ML18009A511

Electrical Distribution Sys (Eds) Functional Insp Rept 50-400/90-200 on 900212-0316.Major Areas Inspected:Eds & Adequacy of Associated Engineering & Technical Support

ML18009A511
Person / Time
Site:	Harris
Issue date:	04/27/1990
From:	Gautam A, Konklin J, Lanning W Office of Nuclear Reactor Regulation
To:
Shared Package
ML18009A509	List: ML18009A508 ML18009A511
References
50-400-90-200, NUDOCS 9005030336
Download: ML18009A511 (49)

See also: IR 05000400/1990200

Text

ENCLOSURE

1

U.S.

NUCLEAR REGULATORY COMMISSION

OFFICE

OF NUCLEAR REACTOR REGULATION

NRC Inspection Report:

50-400/90-200

License No.:

NPF-63

Docket:

50-'400

Licensee:

Carolina

Power 5 Light Company

Facility Name:

Shearon

Harris Nuclear Power Plant

Inspection at:

Shearon Harris Plant,

New Hill, North Carolina

Inspection Conducted:

February

12 through t1arch 16,

1990

NRC Consultants:

R. McFadden,

SAIC

J. Houghton,

RTS

p,

n

.

au

a

,

earn

ea er

Team Inspection Section

A

Special

Inspection

Branch

Division of Reactor Inspection

and Safeguards

Office of Nuclear Reactor Regulation

Approved by:

Inspection

Team:

Anil S. Gautam,

Team Leader,

NRR

Jeffrey B. Jacobson,

Operations

Engineer,

NRR

Thomas

G. Dunning, Senior

Reactor Engineer,

NRR

Peter J.

Kang, Electrical Engineer,

NRR

David L. Solorio, Nuclear Engineer,

NRR

Victor N. NcCree, Operations

Engineer,

NRR

Paul J. Fillion, Reactor Inspector,

RII

Norman Herriweather,

Reactor Inspector,

RII

a e

gne

Approved by:

es

.

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earn Inspection Section

A

Special

Inspection

Branch

Division of Reactor Inspection

and Safeguards

Office of Nuclear

actor Regulation

Approved by:

ay

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.

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Specia

Inspection

Branch

Division of Reactor Inspection

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Office of Nuclear Reactor

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EXECUTIVE SUMMARY

A Nuclear Regulatory

Commission

(NRC) team conducted

an electrical distribution

system functional inspection

(EDSFI) at the Shearon

Harris Nuclear Plant in

New Hill, North Carolina.

The inspection

was conducted

by the Special

Inspection

Branch of the Office of Nuclear Reactor Regulation

(NRR) from

February

12 through March 16, 1990.

The

NRC inspection

team reviewed the design

and implementation of the plant

electrical distribution system

(EDS),

and the adequacy

of associated

engineer-

ing and technical support.

To accomplish this, the team reviewed the design of

electrical

and mechanical

systems

and equipment affecting the

EDS, examined

installed

EDS equipment,

reviewed

programs

and procedures

affecting the

EDS,

and determined

the adequacy

and interfaces of technical disciplines

and func-

tions by interviewing appropriate

corporate

and site personnel.

Overall, the design

and implementation of the

EDS at Shearon

Harris was consid-

ered

by the team to be adequate.

The design attributes of the

EDS were well

documented,

retrievable,

and verifiable.

In most cases,

engineering calcula-

tions had conservative

assumptions

and margins

and were technically sound.

The

scope of the site test program for

EDS equipment

was appropriate.

Engineering

control of modifications to the

EDS appeared

to be effective and there appeared

to be proper interfacing between engineering disciplines

and functions.

EDS

equipment

was properly installed in the plant and, in most cases,

had adequate

traceabi lity to design

documents.

Few deficiency tags

were observed

and the

equipment appeared

to be well maintained.

Engineering

and technical

support

for the

EDS was sufficient in number and the engineering staff appeared

to be

competent.

The team identified deficiencies in the licensee's

design control program,

involving the selection

and verification of the design of EDS equipment in the

electrical

and mechanical

areas,

including LK-16 power breakers,

commercial-

grade electrical breakers

and relays,

emergency

load sequencer

relay contacts,

the emergency

diesel generator

(EDG) air tank relief valves,

EDG lube oil and

jacket water heaters,

and the

EDG air receivers.

Inadequate

design evaluations

to justify the qualification of the equipment to perform its safety function

and to rreet plant procedures

and licensee

commitments

were considered

to be a

weakness

in the design control program.

The inability of the licensee's

engineering'nd

technical

support staff to

determine root causes

and to take effective corrective actions for problems

involving the Brown Boveri LK-16 circuit breakers,

the emergency

load sequencer

relay contacts,

and the qualification of commercial

grade breakers

and relays

is considered

to be

a weakness

requiring additional

management attention.

The

licensee

committed to determining the root cause of the LK-16 breaker failures

by the end of March 1990.

The licensee further committed to complete testing

of the emergency

load sequencer

relay contacts

by September

1, 1990,

and to

demonstrate

the qualification of the commercial

grade breakers

and relays prior

to start

up from the next outa ge.

J

<E.

0

The team identified further concerns

regarding the licensee's

design control

program, involving translation of the plant design basis to specifications,

procedures,

instructions,

and drawings.

It appeared

that insufficient efforts

had been

made to update, revise, or correct information in design

and installa-

tion documents,

including electrical

and mechanical

design calculations

and

drawings.

These

inadequacies

and the lack of an effective program to maintain

and update these

documents warrant additional

management attention.

The team also identified deficiencies

in the licensee's

testing of EDS

equipment

such as discrepancies

in the allowed battery electrolyte temperature,

the specifications for the testing of 480-V power circuit breakers,

an

incorrect relay setting in the field, and the lack of testing of various

underground

cables.

These deficiencies

were considered

indicative of a

weakness

in the test control program.

The team

had

no immediate safety

concerns with regard to the above-mentioned

deficiencies,

because

the licensee

performed safety evaluations

during the

inspection to determine

any adverse effects from these issues,

and performed

corrective actions for some of the issues.

The team noted that,

because

of the steadily increasing electrical

demand

on

the 230-kV grid in the Raleigh/Durham area,

the grid voltage

was steadily

decreasing.

The licensee's

aggressive efforts to ensure that the grid remained

a reliable source of quality power for EDS equipment during emergency

condi-

tions was considered to be

a strength.

TABLE OF CONTENTS

PAGE

EXECUTIVE SUMMARY ... ~ . ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ .o ~ ~ ~ ~ ~ ~ ~

~ ~ "

loO

INTRODUCTION

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~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~

1

2.0

ELECTRICAL SYSTEMS DESIGN .... ~ . ~ ~ ~ ~ .. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ . ~ ~ ~ . ~ .. ~...

~ ~ ~ ~ ~ ~ . ~

2

2.1

Regulation of EDS Loads........................................

2.2

Overcurrent Protection ........................................

2.3

Coordination of Protective

Devices ............................

2 .4

Conclusions ...................................................

2

4

5

5

3.0

MECHANICAL SYSTEMS

~....

~ ~ ~ . ~ ~ ~ ~ . ~ ~ ~ ~ ~ ~ . ~ ~ .. ~ ~ ~ ~ ~ ~ . ~ .. ~ ~ ~ ~ ~ ~ ...

~ ~ ~ . ~

5

3.1

EDG Air Tank Relief Valves ............................

3.2

EDG Lube Oil and Jacket

Water Heaters .................

3.3

EDG Air Receivers ......................."..."....."

3.4

Design Basis Documents Deficiencies ...................

3o5

Conclusions

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~

7

7

8

~ ~ ~ ~ ~ ~ ~ ~

6

~ ~ 0 ~ ~ ~ ~ ~

7

4oO

EDS E(UIPMENT

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~

8

4.1

Equipment

Walkdowns ...........................................

4.2

Equipment Modifications .......................................

4.3

Equipment Testing

and Calibration .............................

.4

Conclusions

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~

9

9

11

13

5.0

ENGINEERING AND TECHNICAL SUPPORT . ~~.........

~ .. ~ ~ ~ ~ ~ ~ .~..... ~ ~....

14

5.1'rganization

and

Key Staff ...........................

5.2

Root Cause Analysis and Corrective Actions ...........

5.3

Engineering

Involvement in Design

and Operations .....

5 ~ 4

Conclusions

~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

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14

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15

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15

~ .~

15

6eO

GENERAL CONCLUSIONS

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15

Appendix A

Deficiencies .......................................

Appendix

B

Personnel

Contacted ................................

~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~

~ . ~

A-1

~ ~ ~

B

1

J

P

1

0

'.0

INTRODUCTION

The Nuclear Regulatory

Commission

(NRC) staff identified several electrical

distribution system

(EDS) deficiencies

during recent electrical inspections at

operating plants.

The Special

Inspection

Branch initiated inspections of the

electrical distribution system

(EDS) at all operating nuclear plants after it

determined that such deficiencies

could affect the

EDS power sources

and

equipment

and could compromise the design safety margins of nuclear plants.

The

NRC considered

one cause of these deficiencies to be inadequate

engineering

and technical

support.

Examples of these deficiencies

included unmonitored

and

uncontrolled

load growth on safety buses

and inadequate

engineering modifica-

tions, design calculations, testing of EDS equipment,

and qualification of

commercial

grade equipment in safety-related

applications.

The objectives of this inspection were to assess

the performance capability of

the Shearon Harris

EDS and the capability and performance of the licensee's

engineering

and technical

support in this area.

For the purposes

of this

inspection,

the

EDS included all emergency

sources of power and associated

equipment providing quality power to systems relied upon to remain functional

during and following design basis events.

The

EDS components

included the

emergency diesel generators;

125V dc Class

1E batteries;

two offsite circuits

from the 230

kV offsite power grid switchyard; distribution transformers;

6.9kV

switchgear;

480V ac load centers;

480V ac,

120V ac,

and

125V dc motor control

centers;

and other electrical

components

such

as battery chargers,

inverters,

associated

buses,

breakers,

relays

and devices.

The team reviewed the adequacy

of emergency onsite

and offsite power sources

for EDS equipment,

the regulation of power to essential

loads, protection for

postulated fault currents,

and coordination

of the current interrupting capa-

bility of protective devices.

The team reviewed mechanical

systems affecting

the

EDS including air start,

lube oil and cooling systems for the emergency

diesel generator

as well as cooling and heating

systems for EDS equipment.

The

team physically examined originally installed

EDS equipment

and modifications

for configuration and ratings

and reviewed qualification testing

and calibra-

tion records.

The team also assessed

the capability and performance of the

licensee's

engineering

and technical

support functions with regard to organiza-

tion and

key staff, timely and adequate

root-cause

analysis for failures and

recurring problems

and engineering

involvement in design

and operations.

The team verified conformance with General

design Criteria

(GDC) 17 and

18 and

appropriate criteria of Appendix

B to 10 CFR Part 50.

The team reviewed plant

Technical Specifications,

the Final Safety Analysis Report,

and appropr iate

safety evaluation reports to verify that technical

requirements

and licensee

commitments

were being met.

The areas

reviewed

and the safety significance of identified deficiencies

are

described

in Sections

2, 3, 4, and

5 of this report.

Conclusions

are provided

at the end of each of these sections.

A summary of the conclusions

and weak-

nesses

is given in Section

6 of this report.

Each deficiency addressed

in the

report is provided in Appendix A with a corresponding

deficiency

number

and

a

reference

to the section of this report in which it is discussed.

A list of

personnel

contacted is provided in Appendix

B and persons

attending the exit

meeting are indicated with asterisks

before their names.

'1

I

0

2.0

ELECTRICAL SYSTEMS

DESIGN

The team reviewed

a sample of specific electrical

design attributes at each

ac

and dc voltage level of one

EDS train to determine

conformance with plant

design

and operational

requirements.

Areas reviewed included the plant load

study for regulation of electrical

loads

needed for the safe

shutdown of the

plant, the overcurrent protection study including short circuit and ground

faults,

and the sizing and coordination of protective devices.

The team reviewed

a number of documents

related to loads associated

with the

plant electrical distribution system.

The documents

reviewed addressed

design

calculations for ac and dc system loading, voltage regulation during normal

and

degraded

conditions, voltage regulation during sequencing

of safety-related

loads onto the emergency

diesel

generators

(EDGs); degraded

voltage relay set

points,

Class

1E battery selection,

short circuit and ground-fault analysis,

fault current system protection, protective device coordination,

and emergency

diesel generator neutral grounding.

The team also reviewed design basis

documents

for electrical distribution systems;

Carolina

Power and Light Company

(CPSL) Nuclear Engineering

Department

(NED) procedures

and guidelines governing

design calculations,

design control, engineering

assurance,

and plant modifica-

tions;

a random

sample of plant change

requests

(PCRs) related to the electri-,

cal distribution system;

several

randomly selected

NED design deficiency

reports

(DCRs); reports

on

EDG qualification tests

and ac system voltages

during degraded

voltage conditions

(response

to

NRC Branch Technical Position

PSB-1);

and electrical distribution system single-line, schematic,

and protec-

tive relay setting drawings.

2.1

Regulation of EDS Loads

The team reviewed (I) the availability of independent

EDS power supplies in

accordance

with GDC 17 of Appendix A to 10 CFR Part 50 and the capacity of

these

power sources

(emergency

diesel generators,

batteries,

and offsite power)

to provide quality power for essential

Class

1E loads

as well as to nonessen-

tial loads,

and (2) the effects of a single failure concurrent with loss of

offsite power, with regard to energizing essential

EDS, loads.

Each

power

source

was currently capable of and available for the operability of the

EDS

arid was within regulatory requirements.

2.1.1

Plant Load Study

Calculation DAC-l, the master

ac voltage, loading,

and fault current calcula-

tion for Shearon Harris, was developed

using the personal-computer

(PC) version

of the load flow program,

AUXSYS4078, entitled "Users Manual for Electrical

Auxiliary System Design."

This computer

code

was developed

by Ebasco.

The licensee validated the AUXSYS4078 program, which was originally designed to

run on a mainframe

computer,

by comparing its output with the results of hand

calculations for a typical set of EDS components

and loads.

This program

has

since

been modified to a

PC version

and the licensee

acquired only the

PC

version of the program for use.

The

PC version cannot

be modified, and there-

fore, only the input and output data from the code

needed to be under design

control at CP8L.

This data

was controlled properly under

NED Guideline E-4 and

other procedures.

Ebasco maintained the AUXSYS4078 source

code under its

engineering quality assurance

program

(NRC audited)

which ensures

that the

licenisee will receive timely error notices

and

code modifications.

In response

to

NRC Branch Technical Position PSB-l, the licensee

conducted

a

series

of system voltage tests with nearly-full-scale

loading before plant

startup.

The voltages

measured

during these tests

were equal to the voltages

predicted

by calculation

DAC-I under the

same

system conditions within the

3 percent

acceptance

limit of the branch technical position.

The team also

performed

a limited validation of the licensee's

test results

by taking voltage

readings

from the switchgear voltmeters at most of the accessible

Class

lE

6.9kV and 480Y buses.

These voltages

were within a reasonable

margin of the

voltages calculated in DAC-1 for normal

power operation.

The

NED had

a policy of updating calculation

DAC-1 annually to incorporate

any

changes

in the short circuit capacity

and voltage of the 230-kV grid.

2.1.2

EDG Load Sequencing

Calculation

EDG load sequencing

calculation

17-EP, "Analysis for Diesel Generator

Load

Sequence

Voltage Profile," established

the minimum voltage available at the

6.9kV emergency

buses

during the sequencing

of safety-related

loads onto the

EDG to be used

as input to other system loading and voltage calculations.

The

team found various deficiencies

in the methodology,

assumptions,

justifica-

tions,

and validation of the input data

and the computer

code used.

The

licensee

stated that

a transient

loading test performed

on the

EDG and docu-

mented in the "gualification Test Report for TDI Standby Generator Set" vali-

dated the calculation.

This test enveloped plant conditions

and provided

reasonable

assurance

that the results of the calculation were conservative for

specific conditions.

However, the team concluded that, prior to this inspec-

tion, adequate

design control measures

had not been taken

by the licensee

to

verify the adequacy of the calculation.

The team considered this to be

a

weakness

in the design control program (see Appendix A, Item Number 90-200-01).

Additional examples that illustrate weaknesses

in the design control program

are discussed

in Sections 3.1, 3.2, 3.3, 3.4, 4.2.1,

and 4.2.3 of this report.

Pending further review by Region II of corrections

and revisions to this

calculation, this is considered

an unresolved

item (see Appendix A, Deficiency

Number 90-200-01).

2.1.3

Voltage Transients

To protect against

adverse effects

on the

EDS resulting from degraded grid

voltage conditions, all licensees

of operating reactors

are required to provide

a second level of undervoltage

(degraded grid voltage) protection with time

delay.

This requirement is based

on

NRC Multiple Plant Action (MPA) B-48,

which later became

NRC Branch Technical Position

PSB-1 entitled "Adequacy of

Station Electric Distribution System Voltages."

The licensee

performed calcu-

lation 55-JHG,

"PSB-I Degraded

Voltage Condition Relay Settings,"

dated

August 3, 1989, to select appropriate

degraded grid voltage and time delay

setpoints

from an analysis of the voltage requirements

of the Class

1E loads at

all onsite

system distribution levels.

The team found the methodology

used for

this calculation to be adequate,

and noted that the calculation

had been

revised periodically to accommodate

any grid voltage changes.

2.1.4

230kV Gr id Voltage

The team reviewed the historic trends of the 230kV grid voltage to ensure that

the grid was capable of supplying adequate

operating voltages to all safety-

related

and supporting

equipment during all power supply conditions within the

'esign

basis of the plant, including periods of high-power grid loading

and

~

~

~

relatively low-power grid voltage.

The trend

showed that, if Shearon Harris

tripped off the grid during peak

summer loading conditions,

the voltage at the

Shearon

Harris plant 230kV switchyard could drop to a value insufficient to

operate

EDS loads.

Furthermore,

the trend of the grid voltage was clearly

downward, indicating that this problem was likely to become worse in the next

few years if not corrected.

No immediate safety

concerns existed

because

the procedure

required the

CPKL

system dispatcher

to notify the Shearon

Harris control room if the system

load

approached

a limit that could lead to an inadequate

230kV grid voltage.

Under

such grid conditions,

the operators

would declare the offsite power source

inoperative

and would enter

a technical specification limiting condition of

operation.

The licensee

recognized that the grid voltage was steadily declin-

ing, and was studying short-term solutions

such

as installing capacitor

banks

in the Shearon

Harris switchyard,

as well as long-term alternatives

such

as

gas-turbine-powered

peaking generation,

to maintain

a quality power source.

The team

commended

the licensee's

aggressive effort to address this concern

and

conclude that it is important for CP&L to move ahead expeditiously in resolving

the problem.

'2.2

Overcurrent Protection

The team examined evaluations for maximum and minimum short-circuit and

ground-fault currents in calculation

DAC-1 to determine the adequacy

of the

overcurrent protection study and

compared the calculated fault currents to the

~

~

ratings of selected

installed

EDS equipment.

The computer program input (e.g.,

resistance,

reactance,

and power factors) for the cables,

main generator,

transmission

system

power transformers,

pump motors,

and diesel generators

appeared

to be adequate.

The team reviewed manufacturer

data sheets

to verify

equipment ratings

used in the calculation

and performed limited independent

computations

and determined that the calculations

were adequate

with the

following exceptions:

For the 22kV base,

the value used for the direct axis subtransient

reactance

at rated voltage (saturated)

for the main generator for the

short-circuit calculation was 0.307 per unit (pu) instead of 0.28 pu.

This computational error was in the nonconservative

direction.

The

licensee recalculated

currents with the correct value and found that no

safety margins were compromisea.

The nominal transformer tap test values

were used to represent

the trans-

former leakage

reactances.

The team was concerned,

however, that the

reactance

at the actual off-nominal taps in the field could be different

and could affect the computational results.

The licensee further

evaluated

the transformer taps

and confirmed that the methodology

used

gave

good results for the specific configuration of the plant.

The short-circuit power available at the 230kV switchyard that was input

to the computer included contribution from the main generator.

Since the

data for the main generator

was input separately,

the generator

contribu-

tion was counted twice.

This gave conservative results but was considered

to be an inadvertent error.

The calculation

used 12,034

mVA as the shor t-

E

r

t

circuit power available at the 230kV switchyard,

instead of 11,449

mVA,

which was based

on source

documents.

This represented

a computational

error in the short-circuit calculation,

in the conservative direction.

A condensate

booster

pump

1A resistance

of 0.023

was used in the calcula-

tion, but the motor data sheet indicated 0.23.

Since the resistance

is

only used to compute the impedance/resistance

ratio, this discrepancy

is

in the conservative direction.

Although several

computational

errors existed in the overcurrent protection

calculations,

no immediate safety concerns existed

because

the errors found in

the conservative direction more than offset the nonconservative

errors.

The

licensee

indicated that the short circuit calculations will be updated to

correct these errors.

2.3

Coordination of Protective Devices

The team reviewed overcurrent coordination studies

by considering

power flow

through the startup transformer to the safety-related

buses.

A review of a

sample of relays

and corresponding

calculations

showed that buses,

cables,

motors

and transformers

were protected

from damage

by the full range of possi-

'ble overloads,

normal plant transients

were properly factored into the

overcurrent relay setting,

and all of the normal design considerations

such as

current transformer burden, relay time rating,

and transformer connections

were

properly addressed.

No concerns

were identified.

2.4

Conclusions

The electrical

systems

design

complied with applicable regulatory criteria and

licensing commitments.

The margins

between required performance

and system

capabilities

were conservative

and the equipment

was sized properly.

The set

of electrical design calculations

adequately

addressed

essential

safety-related

features of the design.

The set of electrical calculations

was sufficiently complete to support the

critical aspects

of the electrical distribution system design

and were readily

retrievable.

The engineering

procedures

were generally

good.

Staff suppor t

from the licensee's

corporate

Nuclear Engineering

Department consisted of

competent staff and was sufficient in terms of numbers.

There were

a few instances

in which electrical design calculations

had mistakes

in methodology

and computation

and inadequately identified and justified

assumptions

and approximations,

references

to sources of methodology, input

data,

and information on verification of computer

codes.

There was

no formal

program to maintain

and update

design calculations

and design documentation.

3.0

YECHANICAL SYSTEMS

REVIEM

To determine the adequacy

and functionality of mechanical

systems,

the team

reviewed equipment associated

with the emergency

diesel generator

(EDG),

heating, venti lation, and air conditioning equipment associated

with the

EDG,

batteries,

switchgear,

and emergency

service water buildings.

The team conducted

a walkdown of the diesel generator air start

and fuel

~

~

~

transfer systems,

the emergency

service water pumphouse,

and the heating,

entilation,

znd air conditioning

(HYAC) systems for the diesel generator

uilding and examined various engineering

and plant operations

documents,

which

included:

selected

modifications

and safety evaluations

associated

with the

EDG and

mechanical

support systems,

reactor auxiliary building and diesel building

HVAC systems,

and emergency

service water cooling systems

interfacing with

the

EDG;

mechanical

system calculations for the diesel generator fuel transfer, air

start,

and emergency

service water

cooling systems;

diesel generator

room,

switchgear

room,

and battery

room ventilation systems;

and significant

safety-related

pump motor loads;

air flow diagrams for diesel

generator building and reactor auxiliary

building

HVAC systems;

diesel generator

manufacturer technical

manuals

and test reports;

component specification data for major mechanical

systems

components in

support of the diesel generator

system,

including

pump performance

curves

and motor data sheets,

the fuel oil day tank,

and the air start tank

relief valve;

plant set point document for fuel transfer

and air start

system

instrumentation;

plant procedures for diesel

generator

preoperational

testing of the air

start system, jacket water heat exchanger tests,

and for adverse

weather

conditions;

plant procedures for interfaces

between the diesel generator

and its

supporting

mechanical

systems

and between supporting mechanical

systems

and nonsafety-related

systems,

including single failure and seismic

criteria; and

site administrative procedure for safety reviews (AP-Oll).

The team interviewed licensee

engineering staff and site technical

support

staff associated

with mechanical

systems in support of the electrical distribu-

tion system,

the maintenance

program for the diesel generator,

and the

ASME

(American Society of Mechanical

Engineers)

Section

XI program.

The team identified a number of concerns

which are discussed

in the following

sections.

3.1

EDG Air Tank Relief Valves

There

was inadequate

documentation to determine if the

EDG Crosby air tank

relief valves were seismically qualified.

The licensee

had not performed

a

~

~

~

formal design evaluation of the seismic qualification of these

valves although

it had received

a Part

21 report of failures of these

valves at the Perry

Nuclear Plant.

However,

no action

had been taken to properly review this

information.

Based

on the team's

concern,

a formal design evaluation to ensure

that the Perry seismic test results

bound the Shearon Harris plant was

scheduled to be completed

by April I, 1990.

The team concluded that the

licensee

had failed to verify the design

by not seismically qualifying these

valves.

The applicable requirement is 10 CFR Part 50, Appendix B,

Criterion III, Design Control which requires

measures

to verify the adequacy of

the design

(see Appendix A, Deficiency Number 90-200-02).

The team also

concluded that there

was not an immediate safety

concern

based

on

a preliminary

review of the seismic testing of these valves at Perry.

3.2

EDG Lube Oil and Jacket Mater Heaters

The

EDG lube oil system

and the jacket water system were maintained

by

non-Class

IE heaters

during diesel

standby.

In the event of a loss of lube oil

and jacket water heaters

during winter conditions, there

was

no assurance

that

the

EDG would fast start at postulated

lower temperatures.

The Technical

Specifications

required the

EDG to start

on demand within 10 seconds

to be

operable.

The specifications,

however, did not address

any limits for lower

temperatures.

No administrative controls existed to ensure that the lube oil

and jacket water temperatures

did not go below temperatures

for which fast

start capability had been evaluated.

In response

to the team's

concerns,

the

licensee established

temperature

limits for the jacket water and lube oil

temperatures,

below which the

EDG would be declared

inoperable

and committed to

having administrative controls in place to maintain the

EDG preheat

temperature

to ensure

a fast start of the diesel.

The team concluded that the licensee

had

failed to verify design for the operability of the diesel

under standby

conditions.

The applicable requirement is 10 CFR Part 50, Appendix B,

Criterion III, Design Control which requires

measures

to verify the adequacy

of

design

(see Appendix A, Deficiency Number 90-200-03).

3.3

EDG Air Receivers

The

EDG starting air receiver low-pressure

alarm set point of 190 psig

+

5 percent

had not been tested

on site to demonstrate

a capability of starting

the

EDG five times without recharging the receivers.

Although the licensee

had

performed

some preoperational

testing at

a higher pressure, it should

have

demonstrated

a five-start capability at

a star ting air receiver pressure of

190 psig on site in accordance

with its

FSAR commitment.

The licensee stated

that they could demonstrate

by analysis that five starts

were possible at

190 psig on the basis of testing

done at the plant, at the manufacturers

location,

and at the Grand Gulf Nuclear Plant at lower pressures.

The team

concluded that the licensee

had failed to verify design for the five-start

capability of the diesel at the air starting pressure

of 190 psig.

The

applicable requirement is 10 CFR Part 50, Appendix B, Criterion III, Design

Contre 1 which requires

measures

to verify the adequacy of the design

(see

Appendix A, Deficiency Number 90-200-04).

3.4

Design Basis

Documents

The team found errors

and inconsistencies

in mechanical

systems

design basis

documents

(DBDs) applicable to diesel generator building HVAC, and the diesel

generator

systems.

Calculations establishing

setpoints for the fuel oil storage

tank and

fuel oil day tank were not reflected in the present plant setpoints.

No design basis

had been provided in any calculation for the technical

specification (3/4.8.1)

minimum fuel oil storage

tank volume requirement

of 100,000 gallons.

Calculations for the

EDG building fans did not provide the fan curve

analysis for HVAC air handling unit AH-85 static pressure,

nor did it

provide a conclusion.

Calculations

demonstrating

the effect of winter condition temperatures

on

diesel generator building areas/rooms

did not address

the acceptance

of

non-1E unit heaters for control of the area/room temperatures.

The team concluded that the licensee failed to ensure that the design basis

was

correctly translated

into specifications,

drawings,

procedures,

and

instructions.

The applicable requirement is 10 CFR Part 50, Appendix B,

Criterion III, Design Control (see

Appendix A, Deficiency Number 90-200-05).

3.5

Conclusions

The administrative procedure for safety reviews

(AP-011) provided

a single,

well-detailed instruction for all plant site and engineering

organizations to

-use in safety reviews

and analyses

and established

qualification requirements

for personnel

performing the functions.

Deficiencies in the design verification of the

EDG air tank relief valves,

EDG

air receivers,

and the

EDG lube oil and jacket water heaters

to perform their

intended safety function and deficiencies

and inconsistencies

in the

design basis

documents

indicated

a weakness

in the design control of EDS

equipment.

However,

upon review of the licensee's

evaluations

performed during

the inspection,

the team found no significant safety concerns

regarding the

operability of the associated

equipment.

4.0

EDS

EQUIPMENT REVIEI!

To confirm the implementation of the electrical

system design,

the team

inspected

the "as-installed" condition of a sample of selected

safety-relatea

equipment in the plant.

The equipment physically examined included:

6.9KV Class

1E switchgear,

480-V load centers

and motor control centers

(MCCs), 125-Vac and dc switchgear including transformers,

switchgear

enclosures,

circuit breakers,

protective relays,

fuses

and other control

devices;

6.9-kV EDGs and associated

auxiliary equipment,

EDG switchgear

and control

panels, circuit breakers,

protective relays,

and the voltage regulator

and

exciter;

125-Vdc batteries,

battery chargers,

and inverters;

and

main control room electrical distribution system controls

and

instrumentation.

'

'1

The team reviewed field modifications to confirm that changes to the installed

EDS equipment

had not compromised

the safety margins of the electrical distri-

bution system.

The review included

an overview of the associated

operation

and

surveillance

procedures,

plant change

requests

(PCRs),

wor k requests

and

authorizations,

and system electrical drawings.

The team reviewed the testing

and calibration procedures

and records of

selected

components of the

EDS and interviewed plant maintenance

personnel

to

determine if actual testing performed adequately

reflected

NRC requirements

and

licensee

cotanitments.

4.1

Equipment Malkdowns

The

EDS equipment

conformed to design requirements.

Switchgear

and buses

were

properly labeled, easily identifiable,

and accessible.

Drawings used to

facilitate the walkdowns were clear, traceable,

and in most cases,

reflected

the field configuration.

Proper physical separation

existed in the field for

the

EDS equipment

and components.

The team,

however, identified a number of deficiencies with regard to

controlled drawings

and installed equipment.

These included locations of motor

control centers

lA23-SA, 1B23-SB,

14B12,

and 14B13; installation of two

synchronism verification relays in cubical 10; installation of three rather

than

2 ground fault relays in cubicle 6A; terminal lead

7B not installed

as

shown

on drawing no.

DFS 1364-42384,

Revision 3; and Zener diodes

and resistors

connected

contrary to drawing no. 4910C76.

The licensee

confirmed that the

equipment in the field met design requirements

and that drawings

had not been

updated.

The team noted that the identified deficiencies

were not safety significant.

4.2.

Equipment Modifications

Very few modifications

had been

performed to the

EDS since licensing of the

plant.

The team examined plant change

requests

(PCRs) that were listed by

systems related to the electrical distribution system.

A number of changes

were examined in the field for conformance to the requirements

of the PCRs.

4.2.1

Emergency

Load Sequencer

The emergency

load sequencer

did not properly reset during testing

on

September ll, 1989.

Licensee

(LER 89-16) indicated that an overload of relay

contacts

was the root cause of the test failure.

PCR-4765 initiated hardware

modifications to reduce the contact overload problem for the relay contacts

that failed.and

a review of the contact loading for all sequencer

relay

contacts.

The team noted discrepancies

in regard to the licensee's

10 CFR 50.59 safety

review of the modifications to the load sequencer.

The reviewer had provided

incorrect and inadequate

conclusions to questions

regarding the probability and

consequences

of the occurrence of an accident,

malfunction of equipment,

and

compromising of the margins of safety.

Based

on the team's

concerns,

the

licensee

performed

an updated evaluation to correct these deficiencies in the

safety review documentation.

~ As part of the hardware modifications to the load sequencer,

the licensee

used

~

~

two Potter Brumfield contacts

in series to help deenergize

each

load group.

The licensee

had conducted

an engineering

analysis to verify that the ratings

of the contacts

in the load sequencer

were not exceeded

and

had concluded that

the installed ratings were adequate for the assumed

load current.

However, the

manufacturer

of the relays

had not provided an dc inductive load rating for the

contacts,

and the team was concerned that qualification of these relay contacts

could not be demonstrated

without the dc inductive load rating.

The licensee

stated that it had planned to test the applicable relays to verify

the appropriate

contact loading for interrupting inductive loads

as

soon as

additional relays are received from the vendor.

The licensee is coamitted to

complete testing of these relays

by September I, 1990.

Although the team

had

no immediate safety

concerns

because

the licensee physically examined the relay

contacts

and confirmed that there

was

no burning or pitting of the contacts

(such degradation

occurs if the relay contacts

are overloaded),

the team

concluded that the Potter Brumfield relay contacts

were unqualified to perform

their safety function without adequate

documentation.

The team concluded that

the licensee failed to justify the suitability of the application of these

contacts.

The applicable

requirement is 10 CFR Part 50, Appendix B,

Criterion III, Design Control (see Appendix A, Deficiency Number 90-200-06).

4.2.2

Instrument List Update

During review of a modification concerning the replacement

of control grade

Agastat relays,

the team noted that the instrument list, a controlled document,

had not been maintained up-to-date with the as-built conditions of the plant

before plant licensing.

In addition,

changes resulting from subsequent field

changes

had not been incorporated in the instrument list.

Adequate controls

had not been exercised

in maintaining the instrument list

current with design modifications and discrepancies

on this list could mislead

personnel

with regard to what model of a given component

was actually installed

in the plant.

In response

to this concern,

the licensee

issued

a request for

action,

"NED Notice of Potential Deficiency," Form 1503B, dated

Yiarch 9, 1990,

to address

problems with updating the data

base for the instrument list.

4.2.3

Commercial-Grade

Breakers

and Relays

Procedure

TNM-104, "Determination of Technical

and gA Requirements for Procure-

ment Documents,"

was used to dedicate

coomercial-grade

components for

safety-related

applications.

The procedure

did not specify methods for verifi-

cation of critical characteristics.

In addition, the licensee

had

no controls

in place to verify if hardware

design

changes

had been

made

by the vendor to

the originally qualified design.

At the team's request,

the licensee

contacted

several of the circuit breaker manufacturers

who indicated that design

changes

had been

made to the breakers

since the original qualification was done.

The

team noted that the licensee

had been

unaware of the changes

and their effect

on the performance of the installed circuit breakers.

The licensee

confirmed that

35 commercial-grade

breakers

were currently

installed in EDS applications.

The team also identified similar deficiencies

in commercial-grade

relays

used in the

EDS.

The licensee

stated that molded-

10

- case circuit breakers

and relays

had been installed consistently

as replace-

~

~

ments

on a like-for-like basis with the original manufacturer

and model

numbers,

and therefore

met the original design requirements.

The licensee,

however,

agreed that since the seismic qualification and othe'ritical

characteristics

could not be conclusively proven, it would either demonstrate

the Class

IE qualification of these breakers

and relays or replace

them in

safety applications with qualified breakers

and relays before startup from the

next plant outage.

The team concluded that the licensee failed to justify the

suitability of materials

and components

and to provide verification of

design.

The applicable requirement is 10 CFR Part 50, Appendix B,

Criterion III, Design Control (see Appendix A, Deficiency Number 90-200-07).

4.3

Equipment Testing

and Calibration

Testing

and calibration requirements for plant equipment important to safety

are addressed

by 10 CFR Part 50, Appendix A,

GDC 18, and Appendix B,

Criterion XI and XII.

The licensee

had

a data

base

and tags

on each piece of

equipment in place to track all the electrical

maintenance

and testing per-

formed.

The electrical equipment,

including circuit breakers

(except for

molded case circuit breakers),

HCCs, transformers,

reactors,

cubicles,

buses,

inverters, battery chargers,

motors,

and relays were covered

under the follow-

ing test programs:

preventive maintenance

(PH) testing in accordance

with vendor

recommendations;

maintenance

periodic. testing

(MPT) in accordance

with 10 CFR Part 50,

Appendix R, and

FSAR commitments;

maintenance

surveillance testing

(MST) pursuant to technical specification

requirements;

corrective maintenance

(CH) testing

done for repair and replacement;

and

process

instrument calibration (PIC) performed for all relays according to

the type and manufacturer of the relay.

With the exception of those

components

under

the surveillance

requirements

stipulated for HST, MPT, or

CM tests,

the program required testing of one of

the two safety trains at each refueling outage,

thus completing the

PM cycle

after every two refueling cycles.

The PIC for the protective relays were

performed every

2 years

and for the grounding relays every

5 years.

In addi-

tion, technical

support requires

some of PH information to be. used for trending

purposes.

Appropriate testing

programs

were associated

with the

PH program, which

included all Class

1E and non-Class

1E equipment required to per form satis-

factorily for the safe operation of the plant.

An adequate

level of testing

and calibration was performed to ensure

the operability of the appropriate

electrical equipment.

However, the exceptions

discussed

below were identified:

11

1

r

'I

4.3.1

Failures of BBC Type LK-16 Circuit Breakers

Brown Boveri type LK-16, 480-V power circuit breakers that were used in

non-Class

lE applications

had failed in the past at Shearon Harris.

The plant

had

109 breakers

installed in non-Class

1E applications

and

18 identical

breakers installed in Class

1E applications

as well as

21 spares

on site for

these applications.

The licensee

confirmed that 24 failures

had occurred in

service

among

12 frequently cycled breakers

in non-Class

lE applications,

when

these

breakers

were given a demand signal to open.

Plant history showed that

these failures occurred over an estimated

22,800

demands to open for all LK-16

applications.

Apparently, the opening

mechanism of these breakers failed to provide enough

force to separate

the movable

and stationary

contacts

against the clamping

force of the contact springs.

These failures occurred

when the contact

surfaces

had been

roughened

by repeated

cycling.

The failures indicated

a

generic defect that could potentially affect the physically identical

LK-16

breakers

in safety applications.

However, the root cause(s)

for the failures

is still unknown.

The licensee

committed to an accelerated

program of

preventive maintenance

on the Class

1E LK-16 breakers

to lessen

the possibility

of failures till permanent modifications could be made.

The licensee

performed

a safety evaluation which indicated

redundancy

and

backup protective breakers

and devices for feeding loads of the circuits inside

the containment

and demonstrated

that the failure of a LK-16 to open in a

safety application disabled only one safe-shutdown

division.

The licensee

had established

an internal engineering

task force before this

inspection.

However, these

breakers

had been failing for 4 years

and no root

cause

had yet been found.

The licensee

committed to finding a root cause for

these failures by the end of March 1990.

Pending further review by Region II

of the root cause

of failures and appropriate corrective action, this is

considered

to be an unresolved

item (see Appendix A, Deficiency

Number 90-200-08).

4.3.2

Relay Settings

During a walkdown in the plant, the team compared

the "as-found"

EDG

overcurrent relay

51V/DGB settings in the field with the corresponding field

calibration sheets

and the relay design calculations.

The time dial of relay

51V/DGB was set at 3.5 while both the field calibration sheet

and the design

calculation specified

a time dial setting of 3.0 for all three

phases

of both

EDGs.

The licensee's

maintenance

personnel

confirmed that the time dial

setting of 3.5 in the field was incorrect.

The licensee

stated that according

to the verified calibration sheets,

the time dial had

been properly set at 3.0

during the last routine calibration in September

1989, but had changed to 3.5

some time before the inspection.

The licensee

had no explanation for the

change.

In regard to safety significance of this deficiency,

a

slightly-longer-than-optimum time delay could have increased

the potential

equipment

damage if a short circuit connection

were sustained

in the Class

IE

ac system.

The licensee recalibrated

the

51V/DGB relay and restored

the

setting to the correct value.

12

~ The team also noted that even though certain administrative controls existed

for identifying repetitive failures of components,

no formal program existed to

trend the drifting of relays.

4.3.3

Battery Test Procedure

The acceptance

criteria of surveillance

procedure

MST-E0010,

"1E Battery Weekly

Test,"

was deficient in that it gave the allowable range for electrolyte

temperature

as

70 to 90'F.

Technical Specification 3.7.12 specified

a maximum

electrolyte temperature

of 85'F in the

A and

B battery

rooms

and required

verification that the temperature

was within limits every

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The

licensee

acknowledged this discrepancy

and issued

a feedback report to have

Procedures

NST-E0010

and MST-E0011 revised to specify

a 70 to 80'F allowable

range for electrolyte temperature.

4.3.4 Testing of Class

1E Underground

Cables

The

FSAR requires

a random sample of Class

lE cables in the underground

cable

system to be tested to demonstrate

that the dielectric integrity of the insula-

tion is maintained throughout the life of the cables.

The licensee's

current

test program procedures

only required

power

cables of large 6.9-kV and 480-V

rotating equipment to be tested for insulation dielectric integrity.

The team

was concerned that the licensee's

test program in this area did not fully meet

the intent of the

FSAR as all cable types were not being tested (i.e., power,

instrumentation,

and control).

The licensee

acknowledged

the concern

and

committed to include appropriate

control and instrumentation

underground

cables

in the test program.

Pending further review by Region II of the testing of

underground

cables, this is considered

an unresolved

item (see Appendix A,

Deficiency Number 90-200-09).

4.3.5

Circuit Breaker Testing

Technical Specification 4.8.4.l.a.2

required 480-V containment penetration

breakers

to be tested

by injecting a current with a value equal to 300 percent

of the pickup of the long-time delay trip element

and

150 percent of the pickup

of the short-time delay trip elements.

In contrast,

plant test Procedure

NSI-E0008 specified the 480-V power circuit breakers

be tested

by applying a

test signal to the circuit breakers solid-state trip units.

Although this

method adequately

checked the functionality of the trip units, it did not check

the functionality of the current transformer in the circuit breaker or the

electrical continuity of the wiring and connectors

between

the current trans-

formers

and the solid-state trip units.

The team was concerned that

a circuit

breaker tested successfully

under

Procedure

HST-E0008 could fail to open

upon

an actual overcurrent

because

of a current transformer

or wiring defect.

The

wiring in question

was easily susceptible

to damage

as it was not totally

confined within the breaker

and could be damaged

during the installation

and

removal of these

breakers

from their cubicles.

The licensee

revised

Procedure

NST-E0008 to perform a continuity check of the subject wiring harness

and connector.

4.4

Conclusions

The construction or installation of EDS equipment

was adequate.

Good house-

keeping

was established

in the plant, few deficiency tags were observed,

and

the equipment

was well maintained.

There was proper separation

of equipment

13

~ and circuits.

Equipment

was properly labeled

and easily identifiable.

The

support staff were knowledgeable,

competent,

and timely in answering questions.

Drawings used to facilitate the walkdowns were clear, traceable,

and in most

cases,

reflected the field certified configuration.

However, minor inconsis-

vencies

between

design drawings

and the location and installation of certain

EDS equipment,

although not safety significant, were further

examples of the

licensee's failure to control the updating of design

documents.

Safety significant deficiencies existed in the licensee's

control of plant

modifications and qualification of installed commercial-grade

equipment.

The

Potter Brumfield relay contacts

modified in the diesel

load sequencer

circuits

had not been adequately verified to confirm if their ratings would compromise

plant safety margins.

Commercial-grade

breakers

and relays were found unquali-

fied based

on inadequate

documentation.

Additional management

attention

and

control is needed

in this area.

The licensee

had

an appropriate

program for testing

and calibration of EDS

equipment although certain deficiencies existed in the testing

and criteria of

power and molded-case

480-V circuit breakers,

125-V dc batteries,

Class

1E

underground

cables,'and

EDS bus voltages.

Although the Brown Boveri LK-16 breakers

had been failing for 4 years,

no root

cause

had been established.

The licensee

committed to determining the root

cause for the failures by the end of March 1990,

and the Resident

Inspector

staff will review the analyses.

Some of the above-identified deficiencies

were

a result of design

documents

not

being updated to be consistent with plant procedures

and practices.

5.0

ENGINEERING AND TECHNICAL SUPPORT

The team assessed

the capability and performance of the licensee's

organization

to provide engineering

and technical

support (BTS) by examining interfaces

between

the technical disciplines internal to the engineering

organization

and

between

the engineering

organization

and the functional groups performing

design reviews, field modifications, surveillance, testing,

and maintenance.

The team also visited the

CPSL Nuclear Engineering

Department

(NED) offices in

Raleigh,

North Carolina.

5.1

Organization

and

Key Staff

Licensee's

organization

included separate

site groups for engineering

technical

support, modifications, maintenance,

and quality assurance.

The corporate

office included nuclear engineering

and quality assurance

departments

and

a

training section.

Throughout the inspection,

the

EETS staff provided timely and technically

sound

responses

with regard to the design

and implementation of the

EDS.

'Hhile the

training of site

EATS personnel

was more formalized, the team noted that there

was less formal training of corporate

engineering

groups

on the use, updating,

and implementation of design basis

documentation.

14

- 5.2

Root-Cause

Analysis and Corrective Actions

The team noted deficiencies in this area.

Despite

an effort by the licensee

to

improve in this area,

there were instances

in which root-cause

analysis

and

corrective action

had not been performed in a proper or timely manner.

Brown Boveri type LK-16 480-V breakers

had been failing for 4 years

without the licensee establishing

a root cause

and corrective action (see

Section 4.3.1).

Modifications to the emergency

load sequencer

with regard to failed relay

contacts

were performed without adequate justification of the dc inductive

rating of the replaced Potter Brumfield relay contacts

(see Section

4.2.1).

Commercial

grade molded-case

480-V breakers

and Potter Brumfield relays

were found unqualified to Class

1E requirements

in spite of a previous

violation issued

by the

NRC to the licensee

on

a similar deficiency

(see

Section 4.2.3).

5.3

Engineering

Involvement in Design

and Operations

The team reviewed the involvement of corporate engineering

(NED) with site

technical

groups in regard to adequate

and timely engineering

support.

The

team noted that the corporate

engineering

support group did respond to requests

for technical

support after they

had

been initiated, prioritized, and budgeted

by the onsite plant management.

A data

base

was maintained with information on

each task.

Open item lists of tasks

were provided to facilitate tracking of

assignments

and schedules.

Typical listings reviewed

by the team indicated

that the computer data

base

provided effective control of tasks.

The control

of engineering

support

was further enhanced

by monthly meetings of NED manage-

ment, department

managers,

and the management staff for each plant.

5.4

Conclusions

The corporate

and site engineering

and technical support available to the

Shearon

Harris plant was sufficient in numbers

and the staff was competent.

The organization

provided appropriate

EATS groups to perform required func-

tions.

The site and corporate

E&TS groups adequately

interfaced to identify

and resolve concerns identified at the site.

However, deficiencies

were noted

in the timeliness

and adequacy

of the

EATS program for addressing

root-cause

analysis

and appropriate

corrective action.

Formal training of corporate

office staff with regard to the application

and control of design basis

docu-

mentation

should

be considered.

6.0

GENERAL CONCLUSIONS

The inspection

team concluded that the

EDS at Shearon Harris was operable

and

had

a generally conservative

design.

Emergency

power sources

were sized

properly and adequate

voltage

and fault current margins were applied to essen-

tial buses with regard to

EDS loads.

The coordination of the protective

equipment

was adequate

and the testing of the

EDS equipment

was appropriate.

15

Staff support for the

EDS from the corporate office and site was sufficient.

Staff were

knowledgeable

and competent.

The licensee's

aggressive effort to

maintain the grid voltage as

a reliable source of power was considered

very

appropriate.

However,

some deficiencies existed in the areas of design

control, test control, root-cause

analysis,

and corrective actions.

The team

had no immediate safety

concerns

because

of the substantial

margins built into

the design of the plant.

The team conducted

an exit meeting

on Harch 16, 1990, at the Shearon

Harris

site to discuss

the major areas

reviewed during the inspection,

weaknesses

observed,

unresolved

issues,

and findings.

NRC management

from NRR and

Region II and licensee

representatives

who attended this meeting are identified

with an asterisk in Appendix

B of this report.

The inspectors

discussed

outstanding

licensee

actions

on major issues

and acknowledged staff commitments

made during the inspection.

The licensee

did not identify any documents

or

processes

as proprietary.

16

APPENDIX A

Deficiencies

DEFICIENCY NUMBER 90-200-01

Deficiency Title:

EDG Load Sequencing

Ca'lculation

(Unresolved

Item - Section 2.1.2 of report)

Des cri tion of Condition:

The emergency

diesel

generator

(EDG) calculation

17-EP established

the minimum

voltage available at the 6.9-kV emergency

buses

during the sequencing

of

safety-related

loads onto the

EDG to be used

as input to other system loading

and voltage calculations.

The team noted the following deficiencies in the

ca 1 cu1 ation:

The effect of sequencing

time drift on the timing of load blocks was not

addressed

in the calculation.

(If drift becomes

excessive,

the voltage

transients

resulting from the two adjoining load blocks could overlap,

causing

a voltage dip beyond the tolerance of the load's equipment.)

The computer

code

used to perform this calculation

had not been adequately

validated

and quality assurance

measures

had not been taken, contrary to

the Nuclear Engineering

Department

procedure

(Reference

1).

~

~

~

Information in the calculation

on the sources

of input data were inade-

quate to allow audit and verification, contrary to Harris plant procedure

(Reference 2).

The transient effect of the suddenly-applied

load, which reduces

the speed

of the generator

and hence the generated

voltage,

was

assumed to be

negligible.

The team considered this assumption

nonconservative

and the

calculation did not justify or establish

the upper bound of its effects.

All loads

(both starting

and running) were assumed

to be accurately

represented

as constant

impedances.

The accuracy of this assumption

depended

on the mix of loads in each

load block.

In view of the Shearon

Harris load mix, the constant-impedance

assumption

was considered

not

properly justified or bounded in the calculation.

The licensee

provided additional information and stated that

a transient

loading test performed during the qualification of the emergency

diesel

generators

(Reference I) demonstrated

the basic validity of the calculation.

The transient

loading test consisted of a block-loading sequence

intended to

approximate the actual

loading

on the Shearon

Harris

EDGs as closely as test

facility limitations allowed.

The

NRC team agreed that the qualification test

enveloped

the plant conditions

and provided reasonable

assurance

that the

results of the calculation were conservative.

Although there were no immediate

safety concerns

because

the qualification tests

confirmed the adequacy of the

EDG system,

the team concluded that the content of the calculation did not

assure that sufficient voltages

were delivered to safety-related

loads during

an event of loss of offsite power.

. The licensee staff will revise calculation

17-EP

by appending clarification of

the calculation methodology

and justification of the nonconservative

assumptions

to the calculation.

The licensee staff also will to add additional information

on the verification and control of the computer

code.

References:

1.

TRP Revision 8, April 10, 1981, "gualification Test Report for TDI

Standby Generator

Set"

A-2

P

DEFICIENCY NUMBER 90-200-02

~DER

f

TET:

ERAT

T kkffff

(Potential

Enforcement Finding - Section 3.1 of report)

Descri tion of Condition:

The vendor for Crosby air tank relief valves

had issued

a Part

21 report

on

failures of these

valves at the Perry Nuclear Plant.

The licensee

had

installed Crosby air tank relief valves in the

EDG air starting

system per

plant change request,

PCR 4406.

There was inadequate

documentation to

determine if the relief valves were seismically qualified in accordance

with

the

FSAR and

ASME Section III (References

1 and 2).

PCR 4406

showed that the Crosby relief valves were similar to those installed

at the Perry Nuclear Plant.

The Perry investigation

had determined

these

valves to be shock sensitive

and

had included

a seismic test confirming that

the valves remained

proper ly seated

up to their set point for a certain seismic

spectra.

Accelerations

above these limits were determined

by Perry to result

in a colon-mode failure.

The Shearon

Harris licensee

performed

a safety

evaluation for PCR 4406

and determined that the accelerations

for the installed

relief valves were less than the limits of the Perry test

and were therefore

qualified.

However, the licensee

had taken

no action to obtain and properly

review this test to verify assumptions,

anomalies

and plant-specific applica-

tion.

The team concluded that the licensee

had not performed

a formal design

evaluation for the qualification of these valves.

The licensee will perform a

formal design evaluation to ensure that the Perry seismic test bounds the

Shearon

Harris Nuclear Plant requirements

and to complete the

IEEE 344-75

documentation

requirements for these relief valves

by April 1, 1990.

10 CFR Part 50, Appendix B, Criterion III, Design Control, requires

design

control measures

to be provided for verifying or checking the adequacy of

design

by performing design reviews, using alternate

or simplified

calculational

methods,

or providing a suitable testing program.

References:

1.

FSAR Section 9.5.6.1,

Design Bases,

states

in c) that "the portions of the

air starting

system necessary

for emergency

operation

meet Seismic

Category

1, Safety Class

3 requirements"

and in d) that "the air

receivers,

piping and valves from the receivers

up to the diesel

engine

are designed to Safety Class

3 and Seismic Category

1 requirements

(refer

to Table 3.2.1-1)"

2.

FSAR Table 3.2.1-1 lists components

under the heading

"Diesel Generator

Air Starting

System

as

ASME III, Class 3, Seismic Category 1, the Diesel

Generator air receivers

and associated

piping, tubing and valves essential

for emergency

operation"

A-3

DEFICIENCY NUMBER 90-200-03

~Dfli

.

Tl 1:

EDGLb

Otl

dJ

k

4

tl t

(Potential

Enforcement Finding - Section

3.'2 of report)

Descri tion of Condition:

During standby the

EDG lube oil system temperature

was maintained at 140'F

minimum by

a non-Class

lE immersion heater

located in the

sump tank.

The

EDG

jacket water

system heater temperature

was also maintained at 140'F minimum by

a non-Class

1E immersion heater

located in the standpipe.

The Shearon

Harris Technical Specifications

(Reference

1) required the diesel

generator to be demonstrated

to be operable

by verifying that it could start

within 10 seconds,

with a test using the manufacturer's

engine prelube

and

warmup procedures.

The technical specifications

gave

no reference to

low-temperature limits.

During standby only non-Class

1E heaters

were avai 1-

able

and could be lost if a

common-mode failure occurred during

a seismic event

because

there

was

no evidence that the

EDG had the capability to cold start in

10 seconds

without the lube oil and jacket water heaters.

This was contrary to

FSAR requirements

(Reference 2).

The team determined this to be

an unreviewed safety

concern with regard to the

design of the plant.

After a seismic event during winter conditions, the

EDG

may not be able to start in 10 seconds.

The licensee

took immediate corrective

action and established

temperature

limits for jacket water (40'F)

and lube oi 1

(70'F) below which the

EDG would be considered

inoperable.

The licensee will

establish administrative controls to monitor the temperatures

of the heaters

and taking appropriate

actions to restore

the

EDG to optimum conditions if

temperatures

approached

these limits.

~Re uirements:

10 CFR Part 50, Appendix B, Criterion III, Design Control requires

design

control measures

to be provided for verifying or checking the adequacy of

design

by performing design reviews, using alternate or simplified

calculational

methods,

or providing a suitable testing

program.

References:

2.

Technical Specification 3/4.8.1 A. C., Sources,

Surveillance

Requirements

4.8.1.1.2.a.4,

identifies that "each diesel generator

shall

be demon-

strated

OPERABLE by verifying the diesel

can start ... within 10 seconds."

In the notes it is stated that "this test shall

be conducted in accordance

with- manufacturer's

recommendations

regarding

engine prelube

and warmup

procedures,

and

as applicable regarding

loading recommendations"

FSAR Section 8.3.1.1.1.5,

Standby

AC Power Supply, b), states that "each

diesel

generator

has

been provided with a preheat

system which maintains

adequate

engine temperature

to ensure fast starts"

A-4

DEFICIENCY NUMBER 90-200-04

~fM

Tl 1:

EOG AD

R

(Potential

Enforcement Finding - Section 3.3 of report)

Descri tion of Condition:

The

EDG air start system

had not been adequately

evaluated

to demonstrate

a

five-start capability of the diesel at

a starting air receiver pressure

of

190 psig.

The team observed

the present

alarm set point for the starting air

receiver

in the plant was

190

+

5 psig.

The present technical specification

surveillance

requirements

(Reference

1) specified

a minimum pressure

of

190 psig in each receiver.

The

FSAR (References

2 and 3) stated that each

starting air receiver shall

be demonstrated

by test to successfully start the

diesel five times without recharging

the receivers.

During plant pre-

operational testing,

the licensee

had demonstrated

that the diesel

generator

had

a five-start capability, but this test

was

done at high initial pressures

of up to 248 psig,

and not at the technical specification requirement of 190

psig.

Test data provided by the diesel

generator

vendor demonstrated

a seven-start

-capability for the

EDG, but this test

was not done

on

a receiver identical to

the

EDG air receivers at Shearon Harris.

During the inspection period, the

licensee

provided relevant test data from the Grand Gulf Nuclear Power Plant

Unit 1 with a similar

EDG air start

system configuration to the Shearon

Harris

air start

system which demonstrated

five or more starts at an initial pressure

of lower than

190 psig.

The licensee did not make any commitment to perform testing of the starting air

receivers

(actual

equipment) for the five-start capability,

as committed to in

the

FSAR (Reference 2).

The licensee

stated that

a retest

would cause

exces-

sive wear on the diesel generator

and air start system.

However, the licensee

did perform an evaluation of the Transamerica

Delaval (vendor)

bench test,

Grand Gulf test,

and Shearon Harris preoperational

testing to conclude that the

combination of these tests result in a safe condition and an adequate

demon-

stration of the five-start capability at 190 psig.

The team had

no immediate safety

concerns after reviewing the licensee's

evaluation,

but noted that

no engineering

evaluation

had been performed for

this concern before the inspection,

other than the Shearon Harris pre-

operational test.

The team considered

the pre-operational

test by itself to be

an unacceptable

resolution with regard to meeting licensing

commitments to

demonstrate

a five-start

EDG capability at a set point of 190 psig.

10 CFR Part 50, Appendix B, Criterion III, Design Control, requires

design

control measures

to be provided for verifying or checking the adequacy of

design

by performing design reviews,

using alternate or simplified

calculational

methods,

or providing suitable testing

program.

A-5

V

r

S

References:

~

~

~

~

~ ~ ~

1.

Technical Specification 3/4.8.1 A. C., Sources,

Surveillance

Requirements

4.8.1.1.2

states

that each diesel generator shall

be demonstrated

operable

by (item 5)" ... verifying the pressure

in at least

one air start receiver

to be greater

than or equal to 190 psig"

2.

FSAR 8.3.1.2.14

k, gualification Testing

Program, identifies that qualifi-

cation testing of the diesel

generator for the

SHNPP consists

mainly of

three test steps:

(1) Factory Run-In Test,

(2) Type gualification Test,

and (3) Site Test.

"Test Steps

1

IE 2, performed at the manufacturer's

facility, established

test conditions similar to what can

be expected at

the actual site except that the intake and exhaust

system

and starting air

of the test faci'lity is substituted for the actual

equipment.

Durin

reo erational test at the site

test ste

3

the actual

e ui men

s

utz zzed.

s

sectzon

urt er

e znes t e startzng

a r capac ty

test performed at the manufacturer's facility under step 2, (3) as "Start-

ing Air Capacity Test:

This test demonstrates

the engine-generator's

ability can

be successfully

stated

a minimum of five times without

recharging

the air receivers"

3 ~

FSAR Section 9.5.6.1,

Design Basis, states

in a) that "each starting air

receiver will supply sufficient compressed air to crank the cold diesel

engine five times without recharging the receiver.

Each cranking cycle

brings the diesel

generator

up to a speed of 200 rpm"

A-6

r

0

DEFICIENCY NUMBER 90-200-05

~fff

fff:

f

f

f f

(Potential

Enforcement Finding - Section 3.4 of report)

Descri tion of Condition:

The team found errors

and inconsistencies

in the design calculations for the

fuel oil transfer

system

and

HVAC systems.

Calculations establishing

setpoints for the fuel oil storage

tank (Refer-

ence

1) and fuel oil day tank (Reference

1) were not reflected in the

present plant setpoints.

No design basis

had been provided in calculations

(Reference

2) for the

technical specification (3/4.8.1)

minimum fuel oil storage

tank volume

requirement of 100,000 gallons.

Calculations

(Reference

4) for the

EDG building fans did not provide the

fan curve analysis of HVAC air handling unit AM-85 static pressure,

nor

did it provide

a conclusion.

A calculation

(Reference

5) demonstrated

the effect of winter condition

temperatures

on diesel generator building areas/rooms,

but did not address

acceptance

of non-Class

lE unit heaters for maintenance

of the area/room

temperatures.

The team noted that discrepancies

in the format and content of these calcula-

tions was contrary to plant procedures

(Reference 6).

In addition, the

licensee

did not have

a program to ensure that the mechanical

and electrical

design

bases

had been maintained

and properly translated

into plant operating

procedures.

10 CFR Part 50, Appendix B, Criterion III, Design Control, requires the design

basis to be correctly translated

into specifications,

drawings,

procedures,

and

instructions.

References:

1.

Calculation E(S-28,

Fuel Oil Day Tank

2.

Calculation E(S-23,

Fuel Oil Storage

Tank

3.

Calculation

E(S F0-5, Fuel Oil Storage

Tank

4.

Calculation 9FP-BE-08,

HVAC Air Handling Unit

5.

Calculation

9-DGB, Tab J,

EDG Building Temperature

6.

NED GL E-4, Revision 0, February

23, 1989,

"NED Guideline-Preparation,

Documentation

and Control of Calculations

A-7

DEFICIENCY NUMBER 90-200-06

~Dfil

T$ 1: i

g

yL dSq

Ndlfi

(Potential

Enforcement Finding - Section 4.2.1 of report)

Descri tion of Condition:

During the inspection,

the team questioned

the adequacy

of the contact rating

for load sequencer

relays.

Modifications of the load sequencers

were imple-

mented

under

PCR-4765 to eliminate relay contact overload conditions that had

led to relay contact failures.

In addition,

an analysis of relay contact

loads

was undertaken

by the licensee to verify the adequacy of the sequencer

design.

However, the safety analysis did not provide an acceptable

basis for the

adequacy of the dc inductive ratings of the contacts.

The licensee

was able to confirm that the contacts of the suspect

relays

had

been

inspected

and were observed to show

no signs of damage;

therefore,

there

was

no immediate safety concern.

However, the licensee initiated a test

program to establish

an acceptable

relay contact inductive load rating for

Potter-Brumfield relays

used in dc circuits and scheduled

to complete this test

program by September I, 1990.

10 CFR Part 50, Appendix B, Criterion III, Design Control, requires

measures

be

established for determining the suitability of materials

and equipment that are

essential

to the safety-related

functions of the systems

and for verifying or

checking the adequacy

of the design.

References:

1.

NRC Regulatory

Guide 1.32, Revision 2, "Criteria for Safety Related

Electric Power Systems for Nuclear Power Plants"

2.

Institute of Electrical

and Electronics Engineers,

Standard

IEEE 308-

1980Property "IEEE" (as page type) with input value "IEEE 308-</br></br>1980" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.,

"IEEE Standard Criteria for Class lE Power Systems for Nuclear Power

Generating Stations"

A-8

DEFICIENCY NUMBER 90-200-07

~dft

I

111:

I

t Id

d I

I

dR IT

(Potential

Enforcement Finding - Section 4.2.3 of report)

Descri tion of Condition:

The team reviewed the plant procedure

(Reference

1) for performing commercial-

grade dedications

and noted that the procedure

did not require the documenta-

tion of critical characteristics

and did not specify methods to verify critical

characteristic.

The storage

and maintenance

sheets for molded-case circuit

breakers

also contained

no testing or inspections to verify the seismic

qualification of commercial-grade

breakers.

The licensee's

response

to an

NRC violation dated

November 8, 1989,

showed that

the licensee

had installed several

commercial-grade

molded-case circuit break-

ers in safety-related

applications without a proper review for seismic qualifi-

cation or other

important critical characteristics.

The response

to the

violation, however, did not address

other commercial-grade

breakers that

may

have

been installed for a similar deficiency.

'The licensee identified 35 commercial-grade

breakers

installed in

safety-related

applications,

and at the team's request,

contacted

several of

the circuit breaker manufacturers

who indicated that changes

had been

made to

the breakers

since their original qualification.

The licensee

was not aware of

these

changes

and their effect on capability of these circuit breakers

to

perform their safety function.

The team also identified several

commercial-grade

Potter

and Brumfield relays

installed in safety-related

applications.

No testing

was apparently

done to

verify the critical characteristics

of these relays including those for seismic

qualification, contact ratings,

pickup,

and dropout for Class

lE applications.

As a result of these

concerns,

the licensee will demonstrate

the Class

1E

qualification of the commercial-grade

breakers

and relays or replacing

them

prior to startup from the next outage.

~kt

10 CFR Part 50, Appendix B, Criterion III, Design Control, requires

measures

to

be established for determining the suitability of materials

and equipment

essential

to the safety-related

functions of systems

and components

and for

verifying or checking the adequacy of the design.

References:

1.

Procedure

TMM-104, "Determination of Technical

and gA Requirements for

Procurement

Documents"

A<<9

r

a

C

r

DEFICIENCY NUMBER 90-200<<08

~fif

111:Fft

fBBttypktfttf ftt

1

(Unresolved

Item - Section 4.3.1 of report)

Descri tion of Condition:

Past failures of BBC type LK-16, 1600A-frame,

480-V (600-V class)

power circuit

breakers

to open

on demand in non-Class

1E distribution switchgear

had occurred

after the breakers

had experienced

a relatively large number of cycles

between

preventive maintenance.

The team noted that the non-Class

1E type LK-16

breakers at Shearon

Harris were physically identical to the Class

IE breakers

installed at the plant.

The licensee

stated that the LK-16 breakers

in

Class

1E service operated

only during operational

surveillance,

post-

maintenance testing,

and accidents

and consequently

accumulated relatively few

cycles.

The licensee

reported that the basic design of the opening

mechanism of the

breakers failed to provide enough force to separate

the movable

and stationary

contacts

against the clamping force of the contact springs, especially

when the

contact surfaces

had

been

roughened

by repeated

cycling.

The licensee

had been

working with the circuit breaker

vendor,

Asea

Brown Boveri (ABB, successor

to

BBC), as well as independently to resolve this problem.

CPEL and

ABB attempted

a variety of "fixes" with unsatisfactory

results,

and

ABB apparently withdrew

from the effort.

The licensee

had established

an internal engineering

task

force before this

NRC inspection,

but had not established

a root cause for

failures for the past

4 years.

In response

to the team's

concerns,

the licensee

prepared

a safety evaluation

(Reference

1) to justify the continued operation of the plant with the

18 LK-16

breakers

in Class

1E applications

and committed to an accelerated

program of

preventive maintenance

(Reference

2) on the Class

lE breakers.

The licensee

also will determine the root cause of the failures by the end of March 1990.

10 CFR Part 50, Appendix B, Criterion III, Design Control, requires

design

control measures

to be provided for verifying or checking the adequacy

of

design

by performing design reviews, using alter nate or simplified

calculational

methods,

or providing a suitable testing

program.

References:

1.

Licensee's

safety evaluation,

"Response

to

NRC guestion

on LK-16

Switchgear

Breakers"

(with attachments

A and B), February 26,

1990

2.

CPSL Letter No. MS-903128(0),

L. J.

Woods to J.

F. Neville, LK-16

Breakers,

March 12,

1990

A-10

DEFICIENCY NUMBER 90-200-09

~dff1

111:

1

I

fdl

lf lid f

dCRI

(Unresolved

Item - Section 4.3.4 of report)

Descri tion of Condition:

The

FSAR (Reference

1) requires

a random sample of Class

1E cables in the

underground

cable

system to be tested to demonstrate

that the dielectric

integrity of the insulation is maintained throughout the life of the cables.

The licensee

indicated that their current test program procedures

only required

power cables of large 6.9-kV and 480-V rotating equipment to be tested for

insulation dielectric integrity.

The team was concerned that the licensee's

test

program did not fully meet the intent of the

FSAR as all cable types were

not being tested (i.e., power, instrumentation,

and control).

The licensee

acknowledged

the concern

and will include appropriate

underground

cables in the

test program.

Region II will follow up on review of testing of appropriate

cables.

10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires that all

testing required to demonstrate

that components will perform satisfactorily in

service are identified and

per formed.

References:

1.

FSAR Section 8.3.1.2.37E,

Test program for Class

1E Underground

Cables

c

Carolina

Power

and Li ht

APPENDIX

B

Persons

Contacted

J.

• G

H.

T.

A.

R.

W.

• J

R.

• G

G.

• 'W

• J

K.

• C

• A

• S

S.

• B

R.

C.

J.

J.

• L

J.

• H.

J.

• R.

W.

• R.

• K.

• W

R.

R.

• D

• R.

• M

G.

• D

• F

• E

R.

L.

R.

Arnette

Atarian

Avinger

Batchelor

Coc keri 1 1

Connoly

Cooper

H. Eads

Floyd

L. Forchard

Forhand

Fowler

Hammond

Heiffner

S. Hinnant

Howe

Hughey

Hughie

Hynds

Knott

McKenzie

Morris

Nevill

A. Olsen

Pierce

Po1 lock

Pospisil

W. Pranty

Pugh

B. Richey

Russell

Shenton

Stewart

Stuart

Tibbits

Yarner

Wallace

White

C. Whitehead

Wi 1 lett

Williams

Woeronick

J.

Woods

Zula

E 1ectri ci an

NED Principal Engineer

AC System Engineer

Electrician

Manager,

NED I&C and Electrical

Engi

NED Project Engineer

Technical

Support Engineer

Project Engineer,

Nuclear Licensing

System Engineer Batteries/Sequencer

Manager,

QA/QC

Manager,

QA/QC

Engineer,

Technical

Support

Manager,

Onsite Nuclear Safety

E 1ectri ca 1 Maintenance

Plant General

Manager

Regulatory

Compliance

Engineer

Site-NED Electrical Liaison

NED Principal Engineer

Super visor, EQ/Seismic

Manager, Quality Assurance

Technical Support

Manager,

NED Electrical Engineering

Technical Support

HVAC Engineer

Senior Specialist,

QA Auditing

Chief Engineer, Electrical Products

Manager,

Licensing

Site Manager,

ASME XI

Site Manager

Onsite Nuclear Safety

EDG System Engineer

Manager,

NED Mechanical

Engineering

Manager,

NED Mechanical Engineering

Regulatory

Compliance

NED Project Engineer

~ Senior Specialist,

Regulatory

Compli

NED, Mechanical

Engineering

Manager,

QA Auditing

Manager,

Outages

and Modifications

NED, Civil Engineering

Ebasco,

Manager,

Nuclear Electrical

Engineering

Supervisor,

Technical Support

Manager, Site Technical Support

neering

ance

V

l I

J

J

k

V

I r

~

l

V

Nuclear

Re ulator

Commission

• R. Becker

• T. Conlon

• H. C. Dance

• C. W. Hehl

• J. Konklin

• W. Lanning

• M. Shannon

• J. Tedrow

Project Manager,

NRR

Section Chief,

PSS,

Region II

Section Chief,

DRP, Region II

Deputy Director,

DRP, Region II

Section Chief, RSIB,

NRR

Branch Chief, RSIB,

NRR

Resident

Inspector,

Harris

Senior Resident Inspector,

Harris

• Denotes those attending the exit interview on March 16,

1990 at the conclusion

of the inspection.

B-2

a

'y/

t

0