

Fire

Protection

Mitigating Actions,

all

of

the

procedures

appeared

to meet the

NRC requirements

and guidelines.

Review of procedure

FPP-013

showed that it was inadequate.

This

was identified as

a violation (b. below).

The staff inspectors

also reviewed the licensee's

implementation

of fire prevention

administrative

controls

and

surveillance

procedures.

This review

showed that the inspections

and tests

were being performed in accordance

with requirements,

except for

that required

by procedure

FPT-3302,

Main Drain Test Auxiliary

Building quarterly

Interval.

Review of inspections

and tests

required

by this procedure

showed that six systems

on the 190',

268'nd 305'levatjons

of the Reactor Auxiliary Building were

not tested

between

February 4,

1987

and August 28,

1987.

This

exceeded

the

quarterly

interval.

This

was identified

as

a

violation (a. below).

During

a walkdown inspection

by the staff, housekeeping,

control

of combustible

and

flammable materials

in safety-related

areas

were

found

to

be

satisfactory.

The

fire

protection

extinguishing

systems

(except

as

previously

noted),

fire

detection

systems

and fire barrier assemblies

protecting plant

systems for safe

shutdown

were also found to be functional.

The technical

support staffing for the fire protection

program

is adequate

to accomplish the goals without excessive

overtime.

The

licensee's

fire

protection

staff's

authorities

and

responsibilities

are

clearly

defined.

The

organization

and

staffing levels along with the training and drill frequency for

the fire brigade

members

met the

NRC guidelines.

It was

noted

17

during this

assessment

period that the

response

time for the

site fire brigade within the power block and outside

and

power'lock

has

improved.

The

improvements

are

attributed

to the

purchase

and

use of equipment carts,

one for each

elevation

in

each building,

and improved hose

houses.

The in-place equipment

carts

are

packed

with the

required

inventory

to fight

a

potential fire, and minimize the distance that equipment

must

be

carried.

The

new

hose

houses

have

improved the

response

time

outside

the

power block because

the

hoses

are preconnected,

as

opposed

to the old hoses

that required

numerous

connections

to

reach the nearest

building.

The

most recent

audits

and

gA surveillance

reports of the fire

protection

program were conducted within the specified frequency

and

appeared

to

cover all

essential

elements

of

the fire

protection

program.

These

audits

identified

some

. minor

discrepancies.

The licensee

appeared

to

be taking appropriate

corrective actions

on these audit findings.

Management

involvement

and control

in assuring

quality in the

fire protection

program

appeared

to

be

adequate

except for the

inadequacy

noted

earlier

regarding

administrative

procedure

FPP-013.

The

licensee's

approach

to resolution

of technical

fire protection'ssues

indicates

an understanding

of issues

and

is

sound

and timely.

Responsiveness

to

NRC initiatives

are

timely

and

thorough.

When

violations

do

occur

effective

corrective

action

is promptly taken.

Fire protection related

events

and discrepancies

identified by the licensee

are properly

analyzed

and promptly reported

and effective corrective actions

are taken.

Two violations were identified.

a.

Severity

Level

IV violation

for

failure

to

perform

quarterly

surveillance

of the

multicycle

and

preaction

sprinkler

systems

on the 190', 268'nd 305'levations

of

the reactor auxiliary building.

(400/88-01-01)

b.

Severity

Level

V

violation

i'nvolving

an

inadequate

procedure

for

implementing

mitigating

actions

for

inoperable fire suppression

systems.

(400/88-01-02)

2.

Conclusion

Category:

2

3.

Recommendations

'n apparent

complacency

on the part of the licensee,

resulted

in

a lower category rating in this area.

Increased

emphasis

by the

licensee

is

warranted.

NRC staff

resources

applied

in the

18

routine inspection

program should

be mai'ntained

~

F.

Emergency

Preparedness

1.

Analysi s

During this

assessment

period,

inspections

were

performed

by

resident

and

regional

inspection

staffs.

The

regional

inspections

included

two routine inspections

and

an

emergency

response facilities (ERF) appraisal.

The licensee

had established

an effective emergency notification

and

communication

system,

consisting

of procedures,

equipment,

and trained staff to

make appropriate

notifications of offsite

agencies.

These

systems

included

the

Emergency

Notification

Systems

(ENS);

a

dedicated

Selective

Signaling

System;

and

backup

equipment

that

included

radio,

a

private

telephone

exchange,

a

microwave

system

and

commercial

telephones.

The

public

prompt notification

system,

consisting

of sirens

and

tone-alert radios,

was kept maintained

and tested.

The licensee

effectively implemented this program.

The

licensee

implemented

an

effective

system

for

emergency

detection

and classification,

based

primarily

on

the fission

product

barrier

concept,

but

also

including

anticipatory

initiating

conditions.

The

licensee's

protective

action

decision

making

was

based

on

NRC

criteria.

Individuals

responsible

for making protective action

recommendations

were

clearly identified.

The

licensee

demonstrated,

during

walk

throughs,

the ability to promptly identify and classify events

and

the

ability

to

make

appropriate

protective

action

recommendations.

The

licensee

maintained

an

effective

system

for

assuring

appropriate

onsite staffing

and for augmenting

onsite staff in

the event of an emergency.

The licensee

implemented

a system to

notify staff

when

needed,

including

pagers

and

a "call in"

program.

The

licensee's

unannounced

drill

of

shift

augmentations

showed

staff

could

arrive

onsite

within

an

appropriate

time after being notified at

home to respond to the

si te.

The licensee

maintained

an offsite dose

assessment

system that

included

computerized

dose evaluations

based

on measurements

of

effluents, plant parameters,

primary coolant activity levels

and

offsite monitoring results.

Source

terms

. were

developed

via

computer

evaluation

of post

accident

sample

results

of the

reactor

coolant,

containment

atmosphere

or containment

sump.

manual

methods

were used-to

develop

source

terms

using

other

plant parameters.

As

a backup for computerized

dose

assessment,

the

licensee

maintained

a

manual

system.

During

a

routine

19

inspection, it was

noted that there

was

a

need for additional

training

in

use

of

dose

assessment

procedures

by

both

radiological

personnel

and

reactor

operators

(who would

make

initial dose projections).

The dose calculations

were performed

slowly and resulted

in erroneous

doses

in two of three walk-

throughs.

Initially, the licensee

indicated that the expediency

of

these

calculations

was

not

relevant,

as

there

was

no

requirement

stating

dose projections

had to be calculated within

a

specified

time

period.

Further

discussions

between

the

licensee

and

Region II management

resulted

in the

licensee's

acknowledgement

of the

need for timely dose

projections.

The

licensee

then

pursued

aggressive

training

and

procedural

corrective actions that were found to be fully adequate

during

a

subsequent

follow-up inspection.

The

licensee

was

slow to

implement'

periodic

maintenance

program

on

Technical

Support

Center

(TSC)

door

seals.

The

licensee

agreed,

in June of 1986,

to perform

such

maintenance.

In August

1987,

the licensee

could not confirm whether

such

a

program

had

been

implemented.

In September

1987,

the licensee

implemented

a procedure

to routinely test

the

TSC pressure

and

habitability

systems.

The

TSC is powered

by two separate

sources.

In preparation for

the

ERF Appraisal,

the

licensee

determined

the

need

for

an

additional

power source

in the event of

a station blackout

and

determined

that

a

vendor-supplied

diesel

generator

could

be

supplied

and

made operational

in approximately

25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months .

The

licensee

agreed

to reanalyze

the

need for an additional

power

supply given the potential

impact of loss of

TSC function

on

station blackout.

The Emergency Operations Facility (EOF) is located approximately

3,400

meters

from the plant.

The. facility is

equipped

with

emergency

ventilation

(HEPA and charcoal)

to maintain the area

under positive pressure.

This degree of protection

exceeds

NRC

criteria,

which specifies

the

need

for only

HEPA filters.

The

licensee's

evaluation

of direct radiation

dose

showed

doses

would be maintained

below

GDC 19 criteria.

During the

recent

emergency

exerci se,

the

ventilation failed to

achieve

the

specified

0. 125 inches

of water differential

pressure.

The

licensee

identified

an

inleakage

path

from the filter train

drain

valves.

The

licensee

committed

to install

isolation

valves

on the drain lines.

1

The

licensee

implemented

an

appropr iate

public

information

program

that

included

dissemination

of

a public information

brochure

in

the

form of

a

calendar,

placement

of

public

information decals

on public telephones

and information signs.

In addition,

the

licensee

conducted

annual

media

education

20

seminars

and

distributed

special

information

brochures

to

school s.

The resident

inspector

observed

the routine

licensee

emergency

preparedness

training drills and

observed

limited portions of

the

annual

exercise.

The licensee's

performance

during

these

routine drills and

the exerci se

demonstrated

the capability to

implement

the

emergency

plan.

The

exercise

included

participation

by corporate

staff

and

management.

The

scenario

for

the

emergency

exercise

was

significantly

improved

as

compared with the

1987 exercise.

The

licensee

has

conducted

annual

audits

of

the

emergency

preparedness

program

by

the

Corporate

equality

Assurance

Department.

In addition,

the

licensee

evaluated drills

and

exercises

to identify areas

where

improvements

are

necessary.

Findings are tracked to completion of corrective actions.

No violations or deviations

were identified.

2.

Conclusion

Category:

2

3.

Recommendations

NRC staff resources

applied to the routine inspection

program

should

be maintained.

Security

1.

Analysi s

During

the

evaluation

period,

four routine

inspections

were

conducted

by region-based

inspectors

and additional evaluations

were conducted

by the resident inspector.

The

licensee

has significantly improved its compliance

record

since

the

last

period

through

increased

management

oversight

of

the

security

program,

plant

employee

security

education

and

increased

experience

on the part of the security

force.

The

one violation identified resulted

from

a misinterpretation

of the

term

"emergency

vehicle" following a

severe

snowstorm.

The violation does

not represent

either

a programmatic

breakdown

or

a lack of sensitivity to regulatory requirements.

The

licensee

aggressively

attacked

and

solved'hose

security

problems

which arose

shortly after licensing

through

a multi-

disciplined security task force.

These

problem areas

related to

21

vital

area

barriers,

compensatory

measures,

the

security

computer

system,

and removal of badges

from the Protected

Area.

Licensee

performance

in these

areas

during the

SALP 'period

has

been

noteworthy.

An On-Shift Training

Program

has

been

implemented

to enhance

security

force training.

This

program

has

provided

security

personnel

with some

200 training sessions

and

an equal

number of

security force drills.

Additionally, increased

tactical

force

and leadership

development

exercises

have

been

implemented.

The

licensee

is

examining

techniques

and

equipment

to

further

enhance

the effectiveness

of the tactical training program.

In

addition

to

the

Security

Training

Program

and

the

establishment

of the multi-disciplined

security

task

force,

management

involvement in this area

has

also

been

evidenced

by

the following:

( 1) quarterly

meetings

with corporate

security

are

attended

by all

three

CP&L nuclear

plant site

security

supervisors,

during which they

share

lessons

learned,

discuss

security

problems

and

encourage

uniform compliance

with

new

regulations;

and (2) the site security

supervisor

and security

chief are directly involved to provide oversight

on routine

and

nonroutine

events.

Where

needed,

and

as

appropriate,

these

individuals contact other on-site

and off-site security groups.

The

licensee

was

very

responsive

to

NRC

concerns

and

the

security program

has excellent

support at the plant

management

level

.

One violation was identified.

Severity

Level

IV violation for failure to search

vehicle

and

driver prior to entry into Protected

Area (400/88-05-01).

Conclusion

Category:

1

Recommendations

Although outside

the rating period,

the recent security access

control

problem

at

the Harris facility warrants

mentioning.

Accordingly,

increased

attention

in this

area

should

be

considered

to assure

performance

does not decrease

over the next

assessment

period.

NRC staff resources

applied to the routine

inspection

program should

be maintained.

22

H.

Outages

1.

Analysi s

During this assessment

period,

inspections

were performed

by the

resident

and regional

inspection staffs.

The licensee

formed

an outage

management

team in June

1987.

The

team was created

as

a support unit to aid other units within the

project's

organization.

The

team participated

in the

planned

outage

which was

conducted

during October

1987

and the forced

outage

which

was

conducted

during

March 1988.

During

the

October

outage

some

major

modifications

were

made

to

the

secondary

plant

systems

and

components.

These

included:

( 1) trimming the main feedwater

pump impellers; (2) changing

the

settings

on the main feedwater

pump low suction pressure

switch;

(3) modi.fying the air boosters for the main feedwater regulating

valves;

(4) removing

one

stage

from each

of the

heater

drain

pumps;

(5) modifying the main feedwater

pump recirculating flow

control line valves

(added flow restrictors);

(6) increasing

the

pressure

settings

for the

main

suction

which feeds

into the condensate

booster

pump control circuit; (7) adding

a

time

delay

to

the

condensate

booster

pump

high

discharge

pressure trip signal;

and other changes

to the controls for the

condensate

and main feedwater

pumps.

The

March outage

lasted approximately

one week and was required

in order to replace five of the bellows for the main turbine low

pressure

extraction

steam lines which failed during normal

power

operation.

.The licensee

determined

that all

eighteen

of ,the

bellows will be replaced

during the

upcoming refueling outage

with bellows that are manufactured with improved materials.

In

addition

to

replacing

the

five bellows,

some

of the

main

condenser

tubes required plugging,

as they were

damaged

when the

bellows failed.

Additional outages,

in excess

of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ,

occurred in order to

co~rect

problems

with

steam

generator

blowdown

valves

(July 16-22,

and September

12=14,

1987),

and to correct

a design

and analysis deficiency relating to the single failures

assumed

in

DC power supplies

(September

15-25,

1987).

During

the

outages

discussed

above,

the

outage

management

organization

coordinated

the efforts of the various

departments

involved to make certain the schedule

was realistic

and adhered

to, that necessary

personnel

and materials

were. available,

and

that inspections

'were conducted

by the site

gC department.

The

licensee

uses

the

Operating

Experience

Feedback

system

to

identify industry events

with potential

safety significance

to

the plant.

The licensee

has taken action

on potential

problems

in

advance

of the

issuance

of

a regulatory

mandate

to take

23

action.

Two

examples

include

the

short

term

inspections

of

reactor trip breakers

done in the October

1988 outage

and prior

to the

issuance

of

NRC Bulletin 88-01,

and

the

plan for

an

inspection

of the

incore

guide

tubes

in the first refueling

outage

in advance

of the issuance

of NRC Bulletin 88-09.

Regional

based

outage

inspection

activity

involved

the

licensee's

IST and ISI programs, as'ell

as

a special

inspection

of the activities in response

to

NRC Bulletin 88-05.

From these

inspection efforts,

the inspectors

concluded

that the licensee

has

adequate

programs,

procedures,

and staffing in the areas

of

ISI and

IST.

In all areas

inspected,

the licensee

demonstrated

excellent

responses

to

NRC initiatives.

No violations or deviations

were identified.

2

~

Conclusion

Category:

1

3.

Recommendations

It was noted,

that while

a category

1 rating

was

assigned

to

this functional

area,

the licensee

had not

been

challenged

by

the

problems

associated

with

a refueling outage.

Accordingly,

NRC staff resources

applied to the routine inspection

program

should

be maintained.

I. 'uality Programs

and Administrative Controls Affecting Quality

l.

Analysi s

During this assessment

period,

inspections

were performed

by the

resident

and

regional

inspection

staffs.

Additionally,

a

Quality Yerification

Inspection

was

performed

during

this

assessment

period.

For the purpose of this assessment,

this area is defined

as the

ability of the

licensee

to identify

and

correct

their

own

problems.

It

encompasses

all

plant activities,

all

plant

personnel,

as well

as

those

corporate

functions

and

personnel

that provide services

to the plant.

The plant and corporate

QA

staff have responsibility for verifying quality.

The rating in

this

area

specifically

denotes

results for various

groups

in

achieving quality,

as well as the performance of the

QA staff in

verifying that quality.

The content of the audit reports

and their related checklists

have

been

demonstrating

improvement

during

the

assessment

period.

The specifics

as to what

was

examined,

how examined,

sample

size

considered,

accept/reject

criteria

used,

and

the

acceptability

of the

audited

items

are

now routine checklist

comments.

The site

survei1 lance

group

performs

approximately

25<o

performance

based

type

inspections

(identifying safety-

problems).

An increase

in the percentage

of

performance

based

inspections

has

been

noted during the review

period.

Nanagement

has

become

more

active

with promptly correcting

identified problems.

This was demonstrated

by the project Vice

President

requiring that all

requests

for extending

response

times for Nonconformance

Reports receive his personal

approval.

This has

been effective in reducing

the

nunber nf requests

for

extensions.

The

resident

inspector,

as

part

of routine

inspections

in

various site activities,

evaluated

the administrative

controls

which may affect quality at the site.

The specific points which

were evaluated

included:

site

gC inspection

and surveillance

of

operations

and

maintenance

activities, control of nonconforming

materials

and

conditions,

gC holdpoint instructions,

and

the

licensee's

corrective

action

as it affects

repeat violations.

With the exception of the two violations discussed

below,

these

areas

appeared

satisfactory.

The first of the

violations

occurred

as

a result of the licensee

allowing repeated

breaching

of the containment building integrity.

The

second resulted

from

the

licensee's

fai lure to

take

prompt corrective

action

on

conditions

adverse

to quality.

This violation involved

a

known

problem with valves

installed

in

the

reactor

coolant

vent

system.

In June

1985

and

February

1987,

the

pl.ant experienced

problems with some of these

vent valves spuriously opening while

being tested.

The licensee

has

since

taken

steps

in an effort

to prevent these conditions

from recurring.

In

summary,

the licensee

had

demonstrated

both weaknesses

and

strengths

in identifying and correcting safety related

problems.

The ability to identify and correct safety related

problems

was

evidenced

by:

Implementation of a task force

recommended

improvements for

the

secondary

plant

(condensate

and

systems),

.

resulting in increased

plant performance, with no subsequent

trips attributed to secondary

system interaction.

Implementation

of

programs

to monitor plant

status

and

prevent

component

failures (i'

maintenance

feedback

program

and live load program),

involvement of operations

technical

support

in

plant

status

and

problems,

and

implementing

a

reactor

protection

system

specific

instrumentation

and control crew.

25

Improved

level

of operator

and

management

challenge

in

emergency drill scenarios.

The inability to either identify or once identified, correct

safety related

problems

was

shown in the following occurrences:

Inadequate

corrective action that led to repeat

breaching

of containment building integrity.

Untimely

corrective

action

in

resolving

operational

deficiencies

wi,th reactor

coolant vent system valves.

A

non-conservative

interpretation

of

Technical

Specifications

led

to

operating

with

a

stuck

open

containment isolation valve in the

steam generator

blowdown

line for 29 days.

Two violations were identified.

a.

Severity

Level

IV violation for failure to prevent

a repeat

violation of breach

of the containment

building integrity

(400/87-40-01).

b.

Severity

Level

IV violation for fai lure to take

prompt

corrective

action 'on reactor

coolant

system

vent

valves

with known operational

defects

(400/87-40-03).

2.

Conclusion

Category:

2

3.

Recommendations

NRC staff resources

applied to the routine inspection

program

should

be maintained.

Licensing Activities

1.

Analysi s

The licensee

generally continued to exercise

management

control

and overview in the licensing activity area.

The licensee

had

frequent

meetings,

visits

and

management

discussions

with the

NRC staff which assisted

in

a clear

understanding

of safety

issues

and

the

need

for timely resolution.

There

was

a

reasonable

balance

between

the licensee'

resources

utilized to

improve plant performance/generation

and the resources

utilized

in the

enchancement/improvement

of overall

plant

safety.

The

licensee

recently assigned

an individual from the Central

Design

Organization

located

in Raleigh,

NC to coordinate

e'ngineering

activities with the Harris plant, to enhance

completion of plant

26

performance

objectives

from

both

safety

and

regulatory

considerations.

Although

the

licensee's

management

continued

to

be

heavily

involved, increased

emphasis

in the development

of the basis

in

a

few of

the

licensee's

initial

amendment

submittals

with

respect

to

the

"No

Significant

Hazards

Considerations

Determination"

would have further enhanced

the overall quality

of submittals.

Notwithstanding this observation,

the technical

quality

of

submittals

was

quite

good.

Moreover,

once

identified, additional

information was expeditiously provided.

During

this

assessment

period

the

licensee's

management

involvement

was

demonstrated

in various

issues

such

as its

response

to

a potential

single failure associated

with a D.C.

bus; participating

as

the

lead Westinghouse

plant in removing

the

organizational

charts

from the

Technical

Specifications;

undertaking

an extensive effort to identify potentially suspect

pipe fitting material

in response

to

NRC Bulletin 88-05,

and

continued participation

in the Westinghouse

Technical

Specifi-

cation

Improvement

Program.

Moreover,

once

the

licensee

became

aware of the

need for the

issuance

of an

emergency

amendment

relating

to

a

diesel

generator,

coordination

was

promptly

initiated with the

NRC staff in order to provide sufficient time

to effectively process

the

amendment

request.

However,

in one

instance

a

non-conservative

interpretation

of the

Technical

Specifications

allowed

continued

operation

with

a

stuck

open

containment

isolation

valve

located

in

the

steam

generator

blowdown line for

a period of

29

days

without the

licensee

taking

compensatory

actions.

(See Violation d. in Section

IV.A

of this report.)

This indicates

there

may

not

be sufficient

controls to assure

proper management

of Technical Specification

interpretations

so that

operation

in

non-conservative

modes

without compensatory

measures

does

not occur.

The

licensee's

approach

to resolving technical

issues

from

a

safety

standpoint

was technically

sound

and

very

thorough

in

most instances.

The licensee's

management

actively pursued

an

aggressive

policy of quality control

on Technical

submittals/

amendments

which

generally

resulted

in

a quality

product.

'icensing

personnel

continued to demonstrate

a strong technical

understanding

of technical

issues

and usually were communicating

with the

NRC licensing Project

Manager

on

a daily basis.

This

interaction with the

NRC Licensing Project Manager

and other

NRC

staff resulted

in a clear understanding

of safety issues

and in

the timely submittal

of various licensing

and technical 'issues

and

minimization of

the

slippage

of mutually

agreed

upon

completion dates.

The licensee,

in cases

where generic

issues

arose,

utilized industry

owners

groups

to obtain

satisfactory

resolution.

27

The

licensee's

responses

to. NRC initiatives

were

prompt

and

generally

complete.

The licensee's

membership

in a significant

number of owners groups

was

an indication of their

commitment to

keep abreast

of acceptable

solutions of generic

issues

that were

applicable

to the Harris plant.

The licensee's

responsiveness

has

also

been

demonstrated

by timely submittals

on various

NRC

Bulletins and Generic Letters.

The licensee

promptly responded

to various

surveys, conducted during this rating period.

The technical

quality of the licensing staff assigned

to the

plant

was excellent.

There

were five full time individuals

assigned

to the various licensing activities'n

comparison

to

other facilities, the

number of licensing personnel

appeared

to

be

small;

but,

considering

their

very timely submittals

and

responsiveness

to

various

NRC initiatives,

the

number

was

adequate.

These

individuals

are

located

in

the

licensee's

corporate

headquarters

in Raleigh,

North Carolina,

which is

.approximately

16 miles

from the plant.

This proximity to the

plant facilitated better

communication

and

understanding

of

plant objectives

and regulatory requirements.

In addition,

the

licensee

has extensive

laboratory capabilities

in the Energy

and

Environmental

Center

in very close

proximity to the

Shearon

Harris site.

These

groups

are

available

to

interface

on

licensing

issues

when

needed

and

performed quite well.

At the

end of the

assessment

period,

there

were

seven

individuals in

the

on-site

Regulatory

Compliance

Group

who

handled

the

day-to-day regulatory interface with the

NRC inspectors

and

NRC

Regional staff.

2.

No violations or deviations

were identified.

Conclusion

Category:

2

Trend:

Improving

3.

Recommendations

The licensee's

performance

in this 'functional area,

while. still

considered

good, declined early during, the

SALP period from the

I rating.

This decline

is attributed,

in

part, to the transition from construction

type licensing activi-

ties to operating activities.

Specifically, this was evidenced

by less

than

adequate

"No Significant

Hazards

Consideration

Determinations"

and

the

non-conservative

interpretation

of

Technical

Specifications.

The licensee's

performance

in the

latter part of the

SALP period indicates that these transitional

problems

may have

been

resolved.

28

K.

Training and Qualification Effectiveness

l.

Analysi s

Three

sets

of licensing

examinations

were administered

during

the

assessment

period.

The first of these

were

given

August

4-5,

1987,

to three Senior Reactor Operators

(SROs).

The

exams

involved all three

SROs

on the simulator

and

one

SRO oral.

All

three

SROs

passed

the respective

sections.

SRO license

examinations

were administered

November 18-19,

1987,

to four

SRO candidates.

Examination results yielded

a pass

rate

of 75io (3 of 4) for the

SRO candidates.

Initial license

examinations

were given to

11 Reactor Operators

(ROs)

and

a retake

given to one

SRO

on April 25-28,

1987, with

all of the candidates

passing their examinations.

Overall, the

pass

rate for all examinations

administered

during the

assess-

ment period was

95/o (18 of 19).

An inspection

was performed to assess

the licensee's

compliance

with Generic Letter 81-21

involving the

upper

head

voiding

during

the

Natural

Circulation

Cooldown

at

St.

Lucie.

The

inspection

reviewed the training curriculum

as well

as attend-

ance

and test

records.

The training curriculum was comprehen-

sive,

the records

were complete,

and all licensed operators

had

received

the required training in this area.

As

indicated

under

the

specific

functional

areas,

training

activities

encompassed,

to

an extent,

all

areas.

To

reduce

plant trips

caused

be

personnel

error, intensified "Real Time"

training was

used

by the Operations

group to acquaint

operators

with revisions

to

procedures

and

lessons

learned

'which

have

resulted

from plant events

and

incidents.

Training

conducted

under

the

general

employee

radiation

program,

as well

as that

given under the health physics technician's training program was

found

to

be

acceptable.

The fire

protection,

emergency

preparedness,

and

security

groups all. made

use

of frequent

trai ning

and

drills/exercises.

When

made

aware

of

the

importance for expedient initial dose calculations,

the licensee

aggressively

trained

all

applicable

reactor

operators

and

radiological

personnel.

In the

case

of security,

an on-shift

training

program

had

been

implemented

during

the evaluation

period.

Under this

new program,

some

200 training sessions

and

an equal

number of drills had

been

conducted

to enhance

security

force training.

Training program weaknesses

were identified in

the

area

of environmental

qualifications

(EQ).

In recognition

of these

weaknesses,

the licensee

had

begun

development

of

lesson

plans

for

indoctrination

and

training

of personnel

towards the

end of the evaluation period.

No violations or deviations

were identified.

29

2.

Conclusion

Category:

1

3.

Recommendations

None.

L.

Engineering

Support

1.

Analysi s

This area

was routinely evaluated

by the resident

inspector

and

the regional staff.

Also, special

inspections

were conducted

in

the areas

of equipment qualification (Eg) and design

changes.

Until early 1988,

the licensee

operated

two separate

engineering

organizations

at

the site.

One of the organizations,

Harris

Plant

Engineering

Section

(HPES),

reported

to

the

Milestone

Completion Manager.

HPES performed

as

a design

group to support

the initial start-up efforts and to complete

any remaining major

design 'efforts.

Upon completion of these

design responsibilities,

management

reorganized

the design

organization

to require that

all design efforts

be

conducted

through

the off-site Central

Design Organization.

This group

wi 11 act

as

the

A/E and

wi 11

reduce

the

licensee's

reliance

on

outside

consultants

and

temporary

personnel.

The staffing of the

engineering

design

organization

was

more

than

adequate.

The

training

and

qualification of design

personnel

was quite good

as demonstrated

by the

large

number

of design

personnel

who

have

obtained

professional

registration

by

examination

and

advanced

engineering

degrees

from accredited

universities.

Part of the

responsibilities

of this design

group

includes

managing

the

Eg

maintenance

program.

The

second

engineering

support

group

is

part

of

the

site

organization

for plant

operations.

The

group,-

Operations

Technical

Support,

reports

to the Plant

General

Manager.

This

group

has

been very active with numerous technical

issues

which

relate to the plant and its systems.

Some of the. specific areas

in

which

they

have

'provided

technical

guidance

include:

investigating

more

than

40 issues

which relate

to Limitorque-

supplied

motors;

the

erosion/corrosion

program

which

was

implemented

early during this

SALP period;

and

guidance

for

operations

technical

trends.

They provided considerable

input

to the plant maintenance

work request

system to aid in setting

up

a method for priority based

on plant safety

and reliability.

They review each

work request

to maintain

awareness

of plant

problems

and to maintain their sensitivity to the

need to assure

plant safety.

-This group has

been

very beneficial

to the

safe

operation'f the Harris plant.

30

During this

assessment

period,

several

significant deficiencies

in design, installation,

and fabrication were addressed

in LERs.

One of the significant events

was

the determination

that the

loss of a specific

DC bus coincident with loss of offsite power

would result

in isolation

of the auxiliary

system

(87-054).

Another event

involved the potential

for excessive

flow rates if only

one

low

head

safety

pump is operating

following switchover to the recirculation

mode after

a

large

break

LOCA (88-001).

In the two situations

discussed

above,

the

license'e

took

necessary

actions

to correct

the

identified

deficiencies.

A potentially more serious situation

was noted in

the

low temperature

overpressure

prctection

system

which would

automatically actuate

the relief valves

under steamline

break or

steam

generator

tube

rupture

accidents

coincident

with

a

specific single failure (88-011).

The automatic

arming of the

protection

system

was

removed to correct this situation.

In

March 1988,

a

special

inspection

team

evaluated

the

licensee's

program.

The

points

evaluated

during

the

inspection

included:

. the

licensee's

implementation

of

10 CFR 50.49, plant walkdown inspections

of electrical

equipment

within the

scope of 10 CFR 50.49,

and

a follow-up on previously

identified

EQ deficiencies.

The

team

found

the

licensee's

programs

and procedures

for the

EQ program to be acceptable

and

no violations were identified by the inspectors.

Licensee

management

appeared

to

be

sensitized

to

the

significance

and

importance

'of having

an

adequate

EQ Program.

The

licensee

identified during

the

entrance

meeting

several

planned

EQ program enhancements

(some of which were in-progress

during the inspection)

which were to be incorporated into the

Program

lessons

learned

from the Brunswick and

Robinson

NRC

Audits.

This information would enhance

Harris

EQ. procedures

and

data

packages,

and

increase

awareness

training for plant

personnel.

In most

cases,

licensee

responses

to

NRC initiatives

on

issues (i.e.,

IENs/IEBs) have

been timely with technically

sound

and

thorough

responses.

One

exception

was

the

licensee's

failure to identify and establish qualification of crimped type

connectors

in Limitorque dual voltage motors.

The

EQ maintenance

program was reviewed

by examining maintenance

procedures,

maintenance

histories

of

equipment,

and

preventive maintenance

schedules.

These

documents

were compared

with the

requirements

set

forth

in

the

Qualification

Data

Packages

(QDPs)

and

were

found

to

be

well

organized

and

controlled,

as well as,

accurate

and acceptable.

The

schedule

for replacement

of EQ equipment at the

end of its qualified life

was

also

reviewed

and

found acceptable.

Problems

previously

identified in the

EQ maintenance

area

were corrected

in a timely

manner.

31

During

the

later

part

of

1987,

a

special

gA effectiveness

inspection

reviewed

the

area

of design

changes,

Inspectors

reviewed

17

design

changes,

reviewed

engineering

and

10 CFR 50.59 evaluations,

performed

some

system walkdowns,

and reviewed

temporary modifications.

Design

basis

documentation

was

also

reviewed

and

determined

to

be excellent.

In all, the

Design

Change

program

was considered

to be adequately

controlled,

with

the exception of one design

change that did not provide adequate

detail

of protective

and control

functions for fuse

removal.

This

lack

of

detai l

caused

a

reactor trip.

A violation

(identified as

a.

below) was issued

in this area.

A review of IE Bulletin 85-03

program indicated

some corporate

" involvement

in site activities

in that

problems

encountered

during

the

performance

of other

CPE L facility Bulletin 85-03

programs

have

also

been

evaluated

for applicability to Shearon

Harris.

For example,

the circuit logic problem associated

with

DC motor operated

valve actuators

was originally identified at

the Brunswick facility, but was also

found to

be applicable

at

Shearon

Harris.

The procedures

that

govern

the Bulletin 85-03

program

were well stated,

controlled,

and explicit. .It was

apparent

that

when

IE Information Notices

were

issued

that

address

motor

operated

valve

problems,

the

licensee

revised

applicable

procedures

to

recognize

the

IE Information

Notice

condition.

The licensee's

development of the

IEB 85-03

program

was viable but lacked thoroughness

in that motor operated

valve

operation

at

degraded

voltages

and

testing

for inadvertent

backseating

should

have

been

considered

but

were

not.

The

bulletin program action

items

by the

licensee

were

completed

prior to the bulletin deadlines.

The final response

was

due by

January

1988,

and the

Shearon

Harris final response

was

issued

on March 1987.

During the evaluation period,

two inspections

were conducted

by

regional

based

inspectors

to followup on allegations

pertaining

to alleged

improper design

practices.

None of the allegations

were substantiated.

These allegations

concerned

improper design

verification practices

in design of structural

steel.

During

the inspection effort,

one violation was identified concerning

fai lure tn follow design

control

procedures

in design of cable

tray supports.

This violation was not directly related

to the

allegations.

Licensee

management

was extensively

involved in design

review

activities required to resolve the concerns

(allegations).

This

involved retaining consultants

to perform

an

independent

study

of structural

steel

design methodology,

and assigning

personnel

to

perform

in-depth

review

of

structural

steel

design

calculation

and prepare alternate calculations.

Decision making

in

these

activities

was

at

a

level

which

ensured

adequate

management

review.

Records

(design calculation

packages)

were

complete,

well

maintained,

legible

and

retrievable.

The

32

licensee's

approach

to resolution of the concerns

from a safety

standpoint

demonstrated

a clear understanding

of the issues,

and

a

technically

sound,

conservative

and

thorough

approach.

Responsiveness

to these

NRC initiatives resulted in timely

resolution of the concerns.

Two violations were identified.

a.

Severity Level

IV violation for failure to provide adequate

detail

of. protective

and

control

functions

for

fuse

removal.

(400/87-38-02)

b.

Severity

Level

IV violation for design engineering failing

to identify the

reasons

why the

design

basis

accident

temperature

values

were

changed

when calculating

thermal

stresses

in the containment

building for

LV-66,

a

cable

tray riser frame.

(400/87-41-02)

2.

Conclusion

Category:

2

Trend:

improving

3.

Recommendations

NRC staff resources

applied to the routine inspection

program

should

be maintained.

V.

SUPPORTING

DATA

A.

Licensee Activities

The plant operated

in its first fuel cycle throughout the assessment

period.

The plant

achieved

commercial

operation

on

May 2,

1987,

prior to the beginning of the assessment

period,

and operated

at

an

coverall

availability of

83 percent

and

a capacity

factor of

80

percent.

The operation

included

two periods of continuous

operation

in excess

of 120 days.

Outages

in excess

of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months

occurred

in

order to correct problems with steam generator

blowdown valves (July

16-22,

and

September

12-14,

1987),

to correct

a design

and analysis

deficiency relating to the

single

failures

assumed

in

DC

power

supplies

(September

15-25,

1987),

and to correct failure of turbine

extraction

steam bellows (March 20-27,

1988).

Each of these

outages

was initiated by

a controlled

shutdown of the plant.

A scheduled

outage

was

conducted

October

9-November

7,

1987.

The

purpose of the outage

was to complete

visual

inspection

of snubbers

required

by Technical Specifications,

to complete other survei llances

which would allow continued

operation

to the

scheduled

refueling

outage,

and to install major modifications to the main feedwater

and

.condensate

systems.

The latter item completed the

implementation

of

33

recommendations

of

a licensee

task force which was initiated during

the power ascension

test

program to investigate and'esolve

the root

cause

of control

instabilities

in

the

and

condensate

systems.

The net result of these

changes

was

improved reliability

from these

secondary

systems.

Consequently,

none of the six reactor

trips which occurred

in the twelve months of this

SALP period

were

due to secondary instabilities.

B.

Inspection Activities

During the

assessment

period,

routine inspections

were performed

by

the

resident

and

regional

staffs.

Special

team

inspections

were

conducted

in

the

areas

of

Equipment

gualification

and

guality

Assurance

effectiveness.

An emergency

response

facilities appraisal

was conducted during the partial participation

emergency

exercise.

C.

Investigation

Review

None

D.

Escalated

Enforcement Actions

1.

Civil Penalties

No escalated

enforcement

actions

were issued during this period.

2.

Orders

None

E.

Management

Conferences

September

17,

1987

Management

meeting

at

Bethesda,

Maryland

to

discuss

the Technical

Specification

improvement

program

as it relates

to Generic Letter 87-09.

October

1,

1987,.

Management

meeting

at

the

Harris

Energy

and

Environmental

Center for a discussion

of the

Board assessment.

October

21,

1987

Enforcement

Conference, at

Region II to discuss

the

loss of steam

generator

blowdown isolation

capability

between

August

13

and

September

13,

1987,

and

a technical

meeting

at

Region II to

discuss

a

DC

power

design

problem

affecting

auxiliary