ML18011A613
| ML18011A613 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/07/1994 |
| From: | Christensen H, Elrod S, Darrell Roberts, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18011A612 | List: |
| References | |
| 50-400-94-21, NUDOCS 9411010163 | |
| Download: ML18011A613 (22) | |
See also: IR 05000400/1994021
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900
ATLANTA,GEORGIA 303234199
Report No.:
50-400/94-21
Licensee:
Carolina
Power
and Light Company
P. 0.
Box 1551
Raleigh,
NC 27602
Docket No.:
50-400
Licensee
No.:
Facility Name:
Harris
1
Inspection
Conduc ed:
September
3 - 28,
1994
Inspectors:
J.
e row, Senio
esi
nt Inspector
Da e Signed
S
o
, Senior
esi
nt Inspector
CJ
Da e Signed
D
obert
,
s
ent
nspector
Approved by:
H. Christensen,
Section Chief
Division of Reactor Projects
Dat
Signed
/
Date
igned
SUMMARY
Scope:
This routine inspection
was conducted
by the resident
inspectors
in the areas
of plant operations,
review of nonconformance
reports,
maintenance
observation,
surveillance observation,
design
changes
and modifications, plant
housekeeping,
radiological controls, security, fire protection,
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 apparent violation was identified involving inadequate
design control
measures
resulting in a single failure vulnerability affecting the
charging/safety
injection pumps,
paragraph
4-;c.(1).
A second
apparent violation was identified which involved incomplete or
inaccurate
information provided to the
NRC in response
to a generic letter
~
~
~
~
regarding single failure reviews associated
with the
ESW system,
paragraph
4.c.(2).
0163 94i007
941 10'DOCK 05000400
2
An unresolved
item was identified involving cell-to-cell resistance
measurements
exceeding
maximum Technical Specification values for the IA
Emergency Battery,
paragraph
3.a.
An unresolved
item was also identified concerning
improper implementation of
procedure
1E Battery Weekly Test,
paragraph
3.b.
Another example of improper implementation or resolution of vendor manual
recommendations
was identified, paragraph
4.b.
The content of operator logs regarding entry into
a TS
LCO action statement
was deficient,
paragraph
2.a.( I).
Management
involvement in radiation worker activities was considered
to be
beneficial to overall radiation control program,
paragraph
5.b.
Improvement
was noted in technical
support center
command
and control,
dispatch of damage control
teams
from the operations
support center,
and
timeliness
and content of offsite notifications during the annual
emergency
exercise,
paragraphs
S.e, 5.f.(2)
and 5.f(3).
REPORT DETAILS
1.
Persons
Contacted
Licensee
Employees
D., Batton,
Hanager,
Work Control
- D. Braund,
Hanager,
Security
B. Christiansen,
Hanager,
Haintenance
- J. Collins, Hanager,
Training
J.
Dobbs,
Hanager,
Outages
- J. Donahue,
General
Hanager,
Harris Plant
R. Duncan,
Hanager,
Technical
Support
H. Hamby,
Hanager,
Regulatory Compliance
D. HcCarthy,
Hanager,
Regulatory Affairs
- R. Prunty,
Hanager,
Licensing
5 Regulatory
Programs
- W. Robinson,
Vice President,
Harris Plant
- G. Rolfson,
Hanager,
Harris Engineering
Support Services
H. Smith, Hanager,
Radwaste
Operation
B. White, Hanager,
Environmental
and Radiation Control
"A. Williams, Acting Hanager,
Operations
Other licensee
employees
contacted
included office, operations,
engineering,
maintenance,
chemistry/radiation
and corporate
personnel.
- Attended exit interview
S.
A. Elrod arrived
on site September
19,
1994 to relieve J.
E. Tedrow
of his duties
as Senior Resident
Inspector.
This
NRC personnel
change
became effective on September
22,
1994.
and initialisms used throughout this report are listed in the
last paragraph.
2.
,
Operations
a 0
Plant Operations
(71707)
The plant continued in power operation
(Hode 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
inoperable 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.
In general,
the inspectors
found the logs to be readable,
well organized,
and provided sufficient information on plant-
status
and events.
However, the inspector
found the shift
supervisor's
log to be incomplete regarding
a
7 day
LCO that
was entered
at 10:57 p.m.,
on September
19,
1994.
The
LCO
was entered for the "A" steam generator
PORV, valve INS-58,
which had
been declared
due to problems with its
hydraulic system.
The inspector identified on September
20
that the shift supervisor's
log did not contain
an entry for
this
LCO.
This information was available
from other sources
including the onshift operators
and the
RO logs.
This
comment follows similar statements
contained
in
NRC
Inspection
Report 400/94-15 regarding
incomplete control
room logs.
Clearance
tagouts
were found to be properly
implemented.
No violations or deviations
were identified.
Facility Tours
and Observations
Throughout the inspection period, facility tours were
conducted to observe 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,
observations
were
made regarding
monitoring instrumentation
which included equipment
operating status,
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 inspector
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 these
areas
was satisfactory.
No violations or deviations
were identified.
b.
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.
No violations or deviations
were identified.
Maintenance
a ~
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 were issued
and
TS requirements
were being followed.
Maintenance
was observed
and work packages
were reviewed for the following maintenance activities:
Clean boric acid buildup from the
"C" CSIP inlet flange
and
retorque bolts to between
100 -
197 ft~lbs.
Install lube oil sample taps
on "C" CSIP components
in
accordance
with PCR 6103,
Taps.
Jumper out cell
87 from the IA emergency battery
and jumper
in spare cell in accordance
with CM-E0024, Safety/Non-Safety
Spare Battery Cell Connection.
The spare cell
was installed in the IA emergency battery
following discovery of some deformities
on the non-
contacting surface of a battery post
on cell 87.
After
installation of the spare cell
and removal of cell
87 on
September
15, the inspector noted that
no post-maintenance
testing occurred other than items contained
in a'M
procedure
which had
been
performed
on the individual spare
cell prior to its installation (i.e, temperature
and
specific gravity readings).
The inspector
asked
maintenance
personnel
whether
any other post maintenance activities
would be done
on the newly connected
battery cell.
Licensee
personnel
indicated that
no other activities were referenced
in the work ticket or the
PCR which was implemented for the
spare cell installation.
After the inspector left the job
site,
the maintenance
crew took cell-to-cell resistance
readings
between
the newly connected
spare cell
and
a cell
on the tier to which it was connected.
These
readings
were
taken to obtain baseline
data
so that trending could
be
performed during subsequently
scheduled
surveillance tests.
Cell-to-cell resistance
readings of 182 micro-ohms were
obtained
which exceeded
a connection resistance
value of 150
micro-ohms referenced
in TS 4.8.2. 1.
.This information was
documented
in ACFR 94-2887.
The battery
had
been declared
at 9:30 a.m.,
on
September
15 following installation of the spare cell.
It
was declared
inoperable nearly
9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> later at 6:07 p.m.,
based
on engineering
reviews of the above resistance
data.
The'spare cell was then
removed from the battery
and cell
//7
was reinstalled.
The licensee
conducted
an operability
determination
which concluded that the battery would remain
operable with cell
0'7 reinstalled
based
on its post
deformation occurring
on
a non'-contacting
side
and that
no
corrosion existed
on the contacting sides of the post.
The
also concluded that cell P7's
capacity
was not affected
by it having been
removed from the
battery
and uncharged for approximately
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The
licensee
then initiated an event review team tasked with
conducting
an engineering
review to determine
whether the
ability of the battery to perform its intended safety
function was jeopardized
during the
9 hour1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> period in which
the spare cell
was installed.
This review would also
include
a root cause
determination
as to why the attribute
of connection resistance
was missed during development of
the
PCR and/or implementing procedures
which installed the
spare cell.
The licensee
issued
an internal
memorandum
on September
21,
1994,
which concluded that the battery was capable of
performing its intended function with the spare cell
installed
and with cell-to-cell resistance
readings of 182
micro-ohms.
The inspectors later reviewed
a preliminary
licensee
interpretation of TS 4.8.2.1.c.3
which concluded
that the requirement
contained
in Technical Specifications
was intended for resistance
measurements
at individual
connections (i.e between
post
and connecting
bar)
and not
for resistance
values of inter-tier jumpers or cell-to-cell
assemblies,
as
had
been
measured
on September
15.
The
inspectors
informed licensee
personnel
that
an independent
NRC review of the intent behind the
TS requirement
and of
the licensee's
final event review team findings would be
conducted
and tracked
as
an unresolved
item.
Unresolved
Item (400/94-21-03):
Determine the intent of TS 4.8.2.l.c.3
and review the licensee's
operability
determination for the IA Emergency Battery.
In general,
the performance of work was satisfactory with proper
documentation of removed
components
and independent verification
of the reinstallation.
No violations or deviations
were
identified.
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:
~
IE Battery Weekly Test
~
OST-1079
Containment Isolation Valves ISI Test quarterly
Interval
The physical
performance of these
procedures
was found to be
satisfactory with proper
use of calibrated test equipment,
necessary
communications
established,
initial
notification/authorization of control
room personnel,
and
knowledgeable
personnel
having performed the tasks.
Post-completion
procedure
review of MST-0010 by the inspector
found that battery cell temperature
had exceeded
the procedure's
administrative
range but the control
room had not been notified as
required
by the procedure.
Also, the procedure
referenced
vendor
technical
manual
"PAA" or C8D manual
12-800,
Standby Battery,
Flooded Cell, Installation
and Operating Instructions.
Though the
vendor manual
was approved,
the local procedures
did not seem to
implement the various requirements
such
as torque values
upon
installation or semi-annual
retorque at
a lower value prior to
taking inter-cell resistance
readings.
These
items are unresolved
pending completion of the
NRC technical
review.
Unresolved
Item 400/94-21-04:
Adequacy of procedures
and
procedure
adherence
in the area of battery surveillance.
c.
Licensee Action on Previously Identified Maintenance
Findings
'92902)
(Closed) Violation 400/94-13-03:
Failure to calibrate high
voltage probe measuring
device.
The inspector
reviewed
and verified completion of the corrective
actions listed in the licensee's
response letter dated August 24,
1994.
Licensee
personnel
have revised applicable surveillance
test procedures
to require the use of calibrated
high voltage
probes
and
have trained technicians
on using this test equipment.
The high voltage probes
used in the example cited were verified to
meet accuracy requirements
and included in the licensee's
calibration program.
Engineering
Design/Installation/Testing
of Modifications (37551)
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
approved
acceptance
criteria or deviations
were resolved
in an
acceptable
manner,
and that appropriate
drawings
and facility
procedures
were revised
as necessary.
In addition,
PCR's
documenting engineering
evaluations
were also reviewed.
The
following modifications and/or testing in progress
was observed.
~
PCR 6103
Safety Injection Lube Oil Sample
Taps
~
PCR 7379
Reportability Determination of
ESW to "B" CSIP
No violations or deviations
were identified.
System Engineering
(37551)
The inspector reviewed information contained
in a vendor manual
for ITT Barton Hydramotor actuators.
During
a tour on August 8,
1994,
the inspector
noted that these
actuators
were employed
on
various plant valves
and dampers
including auxiliary feedwater
flow control valves from both the motor driven and turbine driven
pumps.
The technical
manual listed
maintenance
recommendations
for the actuators
which included
an
item to stroke the actuators
a minimum of 10 times per 90 days.
The inspector
knew that the
AFW flow control valves were not
routinely stroked at that frequency
and inquired with engineering
personnel
on the subject.
According to the engineer,
the
recommendation
had not been translated
into any maintenance
or
surveillance
procedure.
The engineer
indicated that this
nonconformance
was missed during the licensee's
technical
manual
review conducted
in 1991
and 1992.
As
a result of the inspector's
finding, engineering
personnel
contacted
the actuator manufacturer
who indicated that periodic stroking was only a recommendation
for
Hydramotor actuators
with an older type seal that historically
exhibited leakage
problems.
The. Hydramotors
used for the
AFW flow
control valves
had
been
upgraded with a seal that did not exhibit
the problem.
On August ll, this information was
added to the
review forms which had already
been initiated for the vendor
manual
in question.
Further discussions
with licensee
personnel
indicated that this particular vendor recommendation
had
been
addressed
several
years
ago when the valves were included in the
licensee's
Eg program.
It was determined during correspondence
with the vendor then that the maintenance
recommendation
only
applied to those actuators that
had the older type seal installed.
However, that information was not well documented
as the valves
were ultimately removed
from the
Eg program.
The cognizant
engineer
indicated that
he would initiate an
ESR to have the
vendor manual
updated.
Licensee Action on Previously Identified Engineering
Inspection
Findings
(92703)
(
(1)
(Closed)
Unresolved
Item 400/94-17-04:
Examine the
licensee's
design review of the
ESW system cooling water
supply to the
CSIP oil coolers
and development of a better
test method.
This item was previously discussed
in
NRC Inspection
Report
50-400/94-17.
The licensee
and the
NSSS vendor have subsequently
completed
a design review of the postulated
failure-to-open of valve
"A" return valve."
The design review
considered
the effect on the CSIPs,
and also the increased
service water temperature
effects
on
ESW system piping.
The
review concentrated
on the "8" train CSIPs, i.e., the "8"
CSIP or the
"C" CSIP aligned to the "8" train.
The "A" CSIP
was
assumed
not to be available during the single failure
scenario
due to valve
1SW-270 being
on the "A" ESW discharge
The review analyzed
both the long standing
valve lineup with all valves
open
such that both
ESW trains
supplied all three
CSIPs,
and the temporary
ESW valve lineup
existing from July 1-18,
1994,
in which the opposite train
ESW isolation valves from the oil cooler outlets
were
closed.
The licensee
documented
the following review
results
in
PCR 7379, "Reportability Determination
of,ESW to
nBn CSIP
n
For the long-standing
ESW valve lineup with all the
valves
open
such that both
ESW trains supplied all
three
CSIPs, it was concluded that, if a safety
injection signal
was initiated concurrently with a
"A" train valve
1SW-270 failing
to open would result in cooling water with temperature
exceeding
270 degrees
Fahrenheit
reaching the "8"
train CSIP oil coolers
in 10 minutes
and
26 seconds.
This would result in failure of the only available
CSIP.
For the temporary
ESW valve lineup that existed
from
July 1-18,
1994, in which the opposite train
isolation valves
on the oil cooler outlets were
closed,
the time for this increased
temperature
water
to reach the "8" train CSIP oil coolers
was reduced to
9 minutes
and
13 seconds.
This would result in
quicker failure of the only available
CSIP.
The design review further concluded that operator
'ction
would be required within the above time frames
to prevent
CSIP failure.
~
The
NSSS vendor also concluded that the integrity of
the
ESW piping in the
CSIP rooms,
which would be
challenged
by expansion
from temperatures
exceeding
the design,
could not be assured
unless
operator
action was taken within the
above time frames.
This vulnerability existed
from initial power operations
in
Janua'ry
1987, until July 18,
1994,
when the opposite train
ESW supply valves to the
CSIP oil coolers
were shut.
This,
in conjunction with previously shutting the opposite train
oil cooler discharge
valves on'uly I, 1994,
accomplished
total train separation
of the
to and from the
CSIPs.
The licensee
considered
the current lineup (opposite
train supply
and discharge
valves shut) to be both the short
and long term corrective action to eliminate the single
failure vulnerability.
The inspectors
reviewed the engineering evaluation,
various
flow and temperature profile calculations,
and
correspondence
between
the licensee
and its
NSSS vendor.
Based
on flow models developed to support the evaluations,
the increased
temperature vulnerability was setup
by the
single failure of valve
ISW-270 followed by an increase
in
the "A" discharge
pressure
due to continued operation
of the "A" ESW booster
pump.
This increase
in discharge
pressure
would cause
a reverse
flow path in which
preheated
ESW water would flow back through the "A" EDG
jacket water cooler,
which provides
a significant heat input
during the loss of offsite power scenario.
Heated
ESW water
would then flow through the CSIP oil coolers.
Because of
the lack of train separation
before July 18 and the
significantly higher "A" train header
pressure,
the "B"
would not provide sufficient cooling water flow to
the
CSIP oil coolers during the postulated
scenario
absent
operator action.
The inspectors
had originally questioned
why the "B" ESW
was not vulnerable to the comparable
single failure
of "B" train header
discharge
valve ISW-271.
The licensee's
flow model considered this.
The study concluded that the
"B"
ESW booster
pump was located
downstream of the
CSIP oil
cooler lines such that it did not create
the
same
high
pressure/reverse
flow gradients that the "A" train failure
did.
The inspectors
reviewed the design basis of the
ESW system
contained
in the licensee's
FSAR section 9.2. 1, Service
Water System.
It stated that the service water system is
designed to provide
a heat sink for essential
loads
assuming
a single active failure in conjunction with a loss of
offsite power.
Essential
loads referenced
in Table 9.2. 1-1
of the
FSAR included the charging
pump oil coolers.
As
referenced
in Table 9.2.1-13 of the
FSAR,
a failure analysis
was performed prior to plant operations
to support the
statement
that service water to essential
cooling loads
would be assured
despite
any active failure in the system.
That analysis
only considered
the active failures of the
pumps,
booster
pumps,
one emergency electric power train,
and non-essential
header isolation valves.
It did not
consider the failure of any other motor operated
valves in
the system.
In 1989, following industry events
involving service water
systems,
the
NRC issued
Generic Letter 89-13, Service Mater
System
Problems Affecting Safety-Related
Equipment.
One of
the actions
requested
by the Generic Letter was that
licensees
conduct
a review to confirm that the service water
systems
would perform their intended safety 'functions in the
event of the failure of a single active component.
Following recent
concerns with the Harris
ESM system
involving the above-described
scenario
and the recent
discovery of Asiatic clams in the
ESW intake structures
(IFI
400/94-17-02),
the inspectors
reviewed the licensee's
earlier actions regarding the generic letter.
The licensee
provided
a draft single failure analysis
which discussed
the
consequences
of the failure modes of every active component
in the
ESW system.
The analysis for valve- 1SW-270
concluded,
in summary, that
no immediate corrective actions
were required
and that control
room annunciation
and
redundant train flow would be available.
The reverse
flow
and elevated
temperature
scenario
was never considered.
According to licensee
personnel,
this draft single failure
analysis
was the only one completed to address
the generic
letter.
t
10 CFR 50 Appendix A, Criterion 44, requires that
a system
to transfer heat from systems
and components
to an ultimate
heat sink be provided which will perform the intended safety
function assuming
a single failure.
Criterion III, requires that measures
be established
to
assure that applicable regulatory requirements
and the
design basis
are correctly translated
into specifications,
drawings,
procedures,
and instructions.
The single failure
vulnerability described
above,
and the lack of adequate
design
measures
both prior to plant operation
and during the
Generic Letter 89-13 review are contrary to these
requirements
and are considered
to be
an apparent violation.
Apparent Violation (400/94-21-01):
Failure to establish
adequate
design
measures
to prevent/identify single failure
vulnerability associated
with ESW=valve
10
As mentioned
above,
the single failure vulnerability was
immediately corrected
by shutting the opposite train's
supply
and discharge
valves.
However, at the conclusion of
the inspection period, the licensee
had not completed
a root
cause investigation into why the design deficiency was
missed.
It should
be noted that while this postulated
failure is based
on theory, various flow characteristics
assumed
in the licensee's
flow analyses
were substantiated
by field walkdowns
and the results of surveillance tests.
As a mitigating factor, the licensee
conducted .validation
scenarios
on the plant simulator to demonstrate
that
operators
on six crews would have taken steps
to restore
adequate
ESW flow within the
9 minute time frame (i.e.,
opening
ISW-270, stopping the "A" ESW booster
pump, etc.)
using existing procedures
and relying on control
room
annunciation.
These
scenarios
were conducted,
however,
assuming that offsite power was available.
The licensee
indicated that its root cause investigation
and
any
recommendation
of corrective actions
would be completed
by
the end of September
1994.
As noted
above,
the inspectors
reviewed the licensee's
actions taken in response
This
Generic Letter requested,
among other actions,
that
licensees
confirm that the service water system would
perform its intended function in accordance
with the
licensing basis for the plant.
The confirmation was to
include
a single failure review for every active component
in the system
and
a recent
system walkdown.
In a letter to
the
NRC dated January
26,
1990,
the licensee
committed to
conduct the review and walkdown prior to startup
from the
next scheduled
refueling outage.
In a followup response
to
the
NRC dated
June
17,
1991, the licensee
stated that the
Harris plant
had completed,
as of the Hay 20,
1991, plant
startup date
(from refueling outage
0'3), the initial
activities, testing,
and establishment
of the continuing
program to which CPLL committed.
Following the recent discovery of Asiatic clams
and the
single failure vulnerability associated
with ISW-270, the
inspectors
reviewed
a copy of the single failure analysis
conducted
to support the generic letter.
This review
contained
a failure analysis for each of the active
components
as requested
by the letter.
However, the
information provided to the inspectors
was in draft form.
Licensee
personnel
informed the inspectors that they were
unable to track down
a finalized copy of the failure
analysis,
but they were able to locate internal
memorandums
issued
from the offsite engineering
organization during the
time frame in which the single failure review was conducted.
These
memos discussed
the status of the draft single failure
analysis.
One
memorandum
dated
Hay 22,
1991, stated that
the single failure review would remain in draft to'allow
incorporation of plant comments.
The Hay 7 memo stated that
after cleaning
up of editorial
comments,
the single failure
reviews would be transmitted onsite for inclusion into
packages
being prepared for future
NRC inspection.
The
licensee
was unable to find any further internal
correspondence
indicating that the si'ngle failure review was
finalized prior to Hay 20,
1991,
as indicated in its
response
to the
NRC.
Completeness
and Accuracy of Information,
requires,
in part, that information provided to the
Commission
by a licensee
or information required
by the
Commission's regulations,
orders,
or license conditions to
be maintained
by the licensee
shall
be complete
and accurate
in all material
respects.
The .licensee's
actions regarding
the incomplete single failure review or the absence
of
documentation
in plant records containing
a finalized single
failure review is in contrast to statements
contained
in the
licensee's
response
to the
NRC dated
June
17,
1991.
The
licensee's
activities in this regard
are contrary to
and are considered
to be
an apparent violation.
Apparent Violation (400/94-21-02):
Failure to provide
complete
and accurate
information regarding service
water'eviews.
'Closed)
Inspector
Followup Item 400/94-15-01:
Follow the
licensee's
actions to determine
the adequacy of
ESW flow to
the
ESCWS chillers while aligned to the main reservoir at
the minimum TS level.
Licensee
personnel
have completed engineering calculation
SW-0078 to determine the minimum flowrates for the
system
when aligned to take
a suction from the main
reservoir.
The licensee
performed this calculation in
conjunction with the single failure analysis of 1SW-270
described
in paragraph 4.c.(1) of this report.
The
calculation
assumed
a minimum main reservoir level of 205.7
feet
and considered
single failures of active components.
This calculation revealed that the minimum calculated
flowrates for all major
ESW-cooled
components,
including the
ESCWS chillers, were above their respective limits.
The
minimum flowrate values for the "A" and
"B" ESCWS chillers
were calculated to be 2,258
GPH and 2,288
GPH respectively
compared to the minimum limit of 2, 175
GPH.
(Closed) Violation 400/94-12-03:
Failure to properly review
and approve
a change to modification acceptance
testing.
The inspector
reviewed
and verified completion of the
corrective actions listed in the licensee's
response letter
12
dated July 14,
1994.
Licensee
personnel
reviewed the actual
acceptance
testing performed for the modification and found
it to be satisfactory.
Field revision
88 was issued to
modification PCR-6105,
EDG Start
Time Recorder,
to document
the testing performed.
Training was provided to appropriate
licensee
engineering
personnel.
5.
Plant Support
a.
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.
b.
C.
Radiological
Protection
Program
(71750)
- Radiation protection
control activities were observed to verify that these activities
were in conformance with the facility policies
and procedures,
and
in compliance with regulatory requirements.
The inspectors
also
verified that selected
doors which controlled access
to very high
radiation areas
were appropriately locked.
Radiological
postings
were likewise spot checked for adequacy.
While observing
maintenance
associated
with the
"C" CSIP on
September
12, the inspectors
noted that several different jobs
involving 5 or 6 workers were occurring simultaneously.
All of
the jobs involved breaching the area
around the
pump baseplate
which had
been
posted
as
a contaminated
area listing only gloves
as
a dress
requirement.
The inspector
considered
the number of
people working in this small
area to represent
a higher than
normal potential for spreading
contamination,
especially in the
absence
of a health physics technician.
This concern
was
discussed
with the appropriate
management
personnel
who had also
observed
the working condition
and
had already initiated steps to
correct it.
When the inspector returned to the work site,
he
noted that
a health physics technician
was present
and the size of
the posted
area
had
been
increased
so that better controls could
be implemented for equipment
being taken from the
pump baseplate
area.
The inspector considered
licensee
management's
aggressiveness
in addressing
this matter to be beneficial to the
plant's overall
implementation of the radiological protection
program.
Security Control
(71750)
- 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'bserved
the operational
status of
closed circuit television 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.
13
Fire Protection
(71750)
- 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.
During plant tours,
areas
were
inspected
to ensure fire hazards
did not exist.
Emergency
Preparedness
(71750)
- Emergency
response
facilities'ere
toured to verify availability for emergency
operation.
Duty
rosters
were reviewed to verify appropriate staffing levels were
maintained.
As applicable,
emergency
preparedness
exercises
and
drills were observed to verify response
personnel
were adequately
trained.
On September
13,
1994, the annual
emergency drill was conducted
by
the licensee
to verify the effectiveness
of the Radiological
Emergency
Response
Plan
and implementing procedures.
In contrast
to comments
contained
in
NRC Inspection
Report 50-400/94-13
concerning
a practice dril1, no problems
were identified in the
area of command
and control from the
TSC.
Additionally, open
items identified during previous
annual
exercises
involving
timeliness
and content of offsite notifications
and delays in
dispatching
damage control
teams
from the
OSC were closed
as
indicated in paragraphs
5.f.(2)
and 5.f.(3) below.
Licensee Action on Previously Identified Plant Support Inspection
Findings
(92904)
(1)
(Closed) Violation 400/94-05-02:
Failure to implement
adequate
corrective actions to prevent recurrence
of
deficiencies.
The inspector
reviewed
and verified completion of the
corrective actions listed in the licensee's
response letter
dated April 8,
1994.
The following actions
were completed:
~
For the temperature
maintenance
of boron injection
piping, the licensee
completed modification PCR-6259
which installed replacement
room heaters
in the boric
acid transfer
pump valve gallery.
In addition,
placards
were installed near the heater
power panels
alerting personnel
to their importance.
The auxiliary
operator
rounds guidance
was also
changed
indicating
. the importance of the heaters
and compensatory
action
required if they are found to be functioning
improperly.
~
For the degraded
ERFIS
SPDS function, the licensee
revised operating
procedures
and generated
an
operational
check procedure to verify proper operation
of ERFIS.
Operating logs were revised to periodically
check that key ERFIS functions are working properly.
14
A long term plan was also developed for ERFIS
reliability enhancements.
(2)
(Closed)
Inspector
Followup Item 400/92-16-03:
Review
licensee's
corrective actions for improving notification
content
and timeliness to offsite emergency
agencies.
The licensee's
recent training for emergency
communicators
emphasized
message
content .and timeliness.
Additionally,
with the
EOF now assembling for activation at
an alert
classification,
the responsibility for notification of the
State
and Counties
was turned over to the
EOF from the
control
room.
This simplified the turnover process
by
eliminating the interim steps of turnover from the control
room to the
TSC and then from the
TSC to the
EOF.
The
emergency notification messages
1 thru
10 reported during
the September
13,
1994,
emergency 'exercise
were reviewed for
message
content
and timeliness.
All messages
were timely
and contained
the significant events
which affected the
response
of the State
and Counties.
(3)
(Closed)
Inspector
Followup Item 400/93-18-01:
Exercise
Weakness:
Damage Control
Team
(DCT) with top priority
mission took approximately
two hours to be dispatched
from
the
OSC.
The licensee
had increased
the level of management
authority
in the
OSC by re-locating the emergency repair director from
the
TSC to the
OSC.
The SEC's priorities for DCT's were
thereby
implemented
by the
ERD in the responsible
emergency
facility.
Other changes
included selected
OSC personnel
being partially dressed-out
in advance to expedite
team
response.
Noted improvements
were observed
in the September
13,
1994 emergency
exercise with the timely dispatch of top
priority teams
being emphasized.
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,
emergency
preparedness
requirements
and
TS
requirements
in these
areas
was satisfactory.
No 'violations or
deviations
were identified.
Exit Interview (30703)
The inspectors
met with licensee
representatives
(denoted
in paragraph
1) at the conclusion of the inspection
on September
28,
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
15
inspectors
during this inspection.
No dissenting
comments
from the
licensee
were received,
however,
regarding the response
to Generic Letter 89-13 discussed
in paragraph 4.c.(2),
the licensee
believed that
the Generic Letter technical
review was completed
and that any
incompleteness
involved administrative concurrence.
Item Number
Descri tion and Reference
400/94-21-01
Apparent Violation:
Failure to establish
adequate
design
measures
to prevent/
identify single failure vulnerability
associated
with
ESW valve
400/94-21-02
400/94-21-03
400/94-21-04
and Initialisms
Apparent Violation:
Failure to provide
complete
and accurate
information
regarding
a service water review.
Unresolved
Item:
Determine the intent of
TS 4.8.2. l.c.3 and review the licensee's
operability determination for the
1A
Emergency Battery.
Unresolved
Item:
Adequacy of procedures
and procedure
adherence
in the area of
battery surveillance.
ACFR
CFR
CPKL
CSIP
ERD
ERFIS-
ESCWS-
GPM
IFI
LCO
NRC
Adverse Condition Feedback
Report
Code of Federal
Regulations
Carolina
Power
and Light
Charging Safety Injection
Pump
Damage Control
Team
Emergency Diesel
Generator
Environmental Qualification
Emergency
Response
Director
Emergency
Response
Facility Information System
Essential
Services Chilled Water System
Emergency Service
Water
Final Safety Analysis Report
Gallons
Per Minute
Inspector
Followup Item
Inservice Inspection
Limiting Condition for Operation
Nuclear Regulatory
Commission
Nuclear Steam
System Supplier
Operational
Support Center
Power Operated Relief Valve
Reactor Operator
Safety Injection
TS
16
Safety Parameter
Display System
Technical Specification
Technical
Support Center
0