ML18010A388
| ML18010A388 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/06/1991 |
| From: | Christensen H, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18010A385 | List: |
| References | |
| 50-400-91-18, NUDOCS 9109240392 | |
| Download: ML18010A388 (12) | |
See also: IR 05000400/1991018
Text
gpaS REQy~
p
'E
0
co
A,
s
ts
C
C
sVl
rg
Is
++*++
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report No.:
50-400/91-18
Licensee:
Carolina
Power and Light Company
P. 0. Box-1551
Raleigh,
NC 27602
Docket No.:
50-400
License No.:
Facility Name:
Harris
1
Inspection
Conducted:
July 20 - August 23,
1991
Lead Inspector:
J.
edrow,
Sensor
Resident
Ins
ctor
Other Inspectors:
M.
S annon,
Resident
Inspector
Approved by:.
hristensen,
Section Chief
Division of Reactor Projects
Da
e
Soigne
Date Signed
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,
safety
system
walkdown,
licensee
event reports
and licensee self assessment.
Numerous facility tours
were
conducted
and facility operations
observed.
Some of these
tours -and
observations
were conducted
on backshifts.
Results:
Two violations
were identified;
Failure
to approve
and
forward Technical
Specification
required
audits within 30 days,
Paragraph
7
and;
Failure to
document corrective actions,
Paragraph
7.
One weakness
was identified:
Because
the documentation for the audit program
is
scattered
through
various
reports, it was difficult to deterII,ine
the
= effectiveness
of the
program
as required
by 10 CFR 50, Appendix B, Criterion
XYIII, Paragraph
7.
One unresolved
item was identified:
Improper Crosby relief valve blowdown ring
settings,
Paragraph
2.d.
9109'240392
910906
ADOCK 05000400
G
REPORT
DETAILS
1.
Persons
Contacted
Licensee
Employees
- P. Beane,
Manager, guality Control
- J. Collins, Manager,
Operations
- G. Forehand,
Manager,
Management/Organization
- C. Gibson,
Manager,
Programs
and Procedures
C. Hinnant,
General
Manager, Harris Plant
- D. McCarthy, Manager, Site Engineering
B. Meyer, Manager,
Environmental
and Radiation Monitoring
T. Morton, Manager,
Maintenance
J. Nevill, Manager,
Technical
Support
C. Olexik, Manager,
Regulatory Compliance
A. Powell, Manager, Harris Training Unit
R. Richey, Vice President,
Harris Nuclear Project
H. Smith, Manager,
Radwaste
Operation
- N. Wallace, Sr. Specialist,
Regulatory Compliance
E. Willett, Manager,
Outages
and Modifications
W. Wilson, Manager,
Spent Nuclear
Fuel
- L. Woods,
Manager,
System Engineering
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 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
and the licensee's
administrative
procedures.
The following records
were reviewed:
Shift Supervisor's
Log; Control
Operator's
Log; Night Order Book; Equipment Inoperable
Record; Active
Clearance
Log; Jumper
and Wire Removal
Log; Temporary Nodification
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;
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.
(5)
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.
(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.
Review of Nonconformance
Reports
Adverse
Condition
Reports
(ACRs)
were
reviewed
to veri fy 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.
No violations or deviations
were identified.
CCW Inventory Loss
On August 8,
1991, at 8:21 a.m.,
a second
CCW pump
was started
in
order to support
troubleshooting
of the
"A" RHR Heat Exchanger
Outlet
Flow Indicator FI-688A.
The operators
immediately noted
a
decreasing
CCW surge
tank level
and manually maintained
CCW tank
level.
Additional operators
were dispatched
to find the cause of the
leakage
and it was subsequently
determined that various relief valves
had lifted.
A control board operator then initiated
CCW flow through
the
RHR heat exchanger
to reduce
system pressure
from 140
PSIG to 120
PSIG,
but leakage
continued until the
second
running
pump
was
secured.
A second
test
run
was started
at 12:20
p.m. to verify which
relief valves
had lifted and
to
determine
the correct
system
configuration to prevent further relief valve lifting. It was found
that four relief valves lifted following the
second
pump start.
It was also
determined
that if CCW system
pressure
was maintained
less
than
95
PSIG,
no relief valves
would lift when the
second
pump started.
Flow is presently
being maintained
through
the
heat
exchanger
to maintain
system
pressure
below 95
PSIG until this
deficiency is adequately
resolved.
Discussions
with operations
personnel
indicated that
on previous
pump starts,
minor
head
tank level
decreases
had
been
noted.
These
decreases
had been attributed to placing
a cold
CCW system into
operation.
The
CCW system
may
have
been
spi king high
enough
on
previous
pump starts
to cause relief valve lifting but the valves
reset with little head tank loss.
Further investigation
found that the
CCW relief valves
had incorrect
nozzle ring settings
which resulted
in a lower- reset
pressure
than
the
135
PSIG specified
in the vendor test
data reports. 'any of
these
valves
had
been
tested for proper relief setting
during the
1991
refuel-ing
outage.
The
cause
of the incorrect
nozzle ring
settings
has
not
been
determined.
Following a maintenance
history
review it was found that the suspect
valves
had
been disassembled
and
worked
on prior to initial startup in 1986.
It appeared
that during
the
1986 corrective maintenance activities,
the valve blowdown rings
were improperly set prior to returning the valves
back to service.
Further review found that procedural
guidance
was lacking
on
how to
set
the
blowdown rings; specific training
on
how to measure
the
blowdown ring setting
was not adequate;
and the manufacturer's
design
data
and technical
manual
were difficult to interpret,
leading to
different interpretations
in
how to set
the
blowdown rings.
It
appeared
that operator
actions
were correct
and timely in addressing
this
event.
The relief valve deficiency
has
the potential
for
causing
a loss of both
CCW systems
and it also
has the potential for
causing
other safety
systems
to
become
The improper
setting of various
Crosby relief valve blowdown rings is- considered
to
be
an
unresolved
item
pending
NRC review of the licensee's
engineering resolution.
(400/91-18-01):
Improper
Crosby relief valve
blowdown ring
settings.
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:
PN-N0057
Terry Turbine Annual Bolt Retorquing
NST-I0123 Pressurizer
Pressure
Protection
Set II Operational
Test
NST-I0125 Main Steam Line Pressure
Loop
1 Operational
Test
NST-I0400 Spent
Fuel
Pool North Monitor, RN-*1FR-3567B-SB Operational
Test
The
maintenance
personnel
were
found
to
be
knowledgeable
of the
procedures,
used calibrated test equipment,
properly notified the control
room,
maintained
communications,
and followed the applicable
procedure
steps,
therefore
these
procedures
were performed .satisfactory.
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
(WR/JO) activities:
On July 24,
1991 the "B" spent fuel
pump was disassembled
in order to
perform
pump
seal
replacement.
Due to the
high contamination
.potential,
as
a result of Brunswick fuel storage,
special
health
physics
precautions
were
required.
The
maintenance
personnel
received
constant
HP coverage,
followed maintenance
procedures,
had
the required tools,
were properly dressed,
and appeared
to be very
knowledgeable
of
the
assigned
task,
the
job
was
performed
expeditiously with no observed deficiencies.
The inspector
also witnessed
the
replacement
of FI-0688A,
CCW flow
indicator,
per
WR/JO 91-ALI(1.
The maintenance
technicians
properly
followed corrective
maintenance
procedure,
CM-I0084, Methodology of
Scale
Replacement
for
VX2 52 Indicators,
=used
appropriate
tools,
obtained
correct
replacement
parts
and
therefore
performed
an
acceptable
replacement of FI-0688A.
'o
violations or deviations
wer e identified.
5.
Safety Systems
Walkdown (71710)
The inspector
conducted
a walkdown of the service water system to verify
that the lineup
was in accordance
with license
requirements
for system
operability and that the system
drawing and procedure correctly reflected
"as-built" plant conditions.
It was
found that the
system
was lined up
according
to applicable
system lineup procedures,
components
were clearly
identified,
system
drawings
were correct,
and the
system
appeared
to be
well maintained.
No violations or deviations
were identified.
6.
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
r
a.
(Closed)
LER 90-01:
This
LER reported
a violation regarding
response
time testing of an engineered
safety featurechannel.,This
matter
was previously discussed
in
NRC Inspection
Report 50-400/90-02
and
was
the subject of a non-cited violation
(NCV 400/90-02-06).
The
licensee
has completed testing of the omitted channel
instrumentation
and
has
incorporated
controls into appropriate
procedures
used in
writing and approving procedure
changes.
b.
(Closed)
LER 91-14:
This
LER reported that cooling water flow to the
"A" residual
heat
removal
pump
was
inadvertently
isolated
for
approximately
15 minutes.
The licensee
has
completed
corrective
actions
to include the cooling water throttle valves into the locked
valve program
and has
reviewed the event with maintenance
personnel.
Evaluation of Licensee Self Assessment
(40500)
In January
1991, the licensee
made organizational
changes
which eliminated
the
guality
Assurance
Department
(gA)
and
reassigned
the
gA
responsibilities
to the Nuclear Assessment
Department (NAD).'n order to
evaluate
the
new organization,
assessments
performed
by
NAD were reviewed
to ensure
Technical
Specification
requirements
were being met.
Various
deficiencies
were noted.
The
licensee
is
required
to perform various
Technical
Specification
required
audits
at various
frequencies.
The licensee's
reorganization
changed
the audit process
to assessments
and three
1991
assessments
were
performed
'to meet specific audit requirements.
TS 6.5.4.4 requires that
audit reports
shall
be
prepared,
approved
by the
manager
gA/NAD, and
forwarded within 30 days after completion of the audit to the Executive
Vice
President,
Power
Supply
and
Senior
Vice
President,
Nuclear
Generation.
The inspector
found that the fire protection assessment
which
was conducted
February 8-22,
1991,
was not approved until July 16,
1991;
the maintenance
and
E&RC assessment
which'as
conducted April 1-19,
1991,
,was
not
approved
until
June
26,
1991;
and
the
outage
management/
modification assessment
which was
conducted
May 9-17
and
June 14,'991,
was not approved until July 30,
1991.
This is contrary to TS 6.5.4.4 in
that the
licensee failed to approve
and forward these
audits within 30
days.
It was also
found that the licensee failed to forward the
(1991)
fire protection,
maintenance
and
E8RC,
and outage management/modification
assessments
to the executive. and senior vice presidents
as required.
The
licensee's
failure to approve
and forward these
audits within 30 days to
the appropriate
levels of management
is contrary to
and is
considered
to be
a violation.
Violation (400/91-18-02):
Failure to approve
and- forward
TS required
audits within 30 days.
The inspector
performed
an indepth review of Assessment
91-02, Maintenance
and
ESRC,
and it was
found that various
adverse .conditions
noted
on the
observation
reports
were not documented
ip the inspection report.
The
following are
examples
of field observations
which were not noted in the
assessment
report or resolved
on the observation
sheets:
It
Seven out of 26 individuals did not review the
RWP prior to filling
out "CHITS" to begin work in an
RWP area.
Older work packages
did not require
PMT when
asked
on the work
request
sheet,
regular
packing
was
replaced
with live load packing
without any testing,
and
two valves
were disassembled
and inspected
but no
PMT was recorded.
I
A pipe
rack is
being
used
to store
several
different types of
material.
This rack contains
both stainless
steel
and carbon
pipe.
Some of the pipe is marked 9-List and
some
ends of the pipe are not
capped
nor taped.
The individuals involved didn't have
much experience with this task,
and
attempted
to install
the
(cavi,ty seal)
rings
in the
wrong
direction around
the
head.
This took extra 'rigging time and delayed
the job a couple of hours.
'Temporary
power feed to battery chargers
was not tied off properly to
prevent accidental
short, if pulled.
An instrumentation line leading
from valve
1BD-133 was
supported
by
several
wraps of duct tape
attached
to
a mechanical
snubber/strut
assembly.
Possible
binding of the snubber
may have occurred.
Contract
worker exited containment
via step-off
pad but failed to
frisk hands
and feet, quickly frisked at
a second frisker,
and did
not monitor through portal monitor before exiting area.
10 CFR 50 Appendix
B Criteria XVIII and the licensee-'s
accepted
quality
Assurance
Program,
Corporate
equality
Assurance
Program
Manual
Rev.
14,
collectively
require
that
the
corrective
actions
for significant
conditions
adverse
to quality be documented.
gA Manual, paragraph
12.4.2
also requires
that if the condition is not confirmed,
the initiating
document
shall
be
canceled,
the
basis
for cancellation
noted
on the
document,
and the
document shall
be placed in a permanent file.
Contrary
to the
above
requirement,
the previous
adverse
conditions
were noted
on
various'bservation
sheets
but the resolution of the adverse
conditions
were not documented
or retained.
The fai lure to properly document
the
resolution
to adverse
conditions is contrary to
10 CFR 50 Appendix
B and
the licensee's
accepted
gA program
and is considered
to be
a violation.
Violation (400/91-18-03).:
Failure to document corrective actions.
~
'
The
licensee
is required
by
to perform audits
of unit
activities
on
a periodic basis.
10 CFR'0,
Appendix
B Criteria XVIII
requires
that
a comprehensive
system of periodic audits shall
be carried
out to verify compliance with all aspects
of the guality Assurance
Program
and to determine
the effectiveness
of the
program.
After an extensive
review of applicable
assessments,
gA reports,
and observations, it was
concluded that sufficient documentation of inspection activities may exist
to
show
conformance
to the
TS required
audits.
However,
the audit
activities for specific audit
requirements
are
fragmented
throughout
.
various reports
and therefor e it was difficult to draw
a conclusion that
the audited
areas
were satisfactory.
It was also noted that the licensee
in
some
cases
did not
document
a conclusion for specific
TS required
audits.
The audits
need sufficient documentation
to
show that audited
areas
were adequately
reviewed to justify conclusions
in audit reports.
Fragmented
documentation
made it difficult to determine
the effectiveness
of the program
and is considered
a program weakness.
Two violations were identified.
8.
Exit Interview (30703)
The inspectors
met with licensee
representatives
(denoted
in paragraph
1)
at'he
conclusion
of the inspection
on August 23,
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 Violations
and
Unresolved
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
400/91-18-01
400/91-18-02
400/91-18-03
9.
and Initial i sms
URI:
Improper Crosby relief valve blowdown ring
settings.
(Paragraph
2.d.)
VIO:
Failure to approve
and forward TS required
audits within 30 days.
(Paragraph
7).
VIO:
Failure to document correcti ve actions
(Paragraph
7).
ACR
CFR
ESRC
Adverse Condition Report
Closed Circuit Television
Component Cooling Water
Code of Federal
Regulations
Environmental
5 Radiation Control
Health Physics
LER
NAD
NRC
QA/QC
TS
WR/JO
Licensee
Event Report
Maintenance Surveillance Test
Non-Cited Violation
Nuclear Assessment
Department
Nuclear Regulatory
Commission
Post Maintenance
Test
Pounds
per Square
Inch Gage
Quality Assur ance/Quality Control
Residual
Heat
Removal
Radiation
Work Permit
Technical Speci'fication
Unresolved
Item
Violation
Work Request/Job
Order