ML18009A899

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Insp Rept 50-400/91-06 on 910323-0419.No Violations Noted. Major Areas Inspected:Radiological Controls,Fire Protection Surveillance Observation,Maint Observation & LERs
ML18009A899
Person / Time
Site: Harris 
Issue date: 02/02/1991
From: Christensen H, Shannon M, Tedrow J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18009A897 List:
References
50-400-91-06, 50-400-91-6, NUDOCS 9105210221
Download: ML18009A899 (13)


See also: IR 05000400/1991006

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report No.:

50-40D/91-06

Licensee:

Carolina

Power and Light Company

P. 0.

Box 1551

Raleigh,

NC 27602

Docket No.:

50-400

Facility Name:

Harris

1

Inspection

Conducted:

March 23 - April 19,

1991

Inspectors:

J.

e row,

endor

Resi

ent

nspector

License No.:

NPF-63

ate

>gne

r.

I

M. Shannon,, Resident

Inspector

Approved by:

g~H.

r1stensen,

ection Chic

Reactor Projects

Branch '1

Division of Reactor Projects

sZ5

Dat

Signed

5

at

gned

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,

design

changes

and modifications, corrective action 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:

One violation was identified: failure to install

a backflow preventer

during

the performance of local leak rate testing

(paragraph

3).

Improvements

were noted in the licensee's

radiological protection

program

(paragraph

2.b(4))

and in the corrective action program (paragraph

7).

910521 0221

910502

PDR

ADOCK 05000400

G

PDR

REPORT

DETAILS

1.

Persons

Contacted

Licensee

Employees

  • P. Beane,

Manager, guality Control

  • J. Collins, Manager,

Operations

C. Gibson,

Manager,

Programs

5 Procedures

  • C. Hinnant,

General

Manager,

Harris Plant

D. McCarthy, Manager, Site Engineering

  • B. Neyer,

Manager,

Environmental

5 Radiation Monitoring

  • R. Morgan, Manager,

Project Assessment

HNP

  • T. Morton, Manager,

Maintenance

  • J. Nevill, Manager,

Technical

Support

  • C. Olexik, Manager,

Regulatory

Compliance

R. Richey, Vice President,

Harris Nuclear Project

E. Willett, Manager,

Outages

8 Modifications

Other licensee

employees

contacted

included office, operations,

engineering,

maintenance,

chemistry/radiation,

and corporate

personnel.

  • Attended exit interview

H. Christensen,

Section Chief Reactor Projects,

was

on site April 15 and

16,

1991, to tour the plant and hold discussions

with the resident

inspectors

and plant management.

Acronyms

and initialisms used throughout this report are listed in the

last paragraph.

2.

Review of Plant Operations

(71707)

The plant began this inspection

period in cold shutdown

(Node 5).

At

10:57 p.m.

on March 25, the reactor vessel

head closure bolts were

detensioned

and the refueling condition

(Node 6) was entered.

At 4:30

a.m.

on April 4, the reactor vessel

was completely defueled.

The plant

remained in the defueled condition 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; Outage Shift Manager's

Log; Night Order Book;

Equipment Inoperable

Record; Active Clearance

Log; Jumper

and Wire

Removal

Log; Temporary Modification Log; Chemistry Daily Reports;

Shift Turnover Checklist;

and selected

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,

surveillance,

and maintenance activities in

progress.

Some of these

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; reactor

contain'ment building; waste processing

building; turbine building;

fuel handling building; emergency

service water building; battery

rooms; electrical

switchgear

rooms;

and the technical

support center.

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

in an orderly and

professional

manner.

In addition, the inspector

observed shift

turnovers

on various occasions

to verify the continuity of plant

status,

operational

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

radiation work permits to

verify that controls were adequate.

I

The licensee

has

made. substantial

efforts to reduce radiation

levels in the plant.

A new

RCS shutdown chemistry control

program

was

implemented during this refueling outage to dissolve

activated corrosion products into the

RCS coolant for removal.

Further, efforts were noted to remove hot spots

associated

with

the treated

laundry and hot shower tanks.

These

tanks were

cleaned

and flushed with demineralized

water to remove hot

spots.

,The result of this flushing produced substantially

lower

radiation levels at the tanks.

This enabled

the licensee to

repost the areas

as

a radiation area

instead of a high radiation

area.

The

new chemistry control program utilized excess.RCS

coolant

hydrogen

and oxygen concentrations

in conjunction with

appropriate

temperatures

to create

a reducing/oxidizing

condition in which the corrosion product oxide layer becomes

soluble in the

coolant.

The coolant

was then purified via the

normal

letdown system to remove the corrosion products.

This

method

has

been utilized at other licensee

plants

and by the

Japanese

nuclear industry.

The long term objective of this

program is to achieve

lower component radiation

dose rates

over

several

fuel cycles, especially in the steam generator

channel

heads

where significant activities occur with resultant

high

radiation dose.

Although an actual

reduction in dose rate

was

not achieved, in these

components

by the licensee,

the absence

of

any increase

in dose rate from the previous refueling outage

was

encouraging.

The licensee's

efforts to reduce plant radiation levels

produced

positive results

which will lower personnel

exposures

and

be

beneficial to ALARA objectives.

Security Control - In the course of 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 which

included:

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

(CCTY) 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.

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.

C.

Review of Nonconformance

Reports

Adverse Condition Reports

(ACRs) were reviewed 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.

ACR 91-136 reported that the appropriate

action contained in

procedure

AP-301, Adverse Weather,

was not completed

upon receiving

a

severe

storm warning.

This procedure

requires all exterior doors in

the reactor auxiliary building and fuel handling building be closed

upon receiving

a tornado warning.

Due to outage work, numerous

cables

and pressure

hoses

were rout'ed through

an exterior door for

work inside the containment building.

On March 29,

a tornado warning

was issued for approximately

one half hour.

Actions were not

initiated to close the exterior door because

of insufficient time to

do so.

The licensee is presently reviewing this event to determine

appropriate corrective action.

Inspector

Followup Item (400/91-06-01):

Review the licensee's

corrective action to close exterior

doors during severe

storm

warnings'.

3.

Surveil lance 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:

EPT-176T

Temporary Procedure for Emergency Service Water System

Line Stop Installation,

Removal,

and System Operation with

Line Stop Installed.

MST-I0047 Calibration of Nuclear Instrumentation

System

Power

Range

N44

OST-1013

lA-SA Emergency

Diesel

General Operability Test Monthly

Interval

OST-1823

1A-SA Emergency

Diesel Generator

18 Month Operability Test

EST-212

Type

C Local Leak Rate Tests

During the performance

of local leak rate testing

on April 16,1991,

the

inspector noticed that the technician

connected

the leak rate monitor to

the instrument air header

as

a supply source to pressurize

a penetration

for the pressurizer

sample

system.

The technician

was questioned

about

0

the validity of this action since

a previous

problem had occurred in

October,1989,

during which the instrument air header

was contaminated

while performing local leak rate testing.

The inspector

was informed that

this action was acceptable.

The licensee's

corrective action for the

October event

was. reviewed.

The licensee

had revised administrative

procedure

AP-005, Procedure

Format and Preparation,

step 5.6.1.15,

to

require procedures

be written such that

a backflow preventer

(check valve)

be installed

when temporarily connecting

a radioactive

system to the

instrument air system.

This procedure further required that plant

procedures

incorporate this action prior to the next performance of the

applicable

procedure.

The local leak rate test procedure,

EST-212, did

not incorporate this requirement.

Failure 'to properly implement procedure

AP-005 is contrary to the requirements

of TS 6.8.l.a

and is considered

to

be

a violation.

Violation (400/91-06-02):

Failure to install

a backflow preventer during

the performance of local leak rate testing.

When notified of this finding, licensee -personnel

took immediate

corrective action

and revised the testing

procedure to incorporate

the

backflow preventer

and initiated an investigation into the root cause for

this incident.

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

(WR/JO) activities:

Removal of reactor vessel

head vent piping and restriction orifice.

Disassembly of emergency

diesel

generator

"A" main bearings

in

accordance

with procedure

CN-N0152,

Emergency

Diesel

Generator

Main

Bearing Disassembly

and Reassembly.

Installation of refueling cavity seal

ring in accordance

with

procedure

CN-N0074, Reactor

Vessel

Cavity Seal

Assembly Installation

and Removal.

Emergency diesel

generator cylinder head

and valve reassembly

in

accordance

with procedure

CN-M0150,

Emergency

Diesel

Generator

Cylinder Head

Removal,

Disassembly

and Reassembly.

Disassembly,

inspection,

and repair of seat

leaks

on emergency

service water valves

1SW-39,

1SW-40,

and

1SW-274 in accordance

with

procedure

CM-N0017, Jamesbury Butterfly Wafer-Sphere

Valves (24-48")

Disassembly

and Maintenance.

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

HRC Enforcement Policy.

a.

(Closed)

LER 91-02:

This

LER reported

a violation of the technical

specifications

when two trains of reactor coolant

pump underfrequency

trip devices

were found to be inoperable.

.This event

was previously

discussed

in

NRC Inspection

Report 50-400/90-04

and was the subject

of a violation (400/90-04-03).

For record purposes,

this

LER will be

closed

and the licensee's

corrective action will be reviewed with the

violation.

b.

C.

(Open)

LER 91-04:

This

LER reported

the entry into TS 3.0.3 due to

both charging/safety

injection

pumps being inoperable.

This

situation arose

when the "A" safety injection

pump was under

an

equipment clearance for valve testing,

and the cooling water supply

system for the "B" pump failed

a surveillance test.

The licensee

is

presently

implementing corrective action which will include revising

the applicable surveillance test procedure

and

an evaluation to

assess

the method to verify. check valve closure.

The

LER will remain

open pending completion of the corrective actions.

(Closed)

LER 91-05:

. This

LER reported

the entry into TS 3.0.3 when

the "B" emergency

load sequencer

failed

a surveillance test with the

"A" charging

pump inoperable.

This event also rendered

both charging

pumps inoperable.

The faulty relay in the load sequencer

was

subsequently

replaced.

d.

(Open)

LER 91-06:

This

LER reported that

a shutdown margin

calculation

was not performed while testing the source

range nuclear

instruments.

The licensee attributed the cause of this event

as

misinterpretation of the

TS action statement.

The licensee

plans to

revise applicable surveillance

procedures

by adding

a caution step

alerting operators

to this requirement.

This

LER will remain

open

pending completion of the corrective action.

6.

Design'Changes

and Modifications (37828)

Installation of new or modified systems

were reviewed to verify that the

changes

were reviewed

and approved

in accordance

with 10 CFR 50.59, that

the changes

were performed in accordance

with technically adequate

and

approved

procedures,

that subsequent

testing

and test results

met

acceptance

criteria or deviations

were resolved in an acceptable

manner,

and that appropriate

drawings

and facility procedures

were revised

as

necessary.

This review included selected

observations

of modifications

and/or testing in progress.

The following modifications/engineering

evaluations

were reviewed:

PCR 5851

Repair of Emergency Service Water

(ESW) Butterfly Valve

Pitting

PCR 5457

'ESW Branch Connections

PCR 5171

Modification to Add Digital Meters to Power

Range

Drawer

PCR 4488

Two CSIPs Available for Mid-Loop Operation/Evaluation

No violations or de'viations

were identified.

7.

Review of the Corrective Action Program

(40500)

The inspectors

reviewed the licensee's

corrective action program

and

recent

changes

that had

been

made.

This program includes

the reporting of

non-conforming conditions,

determinations

of event reportability, analysis

of event root cause,

action item tracking,

and evaluation of human

performance

problems.

As part of this inspection,

numerous

Adverse

Condition Reports

(ACR) and root cause

evaluations

were reviewed along

with the following procedures:

PLP-002

Corrective Action Program

PLP-618

Human Performance

Evaluation

System

AP-026

Action Item Tracking

AP-605

Root Cause

Evaluations

and Reporting

AP-615

Adverse Condition Reporting

The licensee

has recently

implemented

a

new non-conformance

reporting

system replacing the Significant Operational

Occurrence

Reports with ACRs.

The inspectors

reviewed all of the

ACRs and

have noted

a lower threshold

for reporting identified problems.

Another benefit of the the

new system

was inclusion of several

other previously independent

reporting systems

such

as the non-conforming reports

and field reports

generated

by the

gC

department.

This streamlined

the reporting system

and improved problem

trending abilities.

All other reporting

systems for specific types of

adverse

conditions (for example:

work request,

plant change

request,

security investigations/events,

radiation control feedback)

have

been

designated

as

subprograms

to the

ACR system with triggers established

for

transfer to the

ACR system.

This reporting

system

has

been

implemented

company wide by the licensee

and should

improve communication/problem

correction

between

the licensee's

nuclear plants.

The

ACRs will be

reviewed for adverse

trends

on

a quarterly basis,

however,

due to the

relatively recent, implementation of this system, .an adverse

trend report

was not yet available.

Training was given to appropriate

licensee

personnel

for conducting root cause analysis

and

human performance

evaluations.

Procedure

AP-026 contains

a provision for extending corrective action

due

dates.

Corrective .actions

which are not completed

by the due date are

reported to the Plant General

Manager.

The inspector

reviewed the latest

corrective action overdue. report.

Of the

27 items

on this list, several

items were

10 months

overdue for completion

and

one item was approximately

one year overdue.

It appears

that there is little effort required to get

an extension.

The inspector

considered 'that the lack of attention given

to corrective action

due dates

tended to reduce

the effectiveness

of the

corrective action process.

In conclusion,

the inspector considered

the changes

made to the corrective

action program to be improvements

and should produce'ositive

effects

on

safe plant generation.

Licensee Action on Previously Identified Inspection

Findings

(92702,

92701)

(Closed)

IFI 400/90-20-05:

Review the licensee's

activities regarding

wrong size starter coils in motor control centers.

During the investigation of this event'the

licensee

discovered

two

additional motor control centers

(1823-SB

and

1B31-SB) with 120

VAC

.

starter coils installed.

The licensee

has

completed

an engineering

evaluation,

PCR-5518,

120

VAC versus

110

VAC Starter Coils,

and has,

determined that the installed

120

VAC 'coils would properly pick up at

lower voltages.

Therefore,

the affected, equipment

remained operable.

The

licensee

is nevertheless

replacing the

120

VAC coils with the

110

VAC

coils in accordance

with plant design.

Exit Inte'rview (30703)

The inspectors

met with licensee

representatives

(denoted

in paragraph

1)

at the conclusion of the inspection

on April 19,

1991.

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, 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

400/91-06-01

IFI:

Review the licensee's

corrective action to

close exterior doors during severe

storm

warnings,

paragraph

2.c.

400/91-06-02

10.

Acronyms and Initiali sms

VIO:

Failure to install

a backflow preventer

during the performance of local leak rate

testing,

paragraph

3.

ACR

ALARA

AP

CCTV

CFR

CM

EPT

EST

. IFI

LER

MST

NRC

OST

PCR

PLP

QA/QC

RCS

RWP

TS

VAC

VIO

WR/JO

Adverse Condition Report

As Low As Reasonably

Achievable

Administrative Procedure

Closed Circuit Television

Code of Federal

Regulations

Corrective Maintenance

Engineering

Performance

Test

Engineering Surveillance

Test

Inspector

Follow-up Item

Licensee

Event Report

Maintenance Surveillance Test

Nuclear Regulatory

Commission

Operations

Surveillance

Test

Plant

Change

Request

Plant Program

Quality Assurance/Quality

Control

Reactor Coolant System

Radiation

Work Permit

Technical Specification

Volt Alternating Current

Violation

Work Request/Job

Order