ML18009A636
| ML18009A636 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/07/1990 |
| From: | Dance H, Shannon M, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18009A635 | List: |
| References | |
| 50-400-90-13, NUDOCS 9009050195 | |
| Download: ML18009A636 (20) | |
See also: IR 05000400/1990013
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report No.:
50-400/90-13
Licensee:
Carolina
Power
and Light Company
P. 0.
Box 1551
Raleigh,
NC 27602
Docket No.:
50-400
Facility Name:
Harris
1
Inspection
Conducted:
June
16 - July 20,
1990
Inspectors;
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endor
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nspector
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annon,
esi ent
nspector
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Reacto
Projects
Branch
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Division of Reactor Projects
License No.:
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SUMMARY
Scope:
This routine inspection
was conducted
by two resident
inspectors
in the areas
of plant operations,
radiological controls, security, fire protection,
surveillance observation,
maintenance
observation,
review of licensee
event
reports
and nonconformance
reports,
actions
regarding moderator dilution
accidents,
review of the reactor protection
system
manual trip, actions
'regarding
low temperature
overpressure
protection,
and licensee
action
on
previous inspection
items.
Numerous facility tours were conducted
and facility
operations
were observed.
Some of these tours
and observations
were conducted
on backshifts.
Results:
Two violations were identified:
failure to properly implement plant
procedures
during the performance of an incore/excore calibration,
paragraph
6.a;
and failure to properly perform personnel
monitoring prior to leaving
a potentially contaminated
area,
paragraph
2.b(4) (non-cited violation).
A non-cited licensee identified violation is discussed
in paragraph
5.b
regarding
inadequate
testing of the
FHB emergency
exhaust
system.
An unresolved
item is identified in paragraph
6.b regarding
review of
inservice testing data for the boric acid pumps.
REPORT DETAILS
Persons
Contacted
Licensee
Employees
- J. Collins, Manager,
Operations
- G. Forehand,
Manager,
gA/gC
J. Garcia-Serafin,
Sr. Reactor
Engineer
- C. Gibson, Director,
Programs
and Procedures
- J.
Hammond, Director,
C. Hinnant, Plant General
Manager
D. Jackson,
Electrical
Foreman - Nuclear
- M. Jackson,
Supervisor,
Maintenance
D. McCarthy,
NED Site Principal
Engineer
J. Nevill, Manager,
Technical
Support
- C. Olexik, Director, Regulatory
Compliance
- A. Poland,
Manager,
ESRC Support
R. Richey,
Manager,
Harris Nuclear Project Department-
C. Rose,
Manager,
gA
J. Sipp,
Manager,
Environmental
and Radiation Monitoring
H. Smith, Manager,
Radwaste
Operation
A. Stalker,
Senior Mechanical
Engineer
R. Stewart, Principal Mechanical
Engineer
D. Tibbits, Supervisor, Shift Operations
- B. Van Metre, Manager,
Harris Engineering
Support
E. Willett, Manager,
Outages
and Modifications
- L. Woods,
Engineering Supervisor - Nuclear
Other licensee
employees
contacted
i.ncluded office, operations,
engineering,
maintenance,
chemistry/radiation
and corporate
personnel.
- Attended exit interview
and initialisms used throughout this report are listed in the
last paragraph.
2.
Review of Plant Operations
(71707)
The plant continued in power operation
(Mode 1) for the duration of this
inspection period.
a.
Shift Logs
and Facility Records
The inspector
reviewed records
and discussed
various entries with
operations
personnel
to verify compliance with the Technical
Specifications
(TS)
and the licensee's
administrative
procedures.
The following records
were reviewed:
Shift Foreman's
Log; Control
Operator's
Log; Night Order
Book; Equipment Inoperable
Record;
A'ctive Clearance
Log; Jumper
and Wire Removal
Log; Shift Turnover
Checklist;
and selected
Chemistry/Radiation
Protection
and Radwaste
Logs.
In addition, the inspector
independently verified clearance
order tagouts.
No violations or deviations
were identified.
b.
Facility Tours
and Observations
Throughout the inspection period, facility, tours were conducted
to
observe
operations
and maintenance activities in progress.
Some
operations
and maintenance activity observations
were conducted
during backshifts.
Also, during this inspection period; licensee
meetings
were attended
by the inspectors
to observe
planning
and
management activities.
The facility tours
and observations
encompassed
the following areas:
security perimeter fence; control
room;
emergency
diesel
generator
building; reactor- auxiliary building; waste processing
building;
fuel handling building; emergency
service water building; battery
rooms;
and electrical
switchgear
rooms.
During these tours, the following observations
were made:
(I)
Monitoring Instrumentation
- Equipment operating status,
area
atmospheric
a'nd liquid radiation monitors, electrical
system
lineup, reactor operating
parameters,
and auxiliary equipment
operating
parameters
were, observed
to verify that indicated
parameters
were in accordance
with the
TS for the current
operational
mode.
(2)
Shift Staffing - The inspectors verified that operating shift
staffing was in accordance
with TS requirements
and that
control
room operations
were being conducted in an orderly and
professional
manner.
In addition, the inspector
observed shift
turnovers
on various occasions
to verify the continuity of
, plant status,
operations
problems,
and other pertinent plant
information during these turnovers.
(3)
Plant Housekeeping
Conditions - Storage of material
and
components,
and cleanliness
conditions of various
areas
throughout the facility were observed
to determine whether
safety and/or fire hazards
existed.
(4)
Radiological Protection
Program - Radiation protection control
activities were observed routinely to verify that these
activities were in conformance with the facility policies
and
procedures,
and in compliance with regulatory requirements.
The inspectors
also reviewed selected
RWPs to verify that the
RWP was current
and that the controls were adequate.
While performing
a plant tour on July 9, 1990, three general
contractor
personnel
were observed
to exit the south
RHR/CS
pump area without performing personnel
contamination
monitoring.
Although the area
was posted to frisk hands
and
feet prior to exiting, the three workers left the area without
frisking.
The inspector notified
HP supervision of this
failure to follow plant procedures.
Subsequently,
the three
workers were counseled,
the frisker was relocated
next to the
door,
and
a
new posting with bolder letters
was placed
on the
door.
This
NRC identified violation is not being cited because
criteria specified in Section
V.A of the
were satisfied.
NC5 (400/90-13-01):
Failure to follow radiological posting
requirements.
(5)
Security Control - In the course of monthly activities, the
inspectors
included
a review of the licensee's
physical security
program.
The performance of various shifts of the security
force was observed
in the conduct of daily activities, to
include:
protected
and vital area
access
controls;
searching
of personnel,
packages,
and vehicles;
badge
issuance
and
retrieval; escorting of visitors; patrols',
and compensatory
posts.
In addition, the inspector
observed
the operational
status of Closed Circuit Television
(CCTV) monitors, the
Intrusion Detection
system in the central
and secondary
alarm
stations,
protected
area lighting, protected
and vital area
barrier integrity, and the security organization interface with
operations
and maintenance.
(6)
Fire Protection - Fire protection activities, staffing,
and
equipment
were observed
to verify that fire brigade staffing
was appropriate
and that fire alarms,
extinguishing
equipment,
actuating controls, fire fighting equipment,
emergency
equipment,
and fire barriers
were operable.
3.
Surveillance
Observation
(61726)
Surveillance tests
were observed
to verify that approved
procedures
were
being used; qualified personnel
were conducting the tests;
tests
were
adequate
to verify equipment operability; calibrated
equipment
was
utilized; and
TS requirements
were followed.
The following tests
were observed
and/or data
reviewed:
OST-1004,
Power Range
Heat Balance
OST-1013,
1A-SA Emergency
Diesel Generator Operability Test
OST-1036,
Shutdown Margin Calculation
EST-717,
Incore/Excore Detector Calibration
No violations or deviations
were identified.
4.
Maintenance
Observation
(62703)
The inspector observed/reviewed
maintenance activities to verify that
correct equipment clearances
were in effect; work requests
and fire
prevention work permits,
as required,
were issued
and being followed;
quality control personnel
were available for inspection activities
as
required;
and,
TS requirements
were being followed.
Maintenance
was observed
and work packages
were reviewed for the
following maintenance
(HR/JO) activities:
Troubleshooting of inoperable
bank
D group
and post
maintenance
testing in accordance
with procedure
OST-1005,
Control
Rod Verification
Motor operated
valve testing utilizing VOTES test equipment
Troubleshooting of a failed shut steam generator
B blowdown valve
(BD-20) and temporary modification to the automatic
pressure
control
circuit PCR-5386.
No violations or deviations
were identified.
5.
Review of Licensee
Event Reports
(92700)
The following LERs were reviewed for potential
generic
impact, to detect
trends,
and to determine whether corrective actions
appeared
appropriate.
Events that were reported
immediately were reviewed
as they occurred to
determine if the
TS were satisfied.
LERs were reviewed in accordance
with the current
'a ~
(Closed)
LER 90-15:
This
LER reported
a deficiency in the design of
the emergency
diesel
generator
sequencer
circuit.
This matter
was
previously being tracked
as
an IFI (see
paragraph
10.c of this
report).
The. inspector
reviewed
and verified the licensee's
corrective action
as stated
in the
LER.
b.
(Open)
LER 90-16:
This
LER reported
inadequate
testing of the
FHB
emergency
exhaust
system.
On March 30,
1990, during the performance
of surveillance testing
on this system,
licensee
personnel
identified
a discrepancy
with measured
system flowrate.
Due to turbulent airflow
in the region being measured,
actual
system flowrates were greater
than those
allowed by TS 4.9.12 for test performance.
The licensee
reperformed
the test procedure
which was completed satisfactorily
on
April 27.
Previous test data
was reviewed
by the licensee
and
determined
not to be in compliance with the TS.
A review of other
TS
filtration units
was performed which revealed
no similar problems.
This item is considered
to be
a licensee identified
NCY and is not
cited because
the criteria specified in section
V.G. 1 of the.NRC
Enforcement Policy were satisfied.
5
NC4 (400/90-13-02):
Failure to adequately test the
FHB emergency
exhaust
system.
The
LER will remain
open pending revisions,to test procedures
to
identify acceptable
locations for flowrate measurements
and
comparison of measured
flowrate with permanent
instrumentation.
6.
Review of Nonconformance
Reports
(71707)
Significant Operational
Occurrence
Reports
(SOORs)
and Nonconformance
Reports
(NCRs) were r'eviewed to verify the following:
TS were complied
with, corrective actions
as identified in the reports
were accomplished
or being pursued for completion, generic
items were identified and
reported,
and items were reported
as required
by the TS.
a ~
b.
SOOR 90-92 reported that nuclear instrument detector currents
were
determined
based
on improperly calculated
heat balances.
The
performance of procedure
OST-1004,
Power
Range
Heat Balance,
was
required
at= various steps
during the completion of procedure
EST-717,
Incore/Excore
Detector Calibration
on June
27,
1990.
However, while
performing procedure
OST-1004
on June
26 and 27,
blowdown was left in
service.
This action
was contrary to the requirements
of procedure
OST-1004
step
2 which required the blowdown flow control valves to be
shut.
This action in turn caused
a 1.7 percent error in the normalized
full power nuclear instrumentation currents.
During the subsequent
detector- calibrations,
operating
personnel
alertly identified the
nuclear instrument calibration error.
At this point, licensee
personnel,
without procedural
guidance,
modified the previously taken
'data
from procedure
OST-1004 to account for blowdown remaining in
service.
The program for performing the incore/excore calibration,
detailed in procedure
EST-717,
was rerun
and nuclear instruments
were
subsequently
adjusted.
Although calculatons
were technically correct,
failure to follow procedural
steps of procedure
OST-1004
and
performance of steps
not procedurally
documented
in procedure
EST-717
were collectively considered
a failure to follow plant procedures.
Violation (400/90-13-03):
Failure to follow plant procedures
during
the performance of EST-717
and OST-1004.
Although this matter
was identified by the licensee, it is being
cited due to previous
problems
the licensee
has experienced
in this
area
(90-01-01,
90-02-02).
NCR 90-08 identified improper testing of the boric acid
pumps
as
required
by the licensee's
IST program.
On October 4,
1988 the boric acid
pump impellers were inadvertently
replaced with impellers" which, when tested,
could not meet the
design flow specified in the
FSAR (75 GPH).
The impellers could,
,L
however,
provide the
TS required flow of 30
GPM and the shutdown
requirements
specified
by the
FSAR.
Following the impeller replace-
ment,
a
PCR was written to evaluate
the change in impeller diameter,
but this evaluation
had not been completed
as of May 11,
1990,
almost
two years,
when this item was identified by the
gA organization
during
a modification audit.
The plant response
to this
gA finding
is not due until July 27,
1990,
the licensee
has installed the proper
impellers.
This item is considered
unresolved
pending further
NRC
review of the licensee's
corrective action.
URI (400/90-13-04):
Failure to perform
a timely evaluation of boric
acid
pump test data.
Review of Actions Regarding
Moderator Dilution Accident
(Closed) TI-2515/94:
This inspection
was performed to verify the
licensee's
administrative controls to prevent inadvertent dilution of the
boron concentration
in the reactor coolant system.
The plant
(NUREG 1038, Safety Evaluation Report Related to the Operation of Shearon
Harris
Nuclear
Power Plant, Units
1 and 2, November
1983)
and the
FSAR were
reviewed to determine
which administrative controls the licensee
had
committed to.
As stated
in the
SER, Section 15.4.6,
the licensee
committed
to lock out one reactor
makeup
pump during plant operation in the cold
shutdown condition
and to maintain
a
2 percent
The
licensee
subsequently
revised
the
TS to reflect
a variable
with a minimum value of
1 percent.
This revision was accepted
by the
NRC
staff which= issued
license
amendment
P7
and safety evaluation,
dated
August 16,
1988.
The inspector
reviewed the licensee's
procedures
for
operating in the cold shutdown condition (GP-007,
Normal Plant Cooldown)
and verified that administrative controls were in place to adhere
to the
shutdown margins required
by TS and to lock out one reactor water makeup
pump.
No violations or deviations
were identified.
Review of Actions Regarding
Reactor Protection
System
(Closed)
TI 2500/14:
This inspection
was performed to verify the
location. of the manual trip circuit in the reactor solid state protection
system.
The licensee's
controlled drawings correctly depicted
the
location of the manual trip circuit located
downstream of output
transistors
93 and
g4 in the undervoltage
output circuit.
No violations or deviations
were identified.
Review of Actions Regarding
Low Temperature
Overpressure
Protection
(LTOP)
(Closed) TI-2500/19:
This inspection
was performed to verify the licensee
had
an effective mitigation system to prevent
severe
pressure
while at
a relatively low RCS temperature.
Reviews of the
mitigation system design,
drawings, plant specific analysis,
administra-
tive controls, operator training,
system maintenance
and modifications,
surveillance testing,
and system descriptions
in the
FSAR and
SER, were
performed.
As described
in the
FSAR, Section 5.2.2. 11, the licensee utilizes two
and
1RC-118), with automatically adjusted
opening
setpoints
that vary as
a function of RCS temperature,
to provide
LTOP.
An alarm has
been provided to alert operators
to increasing
RCS pressure
prior to
PORV actuation.
The
LTOP system is manually enabled
by
operators utilizing a switch on the main control
board
when
temperature
decreases
below 350 degrees
F.
Also,
a pressurizer
steam
bubble is utilized as
a surge
volume to help mitigate pressure
The steam bubble is used until the Node
5 (cold shutdown)
condition is approached
when the pressurizer
is filled and solid water
operation is initiated.
While in the solid water condition, pressure
is
controlled with the
CVCS system.
The inspectors
found that the
LTOP system
was appropriately
designed
to
prevent exceeding
pressure limits, had adequate
redundancy of system
components,
and system setpoints
were supported
by a plant specific
analysis.
The SER, section 8.4.8, incorrectly assumed
that the power
supplies for the
PORVs were safety related.
Although the
PORVs are
classified
as safety related
due to their function as
an
RCS pressure
boundary,
the control air system for these
valves is not safety related
or seismically qualified.
The air valve solenoids
receive
DC power from
the non-class
1E balance of plant uninterruptible
DC power supply which
is provided with a backup battery source.
Although these
systems
are not
safety related,
the inspector verified adequate
redundancy
existed
and
that the system descriptions
provided in the
FSAR were correct.
Administrative controls were adequately
addressed
by the
TS and
implemented
by plant procedures.
However, the inspector
found that the
licensee's
operation in the solid water condition did not optimize the
use of a pressurizer
nitrogen bubble which would also act as
a pressure
buffer.
System modifications
and maintenance
were reviewed.
Nodification
3241,
LTOPs Operation in Nodes
1,
2 and 3,
was
implemented
to defeat the
automatic
arming of the
LTOP system
and installed
an inhibit switch
requiring operator action to enable
the system.
This change
was
necessitated
due to
a potential
unanalyzed
condition which could occur
during
a main steam line break or steam generator
tube rupture accident.
This problem,
and associated
corrective action,
was reported to the
NRC
via
LER 88-11.
Nodification
PCR 3965,
Cycle
2
LTOP Setpoints,
changed
the system setpoints
in order to comply with new heatup/cooldown limit
curves established
in accordance
with NRC Generic Letter 88-11,
Regulatory
Guide 1.99
Rev.
2 Radiation Embrittlement of Reactor
Vessel
Naterials.
The inspector
found these modifications to be appropriate
and
post maintenance/modification
testing
adequate.
A review of the licensee's
surveillance testing of this. system revealed
that periodic surveillance tests
were being performed,
the system
was
tested
before
each cold shutdown,
and that the
PORVs were included in the
licensee's
IST program to be full. stroke tested
during cold shutdown.
In response
to
a recent reanalysis
of the steam generator
tube rupture
accident,
and
NRC Generic Letter 90-06, Resolution of Generic
Issue 70,"
Power-Operated
Relief Valve and Block Valve Reliability", and Generic
Issue
94, "Additional Low-Temperature
Overpressure
Protection for Light
Water Reactors"
pursuant
to
10 CFR 50.54(f), the licensee
is considering
upgrades
to the plant
TS and
PORVs to enhance
protection
system
availability.
In correspondence
to the
NRC dated
December
15,
1989, the
licensee
committed to upgrade
the
PORV manual actuation
components,
controls,
and
power supplies,
to safety
grade for use in the tube rupture
event.
The licensee
was encouraged
to upgrade
the
LTOP components
as
well.
No violations or deviations
were identified.
10.
Licensee Action on Previously Identified Inspection
Findings
(92702
5
92701)
a.
(Closed)
IFI 400/90-04-01:
Review the licensee's
activities to
revise
procedure
OST-1092,
1B-SB Residual
Heat
Removal
Pump
Operability,
and to improve records of corrective action.,
The licensee
has revised
procedure
OST-1092 to reflect appropriate
acceptance
criteria for pump flow and
has
changed
procedure
ISI-203,
ASt1E Section
XI Pump
and Valve Program Plan, to provide an
attachment for documenting corrective action.
b.
(Closed)
IFI 400/90-04-02:
Review the licensee's
development of
acceptance
criteria for procedure
OST-1024,
Onsite
Power
Distribution Verification.
C.
Since specific voltage criteria was not included in the
TS
acceptance
criteria, the licensee
decided to revise procedure
OST-1024 to delete it.
Instead,
the licensee
has taken credit for
this criteria in routine operator logs.
(Closed)
IFI 400/89-21-03:
Contact Overloading of Potter-Brumfield
Relays.
This matter
was previously discussed
in
NRC Inspection Report
50-400/90-10
and
was identified as
a deficiency in
NRC Inspection
Report 50-400/90-200
(item 400/90-200-06).
The licensee
has
issued
LER 90-15 describing this event
and corrective actions
taken to
prevent recurrence.
The test report (Corporate Consulting
and
Development
Company,
LTD. dated July 12,
1990)
was reviewed
by the
inspector.
For record
purposes
this item will be closed
and
possible
enforcement
action tracked
by deficiency 400/90-200-06.
l
'
d.
(Closed)
IFI 400/89-13-01:
Failure of Brown Boveri LK-16 breakers
to open
on demand.
The licensee
has
completed onsite testing,
design verification with
Brown Boveri,
and successful
overcurrent (trip and latch) testing at
20K, 40K and
50K amperes
on.two different breakers
at an independent
testing facility.
Modification PCR 3510,
480 Volt Drawout Breakers
Used
As Contactors,
which will install the required breaker design
changes,
is due for initial implementation
by July 27,
1990.
Completion of safety related
breaker modifications will be completed
at the earliest available outage.
All non safety related
breakers
will be modified prior to the completion of the
1991 refueling
outage.
The modification consists of removal of booster springs
and
torsion springs, verification of opening spring tension,
and
replacing of arcing contact
compression
springs.
Additionally, the
licensee will provide maintenance
personnel
with formalized training
by Brown Boveri
and will perform preventive maintenance
on the
breakers
at least
once per
100 breaker cycles.
This matter
was
discussed
with NRC Region II specialist
inspectors
who considered
the licensee's
action adequate
to close this item.
ll.
Exit Interview (30703)
The inspectors, met with licensee
representatives
(denoted
in paragraph
1)
at the conclusion of the inspection
on July 19,
1990.
During this
meeting,
the inspectors
summarized
the scope
and findings of the
inspection
as they are detailed in this report, with particular emphasis
on the Violation, Unresolved
Item,
and Inspector Follow-up item addressed
below.
The licensee
representatives
acknowledged
the inspector's
comments
and did not identify as proprietary
any of the materials
provided to or reviewed
by the inspectors
during this inspection.
Item Number
Descri tion and Reference
400/90-13-01
400/90-13-02
400/90-13-03
400/90-13-04
NC5:
Failure to follow radiological posting requirements
(paragraph
2.b.4).
NC4:
Failure to adequately
test the
FHB emergency
exhaust
system
(paragraph
5.b).
VIO:
Failure to follow plant procedures
during the
performance
of EST-717
and
OST-1004
(paragraph
6.a).
URI:
Failure to perform
a timely evaluation of boric acid
pump test data
(paragraph
6.b).
12.'cronyms
and Initial i sms
CFR
Ameri can Soci ety of Mechani cal
Engineers
Closed Circuit Television
Code of Federal
Regulations
10
EST
FHB
GPN
IFI
LER
NED
NRC
OST
QA/QC
RCS/RC
SOOR
TS
YIO
WR/JO
Containment
Spray
Chemical
Volume Control
System
Emergency Diesel
Generator
Engineering Surveillance Test
Fuel Handling Building
Final Safety Analysis Report
General
Procedure
Gallons per Minute
Health Physics
Inspector Follow-up Item
Inservice Testing
Licensee
Event Report
Low Temperature
Overpressure
Prot
Non-Conformance
Report
Non-Cited Violation
Nuclear Engineering
Department
Nuclear Regulatory
Commission
Onsite Nuclear Safety
Operations
Surveillance Test
Plant
Change
Request
Power Operated Relief Valve
Quality Assurance/Quality
Control
Reactor
Coolant System
.
Residual
Heat
Removal
Radiation
Work Permit
Safety Evaluation Report
Significant Operational
Occurrenc
Technical Specification
Unresolved
Item
Violation
Work Request/Job
Order
ection
e Report