ML18011A392
| ML18011A392 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/04/1994 |
| From: | Christensen H, Darrell Roberts, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18011A390 | List: |
| References | |
| 50-400-94-05, 50-400-94-5, NUDOCS 9403150203 | |
| Download: ML18011A392 (36) | |
See also: IR 05000400/1994005
Text
~pit RK0y
.v,
%eport No.:
50-400/94-05
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETlASTREET, N.W., SUITE 2900
ATLANTA,GEORGIA 30m4199
Licensee:
Carolina
Power
and Light Company
P.
O.
Box 1551
Raleigh,
NC 27602
Docket No.:
50-400
Licensee
No.:
Facility Name:
Harris
1
Inspection Conduc:
January
15 - February
18,
1994
Inspectors:
J.
C$
c
wt
Qe ior
esident
Inspector
C~
D te Signed
g
Cpl
D
o erts,
si
en
Inspector
Date
igned
Approved by:
H. Christensen,
Section Chief
Division of Reactor Projects
a
Si
ned
SUMMARY
Scope:
This routine insphction
was conducted
by two resident
inspectors
in the areas
of plant operations,
safety system walkdown, cold weather preparations,
review
of nonconformance
reports,
followup of onsite events,
maintenance
observation,
surveillance observation,
design
changes
and modifications,
system
engineering,
plant housekeeping,'adiological
controls, security, fire
protection,
preparations
for refueling, review of licensee
event reports,
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:
Two violations with multiple examples
were identified:
Failure to implement
procedures
properly,
paragraph 2.c., 2.d(2)
and 4.a(1);
Failure to implement
corrective actions,
paragraphs
2.d(l)
and 2.e.
A non-cited licensee identified violation regarding control of locked. high
radiation areas is discussed
in paragraph
5.b.
Several
areas of improvement
were noted:
Operator identification and response
to
a failed condensate
booster
pump recirculation valve prevented
a potential
plant trip, paragraph 2.a(l)(a);
The number of operator standing orders
was
reduced,
paragraph
2.a(1)(b);
Operator turnover process
strengthened
by daily
meetings with work control/managers,
paragraph 3.a(l);
The average
age of
9403150203
94030
ADOCK 05000 00
8
maintenance
backlog tickets
has
been
reduced,
paragraph
3.a(2);
Assessments
of the maintenance
functional
area
were good,
paragraph
3.a(3);
Preliminary
efforts for outage safety-related
breaker
replacement
modifications were
beneficial,
paragraph
4.a(2);
Good technical
support
was evident during
a
plant downpower,
paragraph 4.b(l);
Conduct of testing for the
new security
perimeter fence
was good,
paragraph 5.c(l);
Fuel receipt inspection
activities were found to be very thorough,
paragraph
6.a;
and scheduling of
safety train outages
was effective,
paragraph
S.a.
Several
weaknesses
were also identified:
classification of emergency
work was
too general,
paragraph
3.a(4);
poor initial written safety evaluation for a
plant modification, paragraph
4.a(3); superior housekeeping
standards
were not
being maintained
in several
plant areas,
paragraph
5.a; deficiencies
were
identified in the
new security perimeter fence,
paragraph 5.c(l); poor escort
control of visitors was noted,
paragraph
5.c(2); receipt inspection of Siemens
fuel indicated quality problems with the manufacturing of new fuel, paragraph
6.a;
and improvement
was needed
in the licensee's
safe
shutdown analysis,
paragraph
S.c.
REPORT DETAILS
1.
Persons
Contacted
Licensee
Employees
- D. Batton,
Manager,
Work Control
- B. Christiansen,
Maintenance
Manager
- J. Collins, Manager, Training
- M. Hamby,
Manager,
Regulatory
Compliance
- J. Dobbs,
Manager,
Outages
- J. Kiser, Manager,
Radiation Control
- D. McCarthy, Manager,
Regulatory Affairs
J. Hoyer,
Manager, Site Assessment
- R. Prunty,
Nanager,
Licensing
and Regulatory
Programs
- W. Robinson,
Vice President,
Harris Plant
~ *W. Seyler,
Manager,
Project
Management
H. Smith,
Manager,
Radwaste
Operation
- D. Tibbitts, Manager,
Operations
B. White, Manager,
Environmental
and Radiation Control
- 0. Wilkins, Manager,
Spent
Fuel
- L. Woods,
Manager,
Technical
Support
- H. Worth, Manager,
Onsite Engineering
Other licensee
employees
contacted
included office, operations,
engineering,
maintenance,
chemistry/radiation
and corporate
personnel.
"Attended exit interview
2.
and initialisms used throughout this report are listed in the
last paragraph.
Operations
a ~
Operational
Safety Verification (71707)
The plant continued in power operation
(Mode 1) for the duration
of this inspection period.
(1)
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 supervisor's
log; control operator's
log;
night order book; equipment
record; active
clearance
log; grounding device log; temporary modification
log; chemistry daily reports; shift turnover checklist;
and
selected
radwaste
logs.
In addition, the inspector
independently verified clearance
order tagouts.
'
The inspectors
found the logs to be readable,
to be well
organized,
and to provided sufficient information on plant
status
and events.
Clearance
tagouts
were found to be
properly implemented.
(a)
On January
24,
1994, at approximately 5:30 a.m.,
a
control
room operator noticed that the "B" condensate
booster
pump recirculation valve (ICE-261) indicated
partially open
on the main control board.
The normal
valve position was fully closed.
An auxiliary
operator
was dispatched
to isolate the recirculation
line manually.
The line was isolated before the
recirculation valve had completely failed open.
The
inspector discussed
the operator's
action with
licensee
personnel
and
was informed that no alarms
were received prior to the identification of the
problem by the operator.
If the problem
had not been
identified by the operator then
a plant trip would
have occurred
when sufficient condensate
flow was
diverted
away from the suction of the main feedwater
pumps with resultant
low suction pressure
pump trips
followed by the associated
turbine trip/reactor trip.
The operator's
attentiveness
to control
board
indications
was good
and prevented
a potential plant
(b)
The inspectors
reviewed operating standing orders to
determine if previously identified deficiencies
as
noted in
NRC Inspection
Report 50-400/93-14
had
been
corrected.
Also, the content of the standing orders
was discussed
with the manager of shift operations.
The licensee's
policy is to use the standing orders to
provide interim guidance until applicable
procedures
can
be revised.
Specific deficiencies identified
earlier
had
been corrected
by either deletion or by
inclusion into appropriate
procedures.
In addition,
the inspector
noted that the number of standing orders
had
been
reduced to approximately
10, which was about
one-half of the previous
number.
The licensee
had
made
improvements
in the dissemination of this
guidance.
No violations or deviations
were identified.
(2)
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 (RAB); waste processing
building (WPB); turbine
building; fuel handling building; emergency
building; battery rooms; electrical
switchgear
rooms;
and
the technical
support center.
During these tours, observations
were
made
on monitoring
instrumentation
which included equipment operating status,
area
atmospheric
and liquid radiation monitors, electrical
system lineup, reactor operating
parameters,
and auxiliary
equipment operating
parameters.
Indicated parameters
were
verified to be in accordance
with the
TS for the current
operational
mode.
The inspectors
also 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 inspectors
observed shift turnovers
on various
occasions
to verify the continuity of plant status,
operational
problems,
and other pertinent plant information
during these turnovers.
The licensee's
performance
in this
area
was satisfactory.
No violations or deviations
were
identified.
Safety
Systems
Walkdown (71710)
The inspectors
conducted
a walkdown of the Auxiliary Feedwater
(AFW) 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.
The inspectors
found minor drawing discrepancies
on drawings
2165-S-0544
and 2165-S-0545 pertaining to normally depicted valve
positions
and valve labeling.
The licensee's
valve lineup
procedures
and OP-137
agreed with actual
valve labeling in
the field.
The inspectors
also noted several
housekeeping
deficiencies
in the steam tunnel
and slight general
corrosion
on
the
TDAFW pump trip and throttle valve.
The inspectors
were
informed that
an existing
(PCR-7088,
CPL-2165-S-0544
Drawing
Correction for 1AF-55) already
addressed
one of the inspector's
comments
and that the inspector's
other
comments
would also
be
incorporated
into this
PCR.
The licensee's
system engineer
inspected
the general
corrosion
on the trip and throttle valve and
determined that this condition was acceptable
for a steam
admission valve.
No violations or deviations
were identified.
Cold Weather Preparations
(71714)
Between January
15 - 20;
1994, the plant experienced
extremely
cold, ambient air temperatures
which affected various plant
equipment
and caused
several
alarms
and erroneous
indications in
the main control
room.
On January
16,
ambient temperatures
were
recorded to be below
10 degrees
F.
Several
cases
of frozen
instrument sensing lines for non-safety related
components
occurred.
Examples
included the
RAB Normal Ventilation supply
fans which tripped numerous
times due to inadequate
heating for
the fan units.
The high discharge
pressure trips for all three of
the circulating water
pumps
had to be disconnected
due to frozen
pressure
channels
indicating dangerously
close to the
pump trip
setpoints.
Other equipment affected
by the record low
temperatures
(as low as
2 degrees
F) included the diesel driven
fire pump which auto started
due to frozen instrument lines,
and
condenser
pressure
indicators
on the main control
board which
began to show
a decrease
in condenser
vacuum.
Recognizing that
the instruments
on the
HCB did not provide input to the main
turbine trip on low condenser
vacuum,
operators verified that the
instruments
providing the trip input were indicating correctly.
One safety-related
system
was also affected
by the cold weather.
A frozen
RWST level transmitter located
near the
RWST resulted in
a high level alarm in the main control
room.
Eventually the level
channel,
LT-990, failed high and
was declared
inoperable placing
the plant in a seven
day Limiting Condition for Operation
(LCO).
Licensee
personnel
found
some of the affected instrument cabinets
with permanently installed heaters
that were not functioning.
In
other cases
instrument lines were found not to be adequately
insulated or heat traced.
Work tickets were initiated to correct
all of the above deficiencies
and other temperature
related
problems
and included
such actions
as installing heat tracing,
insulation,
and portable heaters.
As a temporary measure for the
RWST level channel,
a heat-emitting light fixture was installed
near the transmitter.
As noted in NRC Inspection
Report 50-400/
93-24,.the
inspectors
observed that the maintenance
backlog for
heat tracing, and temperature
maintenance
systems
had not been
reduced.
This backlog primarily affected non-safety related
equipment.
Although none of the above problems
posed
a threat to
the safe operation of the plant, the inspectors
concluded that
a
more aggressive
approach
by the licensee
to address
the backlog
and identify potential
freeze protection deficiencies
could have
prevented
some of the incidents of frozen instrumentation
noted
above.
During the
same cold week in January,
the inspector
reviewed data
sheets for Procedure
OST-1021, Daily Surveillance
Requirements
(DSR).
Per this procedure,
operators
logged various
TS required
operating
parameters,
such
as tank levels
and
room temperatures.
The inspector noticed that for the
DSR dated January
17,
1994, the
"B" ESW electrical
equipment
room temperatures
were between
47-
49'F for each of the four six-hour surveillance intervals.
The
other rooms in the
ESW intake structure
were all indicating above
60'F.
The inspector further noted that the "B"
ESW electrical
equipment
room temperature initially dropped
below 50'F
on
January
15,
and dipped
as low as 38'F
on January
19,
1994.
Although only maximum room temperatures
for the
ESW structure
were
specified in the TS, the
FSAR, Table 9.4.0-1,
indicated
minimum
temperatures
of 51'F for the
ESW intake structures,
specifically
the
pump rooms
and the electrical
equipment
rooms which house
associated
safety-related
HCCs
and air handlers.
In the
discussion
of the design of plant
HVAC systems,
Section 9.4.0 of
the
FSAR stated that, in winter, the air is heated
by the supply
units'lectrical
heating coils or electrical
heating units to
assure
the minimum design
space
temperature
stated
in FSAR Table
9.4.0-1 is maintained.
The discrepancy
between
the statement
in
the
FSAR and the actual
temperatures
logged for the "B"
electrical
equipment
room was discussed
with licensee
personnel.
It was later noticed
by the licensee that the recorded
temperatures
for the "A" and "B" EDG rooms
had also dropped
below
51'F.
On January
19,
1994, licensee
personnel
initiated actions
to evaluate
the intent of the
FSAR statement
and to correct the
low temperature
conditions in the
ESW structure
and the
building.
Immediate actions
included placing air supply fan AH-
86B in service
so that its heating coil could heat the "B"
electrical
equipment
room intake air.
This action brought the
room temperature
to above 51'F before the fan was
removed from
service
due to frozen fan cooling coils which burst
and leaked
water into the fan housing
and the
ESW structure
(see
paragraph
4.a.(3) of this report).
Later,
a portable heater
was placed in
the room to maintain temperatures
above the
FSAR minimum value.
Portable
heaters
were also placed in the
EDG structure
in an
attempt to raise
room temperatures.
During
a tour of the
ESW intake structure
on January
19, the
inspector noted that
a deficiency tag dated January
12,
1994,
had
been
placed
on the permanent
space
heater installed in the "B"
electric equipment
room.
A tour of the "A" and "B" ESW pump rooms
identified several
heaters
which were also inoperable
and
had not
been tagged.
Operators later wrote deficiency tags for the
remaining inoperable
heaters
in both the
EDG rooms
and the
structure.
The inspector noted that administrative
Procedure
AP-301, Adverse
Weather Operations,
had
been in effect for extended
periods over
the previous
two months
when ambient temperatures
were below 35'F.
The procedure
contained guidelines for monitoring, operating
and
maintaining equipment
and instrumentation
during periods of severe
cold weather.
Operator responsibilities
were outlined in
Procedure
AP-301
and included inspecting
equipment often to
minimize the effects of adverse
weather conditions.
Step
5. 1. 1.4.c directed auxiliary operators
to verify heaters
were
in all buildings
and structures.
Nany of the deficient
heaters
in the
ESW intake structure
had not been identified or
corrected until after inspectors
questioned
the cold temperatures
in the "B" electrical
equipment
room.
The failure to implement
Procedure
AP-301 adequately
to verify heaters
were operable
in the
outlying areas is
a violation of the 'requirements
of TS 6.8. I.a.
Violation (400/94-05-01):
Failure to implement procedures
adequately.
Licensee
personnel
stated that they considered
the
FSAR minimum
value of 51'F
(and other minimum values referenced
in Table 9.4.0-
1) to be
a design
standard for the
HVAC systems
in the
structures
and other plant areas.
Licensee
personnel
are
currently developing
an engineering
evaluation to determine
the
minimum temperatures
at which safety-related
equipment in outlying
areas,
such
as the
ESW structure
and the
EDG buildings,
can still
perform their intended safety functions.
Review of Nonconformance
Reports
(71707)
Adverse Condition Feedback
Reports
(ACFR) were reviewed to verify
the following:
TS were complied with, corrective actions
and
generic
items were identified and items were reported
as required
by 10 CFR 50.73.
(1)
ACFR 94-404 documented that
on January
28,
1994,
an operator
discovered that the room temperature
for the Boric Acid
Transfer
Pump
(BATP) valve gallery had dropped to 62 F.
boron injection flow paths
are required to be at
least 65'F by TS.
The operator discovered that the room was
colder because
the door leading to the
RAB hallway had
been
left open following maintenance activities
on the
BATPs.
The operator
immediately closed the door and secured
a
cooling fan to raise the room temperature
above
65 F.
The inspector
reviewed the history of temperature
maintenance
issues
associated
with borated water systems
and
violations documented
in NRC Inspection
Report 50-400/91-24.
Licensee corrective action for the deficiencies identified
in that report included increased
monitoring of the boration
system flowpath temperatures.
As a result of the increased
awareness
of temperature
requirements
for the boration
flowpath, licensee
personnel
noted difficulties in
maintaining the
BATP valve gallery above the minimum
requirement.
Room heaters
could not maintain the required
temperature
when adjacent
area cooling units were in
operation.
Licensee
personnel
generated
a work ticket
(WR
92-AALL1) on January
8,
1992, to fabricate
a plexiglass
door
to this room to prevent cooler outside air from entering.
Two years later,
on February
18,
1994, the inspector noted
that
a plexiglass
cover had still not been fabricated
and
the deficiency tag was still on the door.
Instead licensee
personnel
had installed
a sheet of plastic over the door
cage to prevent air flow.
Licensee
personnel
also
discovered that the area
room heater
in the
BATP valve
gallery had
been inoperable
and under clearance
since August
1993.
10 CFR 50, Appendix B, Criteria XVI, requires that measures
shall
be established
to assure that conditions
adverse
to
quality such
as failures, malfunctions, deficiencies,
deviations,
defective
equipment
and non-conformance,
be
promptly identified and corrected.
The licensee's
failure
to correct deficiencies
associated
with the
BATP valve
gallery door promptly led to the inability to maintain the
room above the
65 degree
F minimum requirement.
This is
contrary to the requirements
Criteria XVI, and is considered
to be
a violation.
Violation (400/94-05-02):
Failure to implement adequate
corrective actions to prevent recurrence of deficiencies.
ACFR 94-615 reported that
on February
18,
1993,
RCS letdown
was inadvertently isolated during
an
RCS filter backflushing
evolution.
This evolution is controlled by two procedures
Chemical
and Volume Control
System,
and
OP-
120.02.39,
Fuel Handling and Reactor Auxiliary Building
Filter Backflush,
and necessitates
coordination
between
Main
Control
Room
(MCR) and radwaste
personnel.
Radwaste
operators
had previously experienced
problems with the
automatic operation of the backflushing
system,
therefore
the local
manual
mode of backflushing the
RC filter was
implemented
per section 8.5 of Procedure
OP-120.02.39.
Procedure
steps
specify that
MCR personnel
open the
RC
filter bypass
valve
and then direct radwaste
operators
to shut the
RC filter inlet and outlet isolation
valves
(1CS-114,
1CS-118).
When the evolution is complete,
radwaste
personnel
inform the main control
room that the
filter is backflushed,
isolated,
and ready to be placed into
service.
When directed
by
MCR personnel,
radwaste
operators
reopen valves
and
so that valve 1CS-112
can
be closed.
Upon completion of the filter backflush
on
February
18,
MCR personnel
closed
1CS-112 prior to valves
and
1CS-118 being opened.
This action isolated the
letdown system
and raised
system pressure
which potentially
challenged
a system relief valve.
The licensee
is presently
evaluating the cause for this event.
Statements
made
by the
operators
involved indicated that
MCR personnel
were
informed that the backflush
was finished.
MCR personnel
assumed that this meant that the filter was also unisolated
and ready to be returned to service.
Licensee
personnel
have experienced
previous problems with
coordinating filter backflush evolutions.
In NRC Inspection
Report 50-400/92-15
the licensee
was issued
a violation
(400/92-15-01) for failing to implement procedure
properly.
This violation occurred
on August 7,
1992, during
an attempt to backflush the seal
water return filter when
the associated
bypass
valve was not opened
as required.
This event also resulted
in a pressure
increase
and
challenge to system relief valves.
In response
to this
event the licensee clarified procedures
OP-120.02.39
and
OP-107 to identify the action required
by the
NCR.
These
actions
were completed
on October
19,
1992.
In addition,
NRC Inspection
Report 50-400/91-27
contained
a non-cited
violation (400/91-27-02) for the failure to
implement
procedure
OP-109 properly,
Boron Recycle System.
This
violation also involved the failure to open the recycle
evaporator
feed filter inlet and outlet valves
when the
filter was returned to service
on December
15,
1991.
Procedures
were clarified in response
to this event.
The
inspectors
reviewed the procedures
involved and found them
to be clear
and concise.
However, the failure of licensee
personnel
to implement procedure
OP-107 properly,
even after
the recurrent
problems
encountered
during this evolution, is
contrary to the requirements
of TS 6.8. l.a and is considered
to be another
example of the violation listed in
paragraph
2.c of this report (400/94-05-01).
Followup of Onsite Events
(93702)
At 12:30 p.m.
on February
17,
1994, the licensee
declared
an
unusual
event due to a plant computer
(ERFIS) failure.
A licensee
system engineer notified the
MCR that his display of reactor
power
had not changed
during the previous
two days.
At 9:55 a.m. it was
determined that the
SPDS display in the
NCR was not updating data
as required.
The licensee's initial investigation determined that
this condition
had existed since ll:00 a.m.
on February
15.
Although the computer failure had
been corrected at 9:55 a.m.
by
restarting the
SPDS program,
an unusual
event
was declared
and
terminated
at 12:30 p.m.
when the investigation results
revealed
that the
SPDS function had
been inoperable for greater
than four
hours.
The inspectors
reviewed the licensee's
emergency
plan
and
determined that the event
was properly classified
and the
emergency
plan was properly implemented.
The licensee
has experienced
previous
problems with ERFIS.
On
February 6,
1993,
an unusual
event
was declared
upon the complete
failure of ERFIS.
LER 92-02 reported the failure to properly log
containment
sump level
and calculate leakrate during an
ERFIS
failure which was unnoticed
by operators.
" The l,icensee's
corrective action for this event included procedure revisions to
provide adequate
details to ensure
proper operation of TS related
functions performed
by ERFIS.
Again in
NRC Inspection
Report
50-400/93-21,
the licensee's
action in response
to the
LER were
considered
to be weak as
a degraded
condition of ERFIS to
calculate
AFD went undetected
by operators.
In response
to this
I
event,
licensee
management
directed that
an event review team
be
formed to address
the computer problems.
The corrective action
proposed
by the event review team
and accomplished
by the licensee
included revising guidance to determine that
AFD indications
are
updating properly prior to declaring the function operable,
increasing
the numeric
AFD display by one additional digit
(thousandths),
and additional training to operators
and computer
maintenance
personnel.
Since the February
17,
1994,
event involved the failure of the
SPDS function of ERFIS
and
was not
a TS related function,
operators
were not periodically checking these
parameters
to
ensure
the data
was updating.
Operators
instead
simply monitored
the computer clock display which was updating correctly for this
event.
The
SPDS function was required
by the emergency
plan but
not included in previous corrective actions.
The failure to take adequate
corrective action to provide
operators with sufficient guidance to determine
the proper
operation of ERFIS is contrary to the requirements
of 10 CFR 50
Appendix B, Criterion XVI and is considered
to be another
example
of the violation discussed
in paragraph 2.d(l) of this report
(400/94-05-02).
3.
Maintenance
~
~a.
Maintenance
Observation
(62703)
The inspector
observed
and reviewed maintenance activities to
verify that correct equipment clearances
were in effect; work
requests
and fire prevention
work permits were issued,
and
TS
requirements
were being followed.
Maintenance
was observed
and
work packages
were reviewed for the following maintenance
activities:
Reset impeller clearance for "A" ESW screen
wash
pump in
accordance
with Procedure
CM-M0195, Emergency Service
Water
Screen
Wash
Pump Disassembly,
Inspection
and Re-assembly.
Inspection
and cleaning of bus
lA1 in accordance
with
Procedure
PM-E0015,
480 Volt and 6.9
KV Transformer
Electrical
and Preventive
Maintenance
Checks.
Repair sodium hydroxide leakage
from level transmitter
L-
7166.
Replace
B phase
overload relay for cooling fan AH-5 (lA-SA)
breaker.
Plug leaking cooling coils for cooling fan AH-86 (1B-SB) in
accordance
with PCR-7157,
Plugging of AH-86B Cooling Coil
Tubes.
10
~
Troubleshoot/Replace
closing coil
on supply breaker
from emergency
bus
IA-SA to emergency
bus
1A1.
In general,
the performance of work was satisfactory with proper
documentation
of removed
components
and independent verification
of the reinstallation.
(2)
(3)
The inspectors
attended
several
Plan" of the
Day meetings
held
among the shift supervisors,
work control,
and
maintenance
management
personnel.
The licensee
described
the purpose
and conduct of this meeting in procedure
PLP-710,
Work Hanagement
Process.
These meetings
are held
each
weekday at 7: 15 a.m.
Emergent
items
and items
requiring rescheduling
are discussed
at these
meetings.
Operating
personnel
review the schedule
to develop the
necessary
equipment
clearances
to perform the work.
The
inspector considered this meeting
and process
to be
beneficial
as it enhanced
the operator turnover process
to
include craft related
work planned during the upcoming
shift.
In addition, the status of lit main control
board
was discussed
with necessary
action to remove
the alarming condition.
As
a followup to the comments
contained
in NRC Inspection
Report 50-400/93-14,
the inspectors
reviewed the current
backlog of uncompleted
maintenance
work tickets.
The
present
backlog of non-outage
work tickets is approximately
1100.
Licensee
management
plans to continue to reduce this
number to an established
goal of 600.
This equates
to
approximately
seven
weeks of work.
The inspector
noted that
the average
age of work tickets
has
been
reduced to 216 days
from a high of approximately
310 days.
The licensee
attributed this reduction to the
new work control center
which has concentrated
on scheduling
the older tickets for
work.
The inspector considered this aspect of work
planning/scheduling
to be effective.
The inspectors
reviewed
an
NAD assessment
dated
February ll,
1994,
performed in the maintenance
functional area.
This
assessment
was requested
by plant management
to determine
the effectiveness
of the maintenance
program.
The
inspectors
considered this pro-active
assessment
to be good
and the assessment
findings indicated that
a thorough look
had
been
performed of the maintenance
organization.
Issues
identified by
NAD included poor initial planning of work
packages,
poor implementation of work package directions,
and poor maintenance
practices.
In addition, significant
problems
were identified with maintaining the data
base for
the
PH program which included incorrect classification
oF
safety-related
PH's, incorrect classification of
environmentally qualified
PH components,
and inappropriate
11
extension of overdue
PH's.
The inspectors
considered this
assessment
to be effective.
Previous
NAD assessments
were also reviewed.
In June
1993
NAD identified deficiencies
in maintenance
program
procedures
which defined independent verification
requirements.
An assessment
of the
new work management
process
was performed in December
1993.
A strength
was
identified in the implementation of safety
system train
outages
as well as deficiencies
noted in the
new work
control/scheduling
process.
The inspectors
concluded
from
these
assessments
that this effort was effective in
identifying areas
in need of improvement.
While reviewing Procedure
PLP-710,
the inspectors
noted that
the licensee
had established
new criteria for establishing
work priorities.
Attachment
5 to this procedure lists the
five new priority classifications.
Priority
E work
was'efined
as
emergency
work that would have
an immediate
and
direct impact
on the health
and safety of the general
public
or work to prevent the deterioration of plant conditions to
unsafe or unstable levels.
This type of work could
be
authorized to begin prior to planning being completed
and
documented after the fact.
The procedure listed three
examples of emergency
type of work:
I)
Technical Specification 3.0.3 entry.
2)
Significant acid or caustic
system leaks that directly
impact personnel
safety or the environment
and cannot
be isolated.
3)
Large condenser
vacuum leak that results in a
continuous
load reduction to prevent
a unit trip.
The inspector disagreed
with the statement
that emergency
work could be authorized during all
TS 3.0.3 entries.
In
NRC Inspection
Report 50-400/93-08 the licensee
was issued
a
deviation
(400/93-08-03) for performing non-emergency
safety-related
maintenance
without preplanning.
The
licensee
responded
to this deviation by revising the work
control procedure to specify that emergency
work would only
be authorized for those conditions to protect the health
nad
safety of the public, to protect equipment or personnel,
or
to prevent the deterioration of plant conditions to unsafe
or unstable levels.
The inspectors
closed out this
deviation
based
on these corrective actions
being
implemented.
The licensee
has entered
on several
occasions
in
the past.
Some of these
occasions
were documented
in
LER
93-05, safety-related
room cooling units inoperable,
LER
12
93-02, failure to stroke test charging
system valves,
and
LER 92-12, relay failure exceeded
out of service time.
Since
each
one of these
TS 3.0.3 entries did not jeopardize
the ability to safety
shutdown the plant, the inspector
concluded that not all
TS 3.0.3 entries
should
be classified
as
emergency situations necessitating
alleviation of work
planning requirements.
The inspector discussed
this
condition with licensee
management
personnel
who stated that
procedure clarifications would be made.
No violations or deviations
were identified.
b.
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
'ollowed.
The following tests
were observed
and/or data reviewed:
~
OST-1021
Daily Surveillance
Requirements
Daily Interval
~
OST-1026
Leakage
Evaluation Daily
Interval
~
OST-1214
Emergency Service Water System Operability Train
A quarterly Interval.
~
OST-1813
Remote
Shutdown
System Operability 18 Month
Interval
~
Containment
Spray Additive Tank Level
Loop (L-
7166) Calibration.
~
Loop Cold Leg Temperature
Instrument Operational
Test.
The performance of these
procedures
was found to be satisfactory
with proper
use of calibrated test equipment,
necessary
communications
established,
notification/authorization of control
room personnel,
and knowledgeable
personnel
having performed the
tasks.
No violations or deviations
were observed.
Engineering
Design
Changes
and Modifications (37828)
Plant
Change
Requests
(PCR) involving the 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
13
approved
acceptance
criteria or deviations
were resolved
in an
acceptable
manner,
and that appropriate
drawings
and facility
procedures
were revised
as necessary.
In addition,
documenting engineering
evaluations
were also reviewed.
The
following modifications and/or testing in progress
were observed:
~
PCR-6526,
Frequently Cycled
LK Breakers
PCR-7144,
Wires Are Swollen
~
PCR-7157,
Plugging of AH-86B Cooling Coil Tubes
As noted in
NRC Inspection
Report 50-400/93-25,
on
Jan'uary
8,
1994, the
B RAB Emergency
Exhaust
Fan inlet valve
(AV-B4) failed to operate satisfactory after the
implementation of modification PCR-7144.
The inspectors
reviewed the modification and implementing work packages
(WR
94-AAIE1).
The repair replaced
swollen wires found inside
the motor operated
valve in accordance
with procedure
EH-
003, Termination
and Testing of Wire and Cable.
Attachment
1 to this procedure
provides
a checklist of the important
attributes for conducting the wire terminations
and provides
for signature
blocks to document
accomplishment.
This
attachment
also specified that
a guality Verification (gV)
signature
was required to verify that the cable conductor
identification was correct.
The licensee's
investigation of
the valve operating
problem revealed that two of the seven
cables
involved were terminated to the incorrect terminal
due to incorrect labeling of the cable conductors.
The inspector discussed
this matter with craft and
gV
personnel.
Craft personnel
believed that they had
terminated
the cable conductors correctly.
The
gV
individual involved admitted that
he had only verified that
three of the seven cable conductors
were labeled correctly
and that based
on this
he did not consider verification of
the other four necessary
to meet this requirement.
The
gV
inspector
had nevertheless
signed the attachment
on January
7,
1994,
documenting satisfactory labeling of the cable
conductors.
The two cable conductors
which were incorrectly
terminated
had not been verified by gV.
The failure to verify correct labeling of the cable
conductors
properly is contrary to the requirements
of
Procedure
Bl-003 and is considered
to be
a violation.
Although this matter
was identified by licensee
personnel
during the post modification testing, it is being cited due
to the importance of the breakdown of the independent
verification process.
This procedural violation is
considered
to be another
example of the violation noted in
paragraph
2.c. of this report (400/94-05-01).
In accordance
with modification PCR-6526,
the licensee
installed
a new breaker for the "A" station air compressor
in non-safety
bus
1A1 to replace the old LK-16 breaker.
Licensee
personnel
decided to install
a non-safety
breaker
before
any subsequent
safety-related
breaker modifications
to identify potential
problem areas for correction prior to
the safety-related
bus maintenance
presently
scheduled for
the next refueling outage.
Licensee
personnel
experienced
physical
problems with the
new Siemans
breaker
and cradle
assembly
when inserted into
the breaker cubicle.
Minor fit-up problems
were noted with
fuse/terminal
block sizes.
In addition, licensee
personnel
found that the
new breaker
was extremely hard to rack in.
Physical alterations
were
made to install the breaker
successfully.
Two wiring deficiencies
were also identified
by licensee
personnel
during the installation process.
The
licensee
decided that
a wire to wire check would be
beneficial for future installations.
Deficiencies
were also
identified with the post-modification testing procedure
and
PH procedure.
The licensee
plans to revise these
procedures
accordingly.
The licensee
held
a post-modification critique meeting to
discuss
these
problems
and corrective action.
A video of
the installation process
was
made
and viewed during this
meeting.
During the restoration of bus lAl, the feeder breaker
from
bus
1A-SA failed to properly close electrically.
Licensee
personnel
replaced
the closing coil on the feeder breaker
which subsequently
operated satisfactorily.
This breaker
will also
be replaced
during the refueling outage
breaker
modification.
The inspectors
considered
the licensee's
preliminary efforts for the outage
breaker
replacement
work
to be beneficial.
The inspectors
reviewed maintenance activities to replace
cooling coils on air handler
AH-86 (1B-SB) in the
ESW intake
structure.
The work was
done in accordance
with PCR-7157.
The inspectors
reviewed
PCR-7157,
Revision
0 and Revision
1
to verify that appropriate technical
and safety reviews were
documented.
A safety review package
was completed for each
revision of the
PCR.
This activity was required
by
Procedure
AP-011, Safety Reviews,
and included
an Unreviewed
Safety guestion Determination
as mandated
by 10 CFR 50.59.
During a review of the safety
package for PCR-7157,
Revision 0,
(completed
and approved
January
20,
1994) the
inspector noted that the
same generic written basis
appeared
in the answers to four different and distinct questions
related to the malfunction of equipment
and the probability
of accidents
as evaluated
in the Safety Analysis Report.
15
Specifically, the words "the leaking coils are
removed
from
service via a proven method"
were documented
as the only
written basis for answering
"no" to each
one of the
following questions:
guestion I:
May the proposed activity increase
the
probability of occurrence of an accident
evaluated
previously in the Safety Analysis Report?
guestion
3:
Hay the proposed activity increase
the
probability of occurrence of a malfunction of equipment
important to safety evaluated
previously in the Safety
Analysis Report?
guestion
5:
Hay the proposed activity create
the
possibility of an accident of a different type than
any
evaluated
previously in the Safety Analysis Report?
guestion
6:
Hay the proposed activity create
the
possibility of a malfunction of equipment
important to
safety of a different type than
any evaluated
previously in
the Safety Analysis Report?
The answers
to the questions
were simplistic and lacking in
depth to address
the specifics of each question.
Section
3.2 of procedure
AP-Oll stated that qualified safety
reviewers shall perform safety reviews in accordance
with
the program manual
(Attachment 6).
Attachment 6,
Rev. 3,
Section 8.2,
Documentation,
stated
in part that although the
answers
in Part
IV (Unreviewed Safety guestion
Determina-
tion) are simply "yes" or "no", there must
be
an
accompanying justification.
Making a simple statement of
conclusion is not sufficient.
The inspector noted,
however,
that the accompanying
Safety Analysis for the plugged
cooling coils did address
the overall safety concern.
The diminished ability of the air handler to cool the intake
structure
was minimized by the current
season
and the fact
that the coils would be permanently
replaced during
RFO-5
beginning in March 1994.
In addition,
Rev. I to the
PCR had-
been
completed
and approved
one day later
and effectively
superseded
Rev.
0 to the
PCR.
Rev. I contained
a more
detailed safety anslysis,
a better documented
technical
review,
and more detailed
answers
to all seven of the
questions
related to the unreviewed safety question
determination.
The inspectors
noted that Rev. I had
been
completed
by the license
before the inspector identified the
deficiency in Rev.
0.
While the accompanying
safety analysis for Revision
0 was
considered
to be adequate
to address
potential safety
concerns,
the inspectors
considered
the licensee's
answers
16
to the questions for the unreviewed safety question
determination
in Revision
0 to be weak.
NRC Inspection
Report 50-400/93-07
documented
a similar example where two
separate
and distinct modifications contained similar
wording as the basis for determining that
no unreviewed
safety question existed.
However,
as with the previous
example,
the inspectors
agreed with the safety reviewer's
conclusion that
an unreviewed safety question did not exist
for PCR-7157.
The inspector also considered
the safety
review for PCR-7157,
revision I to be good.
ll
System Engineering
On January
22,
1994, plant power was reduced to
approximately
84 percent to perform main turbine valve
testing.
The inspectors
were previously informed that the
reactor engineering
group
had recently obtained
a new
computer software
system
(POWERTRAX) to anticipate/calculate
core parameters
in three dimensions to assist
the operators
during the downpower.
Appropriate recommendations
were
suggested
to the operating shift on rate of power change,
rod bank insertion values,
and boration/dilution volume
estimates.
The inspectors
noted that
AFD predictions
and
actual
values closely agreed
and little problems
were noted
during the downpower evolution.
The inspectors
concluded
that technical
support for this plant evolution was good.
(2)
The inspector discussed
a recent industry event involving
the failure of an NSIV to operate
properly with the
responsible
system engineer.
During the industry event,
a
34 inch air-to-open/spring-to-close
globe valve manufactured
by Atwood and Norrill failed to close following receipt of a
main steam isolation signal
which resulted in steaming
a
steam generator dry.
The cause for this condition was
attributed to valve reassembly
and alignment following
maintenance
at
a temperature
other than the valve's
normal
operating temperature.
The system engineer
informed the inspector that the plant
system design utilizes
a similar
Y type
32-inch
globe valve manufactured
by Rockwell for the main steam
isolation function.
These
valves
are likewise air-to-
open/spring-to-close
operated.
To aid in
disassembly/reassembly,
the valves
have alignment pins
and
are marked to ensure satisfactory
realignment following
maintenance.
In addition, the valves are subsequently
stroke tested while the plant is in the hot standby
(Node 3)
condition following maintenance.
No violations or deviations
were identified.
17
Plant Support
a ~
b.
I
Plant Housekeeping
Conditions
(71707)
- 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.
As noted in paragraph
2.b the general
house-
keeping in the steam tunnel
was considered
to be poor.
Also
during plant tours,
the inspectors
noted poor housekeeping
in the
boric acid transfer
pump room (loose insulation canning,
cotton
gloves discarded
on floor) and in the
286 foot elevation of the
tie-wraps
and tape).
In addition,
the inspectors
noted the general
poor cleanliness
condition of the
NCB.
Dirt and dust
was observed
which indicated that poor
housekeeping
standards
were being maintained
in this highly
visible area of the plant.
The inspector
concluded that plant
management
needed to reenforce
high housekeeping
standards.
Radiological Protection
Program
(71707)
- 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.
On January
22,
1994, the licensee
discovered
an unlocked hatch
on
a cask
used to store spent demineralizer filters.
The cask
was
one of two located in the
211 foot elevation of the
WPB and
was
posted
as
(LHRA).
The hatch,
which
is located at the top of the cask
and is accessible
only with the
aid of a ladder,
was discovered
by technicians
performing routine
rounds approximately fifteen hours after the last
known entry was
made.
The hatch covers
a 24-inch diameter
opening into which technicians
routinely deposit highly radioactive
spent filters. It is usually
secured
by a padlock which engages
a small U-hook on the cask.
The lock was found to be locked, but not engaged
in the U-hook to
prevent the door from opening.
The inspectors
discussed
the
incident with licensee
personnel
who indicated that the unlocked
cask
was the result of personnel
error and that the involved
technician thought the lock was
engaged
when the key was removed.
Upon discovering the unlocked cask,
technicians
locked it and
performed
a radiological
survey of the area.
Surveys indicated
radiation levels of 800 mR/hr at the plane of the hatch'with it
opened
and 2.5 R/hr on contact with the filters which were stored
inside.
The top of the filters inside the cask were at
a level of
approximately
30 inches
below the plane of the hatch.
The
inspector toured the area
and observed that although the cask
opening
was big enough to allow a person to climb inside,
no
personnel
would routinely access
this hatch for reasons
other than
to drop filters inside.
Licensee
personnel
also indicated that
there
were
no unusually high exposures
recorded
on the day the
0
18
cask
was unlocked.
The inspector
concluded that
no personnel
over-exposure
occurred
as
a result of this incident.
The
inspector
also discussed
the potential for personal
with NRC Regional Specialists
who concluded that,
given the
location
and configuration of the filter cask,
the potential for
excessive
exposure
was minimal.
The licensee's
administrative
Procedure
AP-504, Administrative
Controls for Locked, Restricted
and Very High Radiation Areas,
specifies
in Section
5. 1 that
LHRAs shall
remain locked at all
times unless
under the direct control of an individual controlling
access
to the area.
The licensee's
actions regarding the unlocked
filter cask are considered
to be
a violation of the above
requirements.
This violation will not be subject to enforcement
action
because
the licensee's
efforts in identifying and
correcting the violation meet the criteria specified in Section
VII.B of the Enforcement Policy.
Non-cited Violation (400/94-05-03):
Failure to maintain
a
locked.
The licensee's
corrective actions for the above violation included
counseling
the involved individual
and other health physics
technicians,
and revising AP-504 to require
an independent
verification of LHRAs.
The above corrective actions
were
presented
before the
PNSC
on February
23,
1994.
Security Control
(71707)
- 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
(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.
(1)
During this inspection period the licensee
moved the
perimeter fence
such that the administration building was
located outside the protected
area.
The inspectors
walked
down the
new fence
and observed
portions of the testing
performed
on the modified intrusion detection
system,
CCTV,
and lighting systems.
Performance of the testing
was
observed
from the central
alarm station
and in the field.
To alleviate distractions,
security force personnel
routed
the majority of communications to the secondary
alarm
station during performance of the testing.
The inspector
considered
the conduct of the testing to be good with
satisfactory results.
19
During the walkdown of the
new perimeter fence,
on
February 8,
1994, the inspector
noted
two areas
along the
fence where gaps existed
between
the fence material
and
ground.
The inspector
measured
these
gaps
and found them to
be approximately six inches in depth.
The inspector
discussed this finding with security personnel
and
was
informed that the fence modification had not yet been
accepted
as complete.
The inspector
was informed that
a gap
size of six inches
was the maximum allowed
and that barbed
wire was to be installed at the bottom of the fence to
prevent
access
through the gap areas.
Appropriate action
was
implemented to correct the fence deficiencies.
The
licensee
continued the use of compensatory
guard posts until
the deficiencies
were corrected.
(2)
The inspector also discussed
the potential
change to the
security plan required
by this modification with licensee
personnel.
The inspector
was informed that
a change
was to
be submitted within 60 days in accordance
with
On February
17,
1994, while observing the reinspection
effort for the
new fuel assemblies,
the inspector
noticed
two vendor representatives
were standing
nearby with
visitors badges.
The inspector
asked the two individuals
who and where their escort
was.
The visitors indicated that
the escort
was involved in the fuel inspection activities
which were taking place
on the other side of the
new fuel
pool
some fifty to sixty feet away.
The inspector
noted
that although the visitors were visible to their escort,
the
escort
was clearly involved in the inspection activities
and
not in full observation of the visitors.
The inspector
directed the visitors to proceed to where their escort
was
located.
The inspector later discussed
this observation
with the security manager.
Although the inspector did not
,consider this incident to be in violation of security
requirements,
the control of visitors in this case
could
be
strengthened.
The inspector reviewed the Security Plan
and
verified that
no requirements
regarding the escorting of
visitors were violated.
d.
Fire Protection
(71707)
- 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.
Except
as noted
above,
the inspectors
found plant housekeeping
and
material condition of components
to be satisfactory.
The licensee's
adherence
to radiological controls, security controls, fire protection
requirements,
and
TS requirements
in these
areas
was satisfactory.
20
6.
Preparations
for Refueling
(60705)
The inspectors
reviewed several
aspects
of the licensees
activities
associated
with the upcoming refueling outage
(RFO-5) which was
scheduled
to begin Harch
19,
1994.
This inspection
was performed to
ascertain
the adequacy of the licensee's
procedures for the conduct of
refueling operations,
and to determine
the adequacy of the licensee's
administrative requirements
and implementation of controls for refueling
operations
and plant conditions during refueling.
The inspection
was
accomplished
by reviewing procedures,
observing
new fuel handling
activities,
and interviewing various
key licensee
and contractor
personnel.
In addition, the inspectors
reviewed the licensee's
outage
schedules
and the licensee's
independent
pre-outage
shutdown risk
assessment,
dated January
21,
1994.
a.
New Fuel Receipt
The inspectors
reviewed procedures
and observed activities
associated
with receiving,
inspecting,
and storing
new fuel
assemblies.
Procedures
included
FHP-003,
Unpacking
and Handling
of New Fuel Assemblies
and
New Fuel Shipping;
FHP-004,
New fuel
Handling Tool Operation;
and
FHP-106,
New Fuel Receipt Inspection.
The licensee
received
52 new fuel assemblies
from Siemens
Power
Corporation during January
and February,
1994.
The inspector
observed that licensee
personnel
were moving the
new fuel in
accordance
with Procedure
FHP-003.
However during the first day
of inspections,
the inspector
noted several
unapproved
pencil
changes written into the working copy of the procedure.
The
pencil
changes
were primarily due to technical
terminology
differences
between
the licensee's
current
and previous fuel
vendors
and did not alter the scope of the fuel movement
activities.
The type of procedure
problems identified by the
pencil
changes
should
have
been identified,
and appropriate
procedure clarifications implemented,
prior to the first day of
fuel movement.
After the inspector identified this matter to
licensee
personnel,
a temporary
change to Procedure
FHP-003
was
subsequently
initiated and
an advance
change
was implemented
on
February
16,
1994.
The inspector reviewed training certifications for six fuel
inspectors
and observed
fuel inspection activities done at the
Harris site in accordance
with Procedure
FHP-006.
The inspector
observed that the licensee
was especially sensitive to foreign
material
exclusion requirements.
The inspector also observed that
qualified fuel inspectors,
as well as
a quality control
representative
from the fuel vendor,
were present to oversee
fuel
assembly
inspections.
The fuel inspectors
did not restrict their
focus to those inspection objectives called
upon in Procedure
FHP-006.
This resulted
in the identification of discrepancies
in
the fuel assemblies
which resulted
in three defective
assemblies
being returned to the vendor.
Licensee
inspection findings
included the following:
P
21
~
Approximately five fuel bundles
were found with bent tabs
on
grid spacers.
In one case,
the tabs
were found bent
away
from the center
instrument thimble and touching two adjacent
fuel rodlets.
Some of the bent tabs
were able to be field
corrected.
Three assemblies
were sent
back to the vendor
for reworking.
~
A locking lug was found in the non-locked position
on
an
upper tie plate of one of the assemblies.
The locking lug
was immediately placed in the locked position
and
an
ACFR
was generated.
~
A washer
(approximately 3/8 inches outside diameter)
was
found lying on the lower tie plate of an assembly.
Following this discovery,
licensee
personnel
conducted
reinspections
of all 30 of the assemblies
that
had
been
previously inspected
in order to find the mating screw.
The
washer
and screw were believed to have
been dismantled
from
a lifting tool back at the vendor's manufacturing facility.
The missing screw was not found during the subsequent
inspections.
~
A small metal tab,
about the size of a fingernail, broke off
of a feeler gauge
used to measure
separation
between fuel
rodlets.
The measuring
tool
had
been supplied to the
licensee
by the vendor.
The tab,
which had
been spot welded
to the instrument,
was later retrieved
from a fuel assembly
that
had
been previously inspected.
The licensee's
efforts
in identifying the broken tool
and finding the missing piece
was particularly good.
~
During packaging at the manufacturer's facility, each
assembly
had
been
placed in a polyethylene
sleeve prior to
being loaded into a steel
container for shipping.
During
onsite inspections,
some of the steel
containers
were found
to have dust
and dirt located inside.
The fuel assemblies
were protected
from this foreign material
by their
polyethylene
covers.
However,
one of the polyethylene
was found with moisture inside.
The moisture
was
attributed to the washing/drying process
back at the
manufacturing point and
was determined
not to be
a threat to
the future performance of the fuel assembly.
In addition to the above,
licensee
personnel
also inspected
each
new assembly for rod perpendicularity,
rod integrity, rod
separation,
and potential
bowing of rods.
ACFRs were generated
for all of the noted discrepancies
and were in the process of
being resolved
by the licensee's
corporate office at the close of
this inspection period.
Overall, the licensee's
fuel receipt
inspection activities were very thorough in identifying and
addressing
the deficiencies
noted
above.
22
Since the above fuel receipt inspections
indicated
a potential
vendor quality control problem,
the resident
inspectors
interviewed several
key vendor
and licensee
personnel
who had
been
involved in the licensee's
corporate oversight of the fuel
fabrication process.
The licensee's
corporate oversight
program
had
been
implemented
as
a result of fabrication problems
identified previously for the Robinson plant.
The vendor
representative
acknowledged that corrective actions
had only been
implemented related to the design
and fabrication of the
assemblies,
and for the exclusion of foreign material
at the fuel
services
side of the vendor's operation.
Foreign material
exclusion
had not been rigorously addressed
from a manufacturing
perspective,
which could have contributed to the washer intrusion
problem.
Vendor representatives
stated that they were in the
process
of developing corrective actions to address
the licensee's
findings.
The resident
inspectors
reviewed licensee
inspection
and trip
reports
documenting the results of the corporate oversight efforts
conducted prior to the fuel being shipped to Harris.
The
inspectors
noted that characteristic's
for some of the findings
noted
above
(bent tabs,
unlocked locking lug) were documented
in
the reports
as having
been inspected.
No deficiencies
were
identified.
However, licensee
personnel
indicated that the
inspection effort was not
a
100 percent effort in that, while
portions of the fabrication process
had
been
inspected for all of
the assemblies,
only a few assemblies
were completely inspected
during the entire manufacturing
process.
Administrative Controls for Refueling Operations
The inspector reviewed the licensee's
administrative controls for
refueling operations
as established
in Procedure
PLP-700,
Outage
Nanagement.
This procedure
defined lines of supervision within
the outage organization
and listed responsibilities for all key
personnel
including the outage
manager, shift outage
managers,
and
work activity coordinators.
The inspector noted that key
positions
had already
been
appointed
and,
through interviews,
concluded that the incumbents
were cognizant of their outage
responsibilities.
The inspector also interviewed
NAD personnel
to determine
what
gA/gC activities would be completed during the upcoming outage.
Licensee
personnel
indicated that both
an outage
assessment
and
a
vendor assessment
would be performed during RFO-5.
The vendor
assessment
would consist of daily surveillance
observations
from
gV personnel
in the
NAD organization.
The surveillances
would be
performed
by approximately fifteen gV inspectors for several
of
the major outage activities in which contractor personnel
would be
primarily involved.
These activities include steam generator
eddy
current testing,
LK-16 breaker replacement,
RTD bypass
removal,
pipe replacement,
and refueling.
The
23
inspector reviewed the surveillance
plan for the
RTD bypass
removal job and noted that the other plans
were currently under
development
at the close of this inspection period.
As required
by Procedure
PLP-700,
Step 5.2.2.2.7,
the licensee
completed
a pre-outage risk assessment,
dated
January
21,
1994.
The assessment
was performed using
PG0-060,
Outage
Risk Hanagement
Policy and Principles
and
PLP-700,
Attachment ll, Outage Risk
Management
Scheduling
and Assessment
Guidelines.
No mid-loop or
reduced
inventory conditions with fuel in the vessel
are planned
for RFO-5.
However, the licensee's
risk assessment
did identify
five issues
and several
recommendations
concerning the outage
schedule
and related
procedures.
The issues'ncluded
the lack of
a comprehensive
plan for containment
closure prior to core
boiling, the untimely scheduling of tasks that affect
RCS makeup
capability while fuel is in the reactor vessel,
procedure
conflicts,
and personnel
training issues.
The issues
were
required to be addressed
prior to
RFO 5.
The risk assessment
also verified the availability and control
over key plant safety
and support
systems
throughout the outage.
For example,
at least
one source of offsite electrical
power and
one
EDG were verified to be available
by schedule
throughout the
5 schedule.
Two
RHR trains were verified by the licensee's
assessment
to be available while fuel
was in the reactor vessel
with the upper internals installed.
The assessment
also verified
that the
ESW and
CCW systems
were available to support
operability requirements
per, TS 3.9.8.2.
The risk assessment
also verified that procedural
requirements for
LTOP operability and other
RCS pressure
control provisions were in
place.
Containment integrity was verified to be in place for
operating
modes I through 4.
The assessment
also verified that
procedural
requirements
existed for communications
between the
control
room and personnel
on the refueling floor.
The inspectors
will independently verify selected
assessment
attributes during
future routine inspection activities.
The licensee's
pre-outage risk assessment
was thorough
and for the
areas
reviewed
above,
the licensee's
administrative controls were
adequate
for establishing
control of plant conditions during
RF0-5.
Review of LERs (92700)
(Open)
LER 93-04:
This
LER reported that the required surveillance
testing interval for the control
room
HVAC system
had
been
exceeded
on
four occasions.
This matter
was previously discussed
in NRC Inspection
Report 50-400/93-10.
The licensee
has completed real-time training on
this event for operators
and has revised the inservice testing
program
to enhance
the review process.
In addition
PCR-7014,
Correct
EBASCO
Valve and
Damper Nomenclature
on Control
Room Switches,
has
been
initiated to correct the dual labeling systems
presently
employed for
this system.
The
LER will remain
open pending completion of the
PCR.
Licensee Action on Previously Identified Inspection
Findings
(92702
&
92701),
(Closed)
Inspector
Followup Item 400/92-08-01:
Follow the
licensee's
activities to improve the work scheduling
system.
The inspectors
reviewed
a system outage for the
TDAFM pump which
was planned
and scheduled
January
12,
1994.
This outage
was
completed successfully
and resulted
in many
PHs
and corrective
maintenance activities being accomplished
in a relatively short
time frame.
The coordination of these activities minimized
equipment out of service time for these
components.
The
inspectors
considered
the reduction in safety-related
equipment
unavailability time to be beneficial to the safe operation of the
plant.
The inspectors
also noted that work was scheduled
on the
emergency
exhaust
system
on two separate
occasions
within a two
week period,
however.
The
RAB emergency
exhaust
fan (E-6B) was
removed
from service
on January
4,
1994, for preventive
maintenance
on the fan's inlet and exhaust
The system
was returned to service
and tested
on January
8.
In the following
week,
on January
13, the fan was again
removed from service for
preventive maintenance
on another
system
The fan was
again retested
and returned to service
on January
14.
Since both
scheduled activities required entering
an equipment
LCO, the
inspector considered
the scheduling of the activities to be
deficient
as they resulted in redundant
equipment testing
and
unnecessary
equipment out of service time.
The licensee
has experienced
previous
problems with scheduling
HVAC type of work.
As discussed
in NRC Inspection
Report
50-400/93-21,
the scheduling of control
room
HVAC maintenance
was
deficient.
The inspector discussed
the corrective action taken
for the previous
problem with licensee
work control personnel
to
determine if additional action
was required to properly schedule
these activities.
The inspector
was informed that the previous
action properly identified the work but personnel
error resulted
in the poor scheduling of the
RAB ventilation system work.
Again in this instance
no TS equipment out of service times were
exceeded
by the licensee.
Although the inspectors
considered
the
new scheduling/work control
system to be satisfactory with the
planning concept of system
outages
to be
a strength,
the
coordination of HVAC system outages
was considered
to be weak.
25
b.
(Closed)
Inspector
Followup Item 400/93-08-05:
Follow the
licensee's
activities to increase
ESCWS reliability.
Upon further review of PCR-6493,
ESCWS Chiller Low
Flow/Temperature. Trip Alarm, by the
PNSC, licensee
management
decided to cancel
the
PCR.
This decision
was
based
on the
reliable history of operation of the chillers since July 1992.
The inspector considered
the licensee's
action for this matter to
be satisfactory.
c.
(Closed)
Unresolved
Item 400/93-21-01:
Testing of control
circuits required for safe
shutdown.
The inspector reviewed analysis
E-5523, revision 1,
Instrumentation,
Control
and Transfer Switches for Components
Credited in the Event of a Fire Requiring Control
Room Evacuation,
which the licensee initiated to clearly state
which components
were required to perform the functions necessary
to achieve
safe
shutdown.
The inspector determined that procedure
OST-1813,
Remote
Shutdown
System Operability
18 Honth Interval,
was properly
implementing the requirements
of TS 4.3.3.5.2.
The licensee
has
incorporated this analysis
by reference
in the safe
shutdown
analysis.
The licensee
had corrected
previous
comments
on inaccurate
references
to non-existent
tables
and
an inaccurate
table of
contents for the safe
shutdown analysis.
However, the inspector
noted that even with the
new reference to analysis
E-5523 the safe
shutdown analysis still contained
no clear statement
of the "B"
train components fulfillingthe functions specified
by TS 4.3.3.5.2.
In addition, the inspector
found two component
numbers
in analysis
E-5523 which were incorrect.
Although the inspector
considered
the licensee's
action to be sufficient to close this
item, the safe
shutdown analysis
could be further clarified and
improved.
Exit Interview (30703)
The inspectors
met with licensee
representatives
(denoted
in paragraph
1) at the conclusion of the inspection
on February
22,
1994.
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 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.
No dissenting
comments
from the
licensee
were received.
26
Item Number
Descri tion and Reference
400/94-05-01
400/94-05-02
400/94-05-03
Violation:
Failure to implement procedures
properly,
paragraphs
2.c, 2.d(2),
and 4.a(l).
Violation:
Failure to implement corrective
action to preclude recurrence,
paragraphs
2.d(1)
and 2.e.
Non-Cited Violation:
Failure to control
a
paragraph
5.b.
ACFR
AFD
BATP
CFR
CSIP
DSR
ESCWS
FASR
LCO
LER
MCB
NAD
NRC
PNSC
QA/QC
QV
and Initialisms
Adverse Condition Feedback
Report
Axial Flux Difference
Boric Acid Transfer
Pump
Closed Circuit Television
Component Cooling Water
Code of Federal
Regulations
Charging Safety Injection
Pump
Daily Surveilance
Requirement
Emergency Diesel
Generator
Essential
Services Chilled Water System
Emergency Service Water
'inal
Safety Analysis Report
Heating Ventillation Air Conditioning
Limiting Condition for Operation
Licensee
Event Report
Low Temperature
Overpressure
Protection
Main Control
Board
Motor Control Center
Main Control
Room
Nuclear Assessment
Department
Nuclear Regulatory
Commission
Plant
Change
Request
Preventive
Maintenance
Plant Nuclear Safety Committee
Quality Assurrance/Quality
Control
Quality Verification
Reactor Auxiliary Building
Refueling Outage
Residual
Heat
Removal
Resistance
Temperature
Detector
Refueling Water Storage
Tank
26
Item Number
Descri tion and Reference
400/94-05-01
400/94-05-02
400/94-05-03
Violation:
Failure to properly implement
procedures,
paragraphs
2.c, 2.d(2),
and
4.a(1).
Violation:
Failure to implement corrective
action to preclude recurrence,
paragraphs
2.d(1)
and 2.e.
Non-Cited Violation:
Failure to control
a
paragraph
5.b.
and Initialisms,
ACFR
AFD
BATP
CFR
CSIP
DSR
ESCWS-
FASR
LCO
LER
MCB
NAD
NRC
PNSC
QA/QC-
QV
Adverse Condition Feedback
Report
Axial Flux Difference
Boric Acid Transfer
Pump
Closed Circuit Television
Component
Cooling Water
Code of Federal
Regulations
Charging Safety Injection
Pump
Daily Surveilance
Requirement
Emergency Diesel
Generator
Essential
Services
Chilled Water System
Emergency Service
Water
Final Safety Analysis Report
Heating Ventillation Air Conditioning
Limiting Condition for Operation
Licensee
Event Report
Low Temperature
Overpressure
Protection
Main Control
Board
Motor Control Center
Main Control
Room
Nuclear Assessment
Department
Nuclear Regulatory
Commission
Plant
Change
Request
Preventive
Maintenance
Plant Nuclear Safety Committee
Quality Assurrance/Quality
Control
Quality Verification
Reactor Auxiliary Building
Refueling Outage
Residual
Heat
Removal
Resistance
Temperature
Detector
Refueling Water Storage
Tank
TDAFW-
TS
WPB
Turbine Driven Auxiliary Feedwater
Technical Specification
Waste Processing
Building
Work Request