ML18009A727
| ML18009A727 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/02/1990 |
| From: | Carroll R, Shannon M, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18009A725 | List: |
| References | |
| 50-400-90-20, NUDOCS 9011160100 | |
| Download: ML18009A727 (31) | |
See also: IR 05000400/1990020
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report No.:
50-400
Licensee:
Carolina
Power and Light Company
P. 0.
Box 1551
Raleigh,
NC
27602
Docket No.:
50-400
Facility Name:
Harris
1
Inspection
Conducted:
September
15 - October
19,
1990
Inspectors:
waa
J.
edr w, Senior Resident
Inspector
License Nos.:
gAoV
'ate
Signed
~0g
M.
S annon,
esi ent Inspector
Approved by:
arro
,
ctsng
ect
Reactor Projects
Branch
1
'ivision of Reactor Projects
Date
Soigne
ae
one
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,
licensee
event reports
and
nonconformance
reports,
annual
emergency drill, plant nuclear safety committee
activities,
recombiner
survey,
spent
fuel
shipping activities,
followup of onsite
events,
meeting with local officials, evaluation of the
quality assurance
program,
and licensee
action
on previous inspection items.-
Numerous facility tours
were conducted
and facility operations
observed.
Some
of these tours
and observations
were conducted
on backshifts.
Results:
Three violations were identified:
failure to accurately
document
a surveil-
lance test,
paragraph
3.c; failure to properly
implement plant maintenance
procedures,
paragraphs
4.a and 4.b;
and failure to perform compensatory
actions
for an inoperable radiation monitor, paragraph
5.c.
A new unresolved
item was identified concerning
the periodic calibration checks
of installed thermocouples,
paragraph
3.b.
90iiihOi00 90ii02
ADOCK 05000400
0
PNV
I
2
Weaknesses
involving the supervisory
review of completed surveillance'ests
and implementation of technical
manual
recommendations
during maintenance
work
were also identified, paragraphs
3.c and 4.a, respectively.
The licensee's
activities involving the inoperability of an auxiliary feedwater
pump resulted
in an
emergency
Technical
Specification
change,
paragraph
3.a.
The licensee
also took actions to monitor and evaluate
a primary to secondary
leak, paragraph
11.
Additionally, 'the licensee's
spent
fuel shipping activities
were considered
not to be in accordance
with ALARA objectives,
paragraph
10:
l r
J
REPORT
DETAILS
1.
Persons
Contacted
Licensee
Employees
- R. Biggerstaff, Unit Manager Site Engineering
- J. Collins, Manager,
Operations
- G. Forehand,
Manager,
QA/QC
- C. Gibson, Director,
Programs
and Procedures
- P. Hadel, Director, Projects
- C. Hinnant, Plant General
Manager
- D. NcCarthy,
NED Site Principal
Engineer
- T. Morton, Nanager,
Maintenance
- J. Nevil.l, Manager,
Technical
Support
C. Olexik, Director, Regulatory Compliance
- S. Radford,
Manager,
Plant Service/Modifications
R. Richey, Vice President,
Harris Nuclear Project Department
- J. Sipp,
Manager.,
Environmental
and Radiation Monitoring
- N. Wallace, Sr. Specialist,
Regulatory Compliance
E. Willett, Manager,
Outages
and Modifications
Other
licensee
employees
contacted
included
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 I) 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 TS and the licensee's
administrative
procedures.
The following records
were
reviewed:
Shift
Foreman's
Log;
Control
Operator's
Log; Night Order
Book;
Equipment
Recor'd; Active Clearance
Log; Jumper
and Wire
Removal
Log; Shift Turnover Checklist;
and selected
Radwaste
Logs.
In addition,
the inspector
independently
verified clearance
order
tagouts.
l P
j
I
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
and 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'n
an orderly and
professional
manner.
In addition,
the 'inspector
observed shift
turnovers
on various
occasions
t'o verify the continuity of
plant status,
operational
problems,
and other pertinent plant
information during'hese
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
was current
and that the controls were adequate.
(5)
Security Control - In the course of the monthly activities, the
inspector
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.
No violations or deviations
were identified.
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-1011
OST-1018
OST-1026
OST-1039
OST-1211
EPT-097
EPT-166T
NST-E0006
.NST-E0007
NST-E0010
Pump
1A-SA Operability Test
Monthly
Interval
Main
Steam
Isolation
Valve
and
Main Feedwater
Isolation
Valve Operability Test quarterly Interval
Leakage Evaluation Daily Interval
Calculation of quadrant
Power Tilt Ratio
Pump. 1A-SA Operability Test quarterly
Interval
Dechromation of the Closed Cooling Water Systems
(RAB, WPB,
and
BTRS)
Temporary Procedure
For Trouble Shooting
AFW Valve Noise
480
VAC Molded Case Circuit Breaker Test
120/208
VAC Molded Case Circuit Breaker Test
lE Battery Weekly Test
1E Battery quarterly Test
As
a result of these
observations,
the following items were identified:
a 0
At 1:08
p.m.
on September
25,
1990,
the licensee
declared
the "A"
motor driven auxiliary feedwater
pump
after the
pump
failed
to
develop
appropriate
discharge
pressure
during
the
performance
of procedure
OST-1211.
The
pump developed
a discharge
pressure
of 1587 psig,
whereas
TS 4.7. 1.2. l.a. 1 required the
pump to
develop at least
a
1590 psig discharge
pressure
when operated with a
recirculation flow of at least
50
GPM.
'l
J
f'
Subsequent
tests
were
performed
by the licensee
with more accurate
instrumentation;
however;
these
tests
were
also
unsatisfactory.
Since
the surveillance tests
were performed with the
pump operating
in the recirculation lineup with minimum flow, the licensee
decided
to perform
a full flow test to determine
pump compliance with the
system
design.
On September
26, this test
was
performed with flow
directed to the
The data obtained
from this full
flow test
conformed
to the manufacturer's
pump curve, verifying
~ that the
pump
had not significantly degraded
and
was able to meet the
'ystem design.
On September
27,
the licensee
submitted
a letter to the
NRC which
requested
a temporary waiver of compliance to TS 4.7. 1.2. l.a. 1 and
an
emergency
change
to the
TS to measure
a temperature
compensated
pump
differential
pressure
instead.
At approximately
12:40 p.m.,
on
September
28,
NRR verbally gr'anted
the temporary waiver of compliance
to the licensee.
The licensee
implemented
the
proposed
change to
TS 4.7. 1.2. 1.a. 1
and
performed
procedure
OST-1011 satisfactory
at
1:28 p.m. to declare
the
pump operable.
The verbal authorization
was
subsequently
followed by
a written temporary waiver of compliance
dated
September
28,
1990.
On October
5, the
NRC issued
amendment
No.
22 to the facility operati'ng
license incorporating the
TS change
request.
The inspectors
observed
numerous
surveillance tests
on the "A" motor
driven auxiliary feedwater
pump
and
reviewed
the safety review and
supporting engineering calculations for the proposed
TS change.
b.
As part of
system
walkdowns
the
inspector
checked
periodic
calibration of installed instrumentation.
The inspector
found that
typically the licensee
does
not periodically check the calibration of
installed
thermocouples,
although
the instrument strings,
which the
thermocouples
provide input to, are checked.
Some thermocouples
do
receive
an ambient temperature
check periodically, whereas
others
are
not checked at all.
For instance,
the
RWST,
CST,
and
BAST have
a one
point
check for ambient
temperature
performed
in accordance
with
procedure
PIC-I666,
Thermocouple
Computer Point Calibration
Check.
Some of the installed thermocouples
that provide data for TS required
surveillance
testing
were not checked.
Specifically,
RHR cooler
outlet temperature,
which is utilized to calculate
cooldown/
heatup
rates,
and
the
recombiner
operating
temperature
thermocouples,
receive
no periodic checks.
The inspector considered
the practice of checking
the instrument string but not the primary
sensor
to be unusual
and that performance of calibration
checks for
different TS instrumentation
was inconsistent.
The thermocouple
technical
manual
Company
and
Thermocouples,
Manual
ID:OZC)
was
researched
to determine
vendor
recommendations.
This
manual
recommended
a calibration
check of
thermocouples
approximately
once
each
year
at
two
separate
temperature
points within the
thermocouple
operating
range.
The
inspector
questioned
whether the licensee's
practice of not checking
the calibration of theromocouples
in accordance
with technical
manual
recommendations
was consistent with 10 CFR 50 Appendix
B Criterion XII
and ANSI N18.7.
The licensee
has
requested
information from the rest of the nuclear
industry
on present
practices for checking the calibration of these
instruments.
This matter is considered
to
be unresolved
pending
receipt
of this
additional
information.
(400/90-20-01):
Periodic calibration check of installed thermocouples.
During this inspection period,
due to problems
experienced
at another
CPSL nuclear facility, various
work packages/surveillance
tests
were
reviewed
in order
to ensure
adequate
independent
verification of
required
procedural
steps.
Security
access
records
for the
individuals
performing
the
activity
and
those
performing
the
independent verification of the activity were reviewed in detail.
No
deficiencies
were identified relating to independent
verification,
but deficiencies
were noted in the surveillance tests
as discussed
in
the following paragraphs.
The Weekly Battery Technical Specification Surveillance,
TS 4.8.2.1.a,
for the
"A" and
"B" Emergency
Batteries,
performed
by MST-E0010,
Inspection
of
125
VDC* Emergency
Battery Banks,
was
found to have
inaccurately
documented
times
and
dates.
The surveillance
data
sheets
documented
the
MST start times
as
1:00 a.m.,
on September
26,
1990,
and
completion
times
as
6:00 a.m.,
on
September
26,
1990.
Security records for the individuals performing the surveillance
were
reviewed
and it was
found that the individuals
had not entered
the
battery
room area
during the time period
when the surveillance
was
documented
as worked.
Additional reviews were conducted
and it was found that the quarterly,
battery surveillance test,
performed
by MST-E0011, for the
"A" and
"B" emergency batteries,
had
been
completed
by the
same individuals
during the late
evening
of September
25,
1990.
Security
records
indicated
the individuals
had
been in the battery
room areas
on this
date.
Further
discussions
with licensee
personnel
uncovered
that
after
completing
the
quarterly
surveillance,
the
individuals
transcribed
the quarterly data onto the weekly surveillance
forms and
thus
documented
the times
and dates
when they were transcribing
the
data
and not the times
and
dates
when the data was'aken.
It was
noted
by the
inspectors
that
the quarterly battery surveillance
fulfills all of the requirements
of the weekly battery surveillance.
The weekly battery surveillance
can therefore
be considered
completed
upon satisfactory
completion of the quarterly surveillance.
Although
plant procedures
presently allow annotation of the surveillance tests
as
being completed
in this. manner,
the weekly surveillance test
was
not annotated
as
such.
I
4
10 CFR 50.9 requires that information, required
by the Commission's
license
condition (i.e.,
TS surveillances),
shall
be complete
and
accurate
in all material
respects.
The documentation
of times
and
dates
other
than
those
when
the surveillance
was
performed
is
contrary
to
and
is .considered
to
be
a violation.
Violation (400/90-20-02):
Failure to accurately
document surveil-
lance performance
dates
and times.
An additional
discrepancy
concerning
surveillance
testing
was
identified.
Following completion of MSTs, the maintenance
foreman is
required to review and sign for review of the completed surveillance.
This
can
be
the
only supervisory
review to ensure
satisfactory
completion of the, test.
It was
found
on several
MSTs that the
maintenance
foreman did not review the
MST for'periods of up to six
days.
Although
no unsatisfactory
surveillances
were found that were
not
promptly identified,
this
untimely
review
could
to
unsatisfactory
surveillances
not being identified in a timely manner,
'and this practice is therefore
considered to be
a weakness.
One violation was 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
foJ
inspection activities
as
required;
and
TS requirements
were
being
followed.
Maintenance
was
observed
and
work packages
were
reviewed for the following maintenance
(WR/JO) activities:
Troubleshooting
and
inspection
of the
S-4 vital inverter
in
accordance
with thermography
techniques
and procedure
PM-E-34,
Inspection
and Clean of Inverters.
Installation of pipe supports for CCW corrosion
coupon rack.
LK16 Breaker Modifications.
Replacement
of the
resonant
transformer
on
the
S-1 vital
inverter.
As a re'suit of these
reviews,
the following items were identified:
a.
Due to
a loud humming noise
coming from the S-I vital inverter, "the
licensee
decided
to replace
the ferro-resonant
transformer.
The
transformer
was replaced
under
WR 90-AMNT1 on October 5,
1990.
The
inspector
witnessed
the removal
and replacement
of the ferro-resonant
transformer
and
subsequent
troubleshooting
by
maintenance
and
technical
support
personnel.
Various discrepancies
were
noted
and
are detailed in the following paragraphs.
7'uring
the transformer
replacement,
the inspector
noted that several
were
removed
from the old transformer.
and relanded
on the
new-
transformer.
Plant procedure
PGO-53
(Control of Instrumentation
and
Removal
of Test
Equipment,
Jumpers
and Lifted Leads,
Rules of
Practice)
authorizes
removal
and .reconnecting
of electrical
to
be performed
by use of a
are
documented
on the
WR.
The technicians failed to document
the leads
and terminals
on the
and failed to use
design
drawings to document
proper lead landing.
The failure to properly
document
the lifted leads
is contrary to
plant
procedures
and is considered
to
be
a violation.
Violation
(400/90-20-03):
Failure to adhere to plant maintenance
procedures.
The inspector
did observe
that
an
independent
verification for the
lifted leads
was performed
by the electrical
foreman.
Following the
transformer
replacement,
when
operating
personnel
energized
the inverter the
AC 'input breaker tripped
on two occasions.,
Subsequentl'y
the trim capacitors
were 'removed
as stipulated
by the
manufacturer's
technical
manual.
At this point the
AC input breaker
stopped tripping, but
no apparent
correlation
could
be made.
The
technicians
measured
the
AC input voltage
to the ferro-resonant
transformer
and it was
found to
be
273
VAC, which
exceeded
the
technical
manual
voltage of 260
VAC maximum.
The inverter was placed
in service
and returned
to operable
status.
The inspector
reviewed
the
manufacturer's
technical
manual
and
made
the
following
observations.
(1)
technical bulletin to the technical
manual
dated
July 1,
1987,
stated
that
when replacing
the ferro-resonant
transformer,
no trim capacity
should
be
connected
to the
transformer
output.
The trim capacitors
were left connected
until after the
AC input break'er tripping problem.
(2)
The technical
manual
required
the ferro-resonant
transformer
input voltage to be between
190 to 260
VAC.
The input voltage
was
found to
be
273
VAC and yet,
the unit was
returned to
service.
(3)
The
technical
bulletin stated
that the inverter
output
frequency
should
be
59.9 - 60.1
HZ.
The
as left
condition was 60.19
HZ.
(4)
The technical
manual,'ection
5.5, listed circuit operational
checkpoints
to
be taken while troubleshooting.
Many of these
checkpoints
were
not verified
while
troubleshooting
or
subsequent
to placing the unit in service.
Although
a technical
support
system
engineer
was involved with the
transformer
replacement
and troubleshooting activities,
and
had ready
access
to the technical
manual
and Westinghouse bulletin update,
the
l ~
~
~
technical
recommendations
were
not
implemented.
The failure to
implement
the
technical
manual
and bulletin
recommendations
are
considered
to be
a weakness.
b.
One
The inspector
observed
a portion 'f the
work being
performed
to
install
pipe supports
for the
CCW system
which
was
conducted
in
accordance
with WR/JO
90-AMFE2 and
PCR-5331,
Corrosion
Coupon
Racks.
The hangers
were in various
stages
of being installed with numerous
anchor bolts already
embedded
in the concrete.
Upon
a review of the
work request,
the inspector
noted that the appropriate
review and
approval
signatures
were missing.
Specifically the shift foreman
(or his designee)
and maintenance
foreman
signatures
were missing.
When questioned
about this matter,
the craft technicians
were unable
to explain the discrepancy.
The inspector
contacted
the operations
shift foreman
designee
who indicated
that
he
had
not approved/
authorized
this
work.
The craft
stopped
work
and
subsequently
obtained the appropriate
approval
signatures
before proceeding.
The. licensee's
procedure for the performance of maintenance,
MMM-012,
Maintenance
Work Control Procedure,
section 5.3.3, requires that the
operations shift foreman or his designee
must authorize
work prior to
performance.
Failure
to obtain
the
appropriate
approval
before
commencing
work is contrary to procedure
MMM-012 and is considered
to
be another
example of the violation discussed
in paragraph
4.a above.
violation, with two examples,
was 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
(Open)
LER 90-18:
This
LER reported
the loss of
CCW inventory due to
the incorrect setpoint of a relief valve.
This matter
was previously
discussed
in
NRC Inspection
Report
50-400/90-17.
The following
corrective action
remains
to be accomplished
to preclude repetition
of this event:
Increase
relief valve setpoint
(PCR-5448,
CCW Relief Valve
Setpoint Change).
Revise
procedure
OST-1216,
Component
Cooling
Water
System
Operability quarterly Interval, to allow only one
CCW pump to be
in service while performing valve testing.
Revi,ew of other plant support
systems
by
ONS for comparable
problems.
The
LER will remain
open
pending
completion
of this corrective
action.
(Open)
LER 90-19:
This
LER reported
the potential condition where
a
pump could
be placed
in
a runout condi.tion.
This matter
was
previously
discussed
in
NRC Inspection
Report
50-400/90-17.
The
licensee
has
performed additional
reviews of CCW operating/emergency.
procedures
and determined'hat
o4her
scenarios
existed
which could
have
placed
the
pump in
a potential
runout condition.
The licensee
has
implemented
procedure
changes
to prevent this situation
and
has
initiated
an engineering
evaluation
(PCR-5460)
to justify deleting
the requirement for cooling
pump recirculation flow.
The
LER
will remain
open pending completion of this evaluation.
Open)
LER 90-20:
This
LER reported
that
a radiation
monitor
REM-3542)
was
during
a
continuous
release
of the
secondary
waste
sample
tank.
This matter
was identified
by the,
licensee
on September
13,
1990,
when
an instrumentation
and control
technician
found the
sample
pump flow switch in the off position.
Without sample flow the monitor is not capable of determining process
fluid activity, whereas
TS 3.3.3.10,
table 3.3-12, requires that this
monitor be operable
during tank releases.
,Action 36 of this table is
'pplicable
.to the secondary
waste tank monitor
and requires that when
the tank is being released, continuously with the monitor inoperable,
a grab
sample to detect radioactivity must
be obtained
every
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
or every
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
dependent
on the specific activity of the secondary
coolant.
Since it was
unknown that the monitor was inoperable,
none
of the
compensatory
actions
required
by the
TS were initiated.
Although the licensee
discovered
resin in the monitor sample lines
which caused
a flow switch to stick open that would have otherwise
alerted
operators
to the improper
switch posit'ion,
they were unable
to determine
why the
sample
pump
had
been
turned off.
The sample
pump
was
known
to
be
experiencing
operational
problems
on
September
5,
1990.
The licensee
concluded
that the monitor
was
not operating
between
September
5,
and
September
13,
1990.
However,
composite
samples
taken before
and after this event indicate that no
radioactivity had
been released.
Problems
have continued to recur with the radiation monitoring system
in general.
As discussed
in
NRC Inspection
Report 50-400/89-33,
a
task
force
was initiated to
recommend
action
to correct
these
problems.
The
licensee
implemented
these
recommendations
and
required
RNS technicians
to periodically walkdown the monitors in the
field 'on
a daily basis
to verify proper monitor operation.
This
action failed to identify the improper switch setting
even
though
approximately
seven daily walkdowns were performed which should
have
detected it.
A licensee
identified
NCV (400/90-08-02)
was issued'n
May
1990 for
a personnel
error which resulted
in the failure to
properly
sample
a
secondary
release.
The
sample
pump
problem,
although identified by the licensee,
is being cited due to recurrent
problems
in this
area.
Failure
to
perform
the
required
TS
compensatory
actions for the inoperable radiation monitor is contrary
1 /
~I
10
to
the
requirements
of
TS 3.3.3. 10
and
is
considered
to
be
a
violation.
Violation (400/90-20-04):
Failure to perform required
compensatory
actions for an inoperable radiation monitor.
The
LER will remain
open pending gompletion of the corrective actions
as, stated
in the
LER.
One violation was identified.
6.
Review of Nonconformance
Reports
(71707)
SOORs
and
NCRs were reviewed to verify:
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 4
NCR 90-011
reported
a deficiency in that
replacement
electrical
transmitters
were not upgraded
to meet
environmental
qualification
requirements.
During the years
1986
through
1989
the licensee
replaced
four Barton
752/753 transmitters
during routine maintenance
activities.
Although
these
transmitters
were
replaced
with
like-in-kind equipment,
the
new transmitters
were only seismically
qualified.
Regulatory
Guide
1.89,
Environmental
gualification of
Certain Electric
Equipment
Important to Safety for Nuclear
Power
Plants,
paragraph
C.6,
requires
that
replacement
equipment
be
qualified in accordance
with 10 CFR 50.49
and must
be qualified for
thermal/radiation
aging effects
as well.
The licensee
discovered
this
matter
during
a
review of
components
for life extension
conducted
on June
14,
1990.
The
licensee
has
performed
an
engineering
evaluation
of this
situation
(PCR-5291,
Barton
752
and
753 gualification).
Although
three of the subject transmitters,
FT-1RC-424
(RCS Flow), LT-1CT-992
(RWST Level),
and
PT-1RC-402
Wide
Range
Pressure),
are
subjected
to radiation fields,
these
transmitters
can
be replaced
well'efore the effects of radiation aging
becomes
evident (at least
eight years).
The fourth transmitter,
LT-1CS-106
(BAT Level)'s
subject
to
an
increase
in temperature,
but is still below the
continuous
temperature
rating of the
equipment
(130 degrees
F).
Based
upon this information, the licensee
has written
an internal
justification for continued
plant
operation
with the
replaced
transmitters
(JCO 90-003).
The licensee
plans to replace
the subject transmitters
with upgraded-
environmentally qualified
ones
as
soon
as practicable.
Based
upon
the
lengthy
lead. time for equipment
procurement,
the
licensee
estimates
this work to be completed
by the end of the
1992 outage.
b.
SOOR
90-132 reported that four safety related
motor control centers
(lA21-SA, 1B32-SB and.l/4A33-SA)
have
120
VAC starter coils installed
in place
of the
110
VAC designed
starter coils.
Although the
installed coils
have
a greater
capacity for handling overcurrent
incidents,
they
may not properly pickup at lower voltages.
The
affected
loads
from the
MCCs include:
RCP Thermal Barrier Isolation
Valve
(1CC-249);
"B" Emergency
Intake Traveling
Screen;
and
FHB
Emergency
Exhaust Inlet Valves
(3FV-B2SA-1/4).
The licensee
has
written work requests
to replace
the subject starter coils
and is
presently
evaluating
the operability of the starters
with 120
VAC
coils.
IFI (400/90-20-.05):
Review
the
licensee's
activities
regarding
wrong size starter coils in MCCs.
No violations or deviations
were identified.
7.
Annual
Emergency Drill (71707)
On September
19,
1989,
the
annual
emergency drill was
conducted
by the
licensee
to verify the
effectiveness
of the
Radiological
Emergency
Response
Plan
and
implementing
procedures.
Details
of the drill,
including the results of critiques held,
are discussed
in
NRC Inspection
Report 50-400/90-15.
8.
Review of Plant Nuclear Safety Committee Activities (40500)
The
inspectors
attended
selected
PNSC
meetings
to
observe
committee
activities
and
verify
TS
requirements
with
respect
to
committee
composition,
duties,
and responsibilities.
Minutes
from this meeting
were
also
reviewed
to verify accurate
documentation.
The inspector
considers
the
conduct of these
meetings
to
be
good
and that committee
actions/recommendations
enhance
the safe operation of the plant.
No violations or deviations
were identified.
9.
Recombiner
Survey
(71707)
In response
to an
NRC regional office memorandum
dated
September 26,'990,
a survey of the facility's hydrogen recombiner
system
was performed.
This
system
is
described
in the
FSAR, section
6.2.5,
and
addressed
by
The hydrogen
recombiners
are designed
to be the primary means of reducing
potential
hydrogen concentrations
produced inside containment following an
accident.
Hydrogen concentration
is minimized to avoid possible explosive
hazards.
Two separate'ecombiners
are
located
inside containment
and
utilize natural
circulation flow to circulate
gas
through
the
recombiner.
In the
recombiner,
the
gas
is
heated
to
a sufficient
temperature
to
cause
recombination
with oxygen.
The
recombiners
are
classified
as
safety
related
and
are
seismically
and environmentally
qualified components.
12
The licensee
performs
an operational
test of this equipment'every
six
months
and
a channel calibration every
18 months.
The inspector
reviewed
the
performance
history for these
tests
and
reviewed
the
procedures
to
determine
compliance with TS requirements.
The following procedures
were
reviewed:
OST-1030
Electric Hydrogen Recombiner
Functional
Test
HST-E0015
Electrical
Hydrogen Recombiner
Electric Hydrogen Recombiner Kilowatt Indication Channel
Calibration,
A or
B
Thermal
Recombiner
Temperature
Channel Calibration:
T-7701A and T-7701B
No violations or deviations
were identified.
Review of the Spent
Fuel Shipping Program
(71707)
As
a followup to the
observations
mentioned
in
NRC Inspection
Report
50-400/90-17,
the inspectors
met with licensee
management
to discuss
the
spent fuel shipping
program.
Items discussed
included the creation
and
spread of the radiological
crud hazard,
efforts underway to control this
hazard,
resource's
committed to the program,
and the project schedule.
Licensee
personnel
have
been responsive
to the problems resulting from the
new radiological
hazard.
A rack processing facility is
now in place
and
covers
provided to spent
fuel
pools to contain/minimize
the
spread
of
airborne contamination
during work activities.
Although these actions
are
considered
to
be
good,
they are basically
responsive
in nature
and not
'ro-active.
The need for pro-active planning
was emphasized.
The
BWR fuel shipped
from other
CP&L facilities is stored with the Harris
spent fuel in the "A" spent fuel pool.
This simple concept
has resulted
in the dispersion of the
BWR spent fuel crud throughout the B, C,
and
D
fuel pools,
as well as in the refueling transfer canals.
The inspectors
discussed
how this past action
may not
have enforced
ALARA concepts
in
that the creation of a larger area for decontamination
work will result in
an
increase
in time to clean
up the
areas
and therefore result in'n
increase
in worker radiation exposure.
Finally, the inspectors
discussed
the
need to prevent the transfer of this
crud to plant systems.
The spread of this crud to the spent fuel skimmer
system
has already contributed to localized radiation hot spots in the
FHB.
The
need to prevent the transfer of the crud to the
RCS during refueling
operations
was
reemphasized.
The potential
for this eventuality,
and
the resultant
increase
in radiation
levels
in the
WPB and
RAB with
accompanying
potential
increases
in personnel
exposures,
would also
be
detrimental
to ALARA objectives.
~ g
V
~
~
13
Licensee
management
realize
the significance of,this situation
and
have
initiated steps
to reduce
the effects
of the radiological
hazard.
A
corporate quality assurance
audit of spent fuel activities
and
a special
review by an independent third party wer e performed.
Also,
a spent fuel
crud task force
has
been established.
The licensee is presently planning
to implement all of the resulting
recommendations.
The reports did not
identify any significant problem areas
and licensee
management
believes
adequate
resources
have
been
devoted
or. are available for this program.
The inspector
reviewed the audit reports
and associated
recommendations.
The licensee
was encouraged
to continue their pro-active measures.
No violations or deviations
were identified.
Follow-up of Onsite Events
(93702)
On October
14,
1990,
during
a routine daily grab sample for an inoperable
condenser
vacuum
pump effluent radiation
monitor
(REM-3534),
plant
chemists
found traces of radioactive
Xenon gas.
A follow-up sample of the
three
steam
generators
showed activity in the
"A" steam generator
which
indicated that
a small
primary to secondary
steam
generator
leak
had
developed.
Both "B" and
"C" steam generators
indicated
no activity.
The leak from the
"A" steam
generator
was calculated
to be approximately
15
GPD.
requires
action
to
shutdown
the plant if steam
generator
leakage
increases
to
1
GPM through all .the
steam
generators
or
500
GPD through
any
one
steam
generator.
Since the
TS limits were not
exceeded,
plant
management
decided
to continue
power operation
while
closely monitoring the leakrate
trend.
The licensee
has also taken steps
to minimize the potential
contamination of the secondary plant.
Numerous
actions
have
been initiated to mitigate the consequences
of this event:
The "A" steam
generator
and turbine building effluent stack is being
sampled
every
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Continuous
secondary
releases
were
terminated
and
batch
releases
implemented.
Condensate
polisher flow was optimized.
The
HEPA filter system for the
condenser
vacuum effluent
system
was placed in service.
If steam generator, leakage
approaches
75 GPD,
a power reduction to 50
percent is planned.
The inspectors will continue to closely monitor the licensee's
actions in
this area.
12.
Meeting with Local Officials (94600)
On October
19,
1990, the inspectors
met with members of the North Carolina
Radiation Protection staff to discuss
the role of the resident inspectors
during
an
emergency.
Topics
discussed-
included
a brief history
and
organizational
structure
of the
NRC,
NRC modes
of response
during
an
emergency,
and emergency facilities/equipment available to the inspectors.
The inspectors
were
impressed
with the interest exhibited
by the state
personnel
and felt that all participants benefitted from this meeting.
An internal office evaluation
was
conducted
on October
11,
1990, of the
licensee's
quality assurance
program implementation
by reviewing recent
inspection reports,
SALP reports,
open items, licensee corrective actions
for
NRC inspection
findings,
and
licensee
event reports.
Particular
emphasis
was
placed
on all
new items or findings since
the last
report period-(November
30,
1989).
It was
recognized
that
an
team
inspection is currently scheduled
during this
SALP period.
Recommenda-
tions were
made to maintain inspection efforts at the current level.
14.
Licensee Action on Previous
Inspection
Findings
(92702
5 92701)
(Closed)
URI 400/89-17-02:
Potentially inadequate
testing of containment
conductor
protective
devices.
Although
the
testing
method for verification of a breaker's
instantaneous
trip setting
was
changed, it was confirmed that the "run up" method of testing,
which
'll ensured
protection.
was less accurate,
st>
15.
Exit Interview (30703)
The inspectors
met with licensee
representatives
(denoted in paragraph
1)
at the conclusion
of the inspection
on October
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 violations,
weaknesses,
unresolved
item,
and inspector followup
items
addressed
below and in the
summary section of this report.
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.
13.
Evaluation of Licensee guality Assurance
Program Implementation
(35502)
Item Number
Descri tion and Reference
400/90-20-01
400/90-20-02
400/90-20-03
URI:
Periodic
calibration
check
of
installed thermocouples,
paragraph
3.c.
VIO:
Failure
to
accurately
document
surveillance
performance
dates
and times,
paragraph
3.c.
VIO:
Failure to adhere to plant maintenance
procedures,
paragraphs
4.a
and 4.b.
15
Item Number
cont
d
,Descri tion and Reference
400/90-20-04
400/90-20-05
and Initial i sms
VIO:
Failure to perform required
compensatory
. actions
for
an
radiation monitor, paragraph
5.c.
IFI:
Review
the
licensee's
activities
regarding
wrong size starter coils in MCCs,
paragraph
6.b.
ANSI
BAST
BTRS
CFR
'EOP
EPT.
FHB
GPD
GPM
HZ
IFI
JCO
LER
'MCC
MMM
NED
NRC
ONS.
OST
Alternating Current
Auxiliary 'Feedwater
As Low As Reasonably
Achievable
American National
Standards
Institute
Boric Acid Storage
Tank
Boron Thermal
Regeneration
System
Boiling Water Reactor
Closed Circuit Television-
Component Cooling Water
Code of Federal
Regulations
Condensate
Storage
Tank
Emergency Operating
Procedures
Engineering
Performance
Test
Engineered
Safety Feature
Fuel Handling Building
Final Safety Analysis Report
Gallons
Per
Day
Gallons
Per Minute
High Efficiency Particulate Absorption
Hertz
Inspector
Follow-up Item
Justification for Continued Operation
Licensee
Event Report
Motor Control Center
Maintenance
Management
Manual
Maintenance Surveillance Test
Non-Conformance, Report
Non-Cited Violation
Nuclear Engineering
Department
Nuclear Regulatory
Commission
Nuclear Reactor Regulation
Onsite Nuclear Safety
Operations
Surveillance Test
l~
It
16
PGO
- PIC
PNSC
QA/QC
RCS/RC
'OOR
TS
VAC"
VDC
WPB
WR/JO
Plant
Change
Request
Plant General
Order
Primary Instrument Control
.
Preve'ntive
Maintenance
Plant Nuclear Safety Committee
Pounds
per Square
Inch Gage
Quality Assurance/Quality
Control
Reactor Auxiliary Building
Reactor
Coolant System
Pump
Residual
Heat Removal
Radiation Monitoring System
Resistance
Temperature
Detector
Reactor
Vessel
Level Indicating System
Radiation Work Permit
Refueling Water Storage
Tank
Significant Operational
Occurrence
Report
Technical Specification
Unresolved. Item
Volts Alternating Current
Volts Direct Current
Violation
Waste Processing
Building
Work Request/Job
Order
4 g
O.