ML18012A457
| ML18012A457 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/20/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18012A455 | List: |
| References | |
| 50-400-96-10, NUDOCS 9701150050 | |
| Download: ML18012A457 (19) | |
See also: IR 05000400/1996010
Text
U. S.
NUCLEAR REGULATORY COHHISSION
REGION II
Docket No:
License
No:
50-400
NPF ~ 63
Report
No:
50-400/96-10
Licensee:
Carolina
Power
& Light (CP&L)
Facility:
.Shearon Harris Nuclear
Power Plant, Unit 1
Location:
5413 Shearon Harris Road
New Hill, NC 27562
Dates:
October
13
-
November
23,
1996
Inspectors:
J.
Brady, Senior Resident
Inspector
DE Roberts,
Resident
Inspector
G. HacDonald,
Project Engineer
Approved by:
N. Shymlock, Chief, Projects
Branch 4
Division of Reactor Projects
970l150050
961220
ADOCK 05000400
8
EXECUTIVE SUMMARY
Shearon Harris Nuclear
Power Plant, Unit 1
NRC Inspection Report 50-400/96-10
This integrated
inspection included aspects of licensee operations,
engineering,
maintenance,
and plant support.
The report covers
a six-week
period of resident inspection:
in addition, it includes the results of an
announced
inspection
by a regional project engineer.
O~erations
~
The conduct of operations
during the period was adequate.
(Section 01.1)
The negative trend in operator
performance
continued into this report
period with two minor errors being identified by the licensee.
(Section 04.1)
~
The System Description for the Chemical
5 Volume Control
System did not
describe the emergency boration function. (Section 02.1)
~
Self-assessment
activities were good (Section 07.1)
Maintenance
~
Maintenance
personnel
were following procedures
during maintenance
activities
and modification installation activities.
An incorrect
maintenance
procedure
had personnel
bypass
a start permissive interlock
for the running ."A" Normal Service Water
(NSW)
pump rather than the
intended
"B" NSW pump during an uncoupled motor run. (Section H1.4)
~
Surveillance
performances
were being adequately
conducted.
(Section
M2.1)
En ineerin
Engineering support for operation of the plant was good (Section E2.1)
Two violations were identified which related to the determination of a
new main reservoir water level design basis.
One related to the use of
an administrative limit to administer
the
new main reservoir level limit
without promptly submitting
a license
amendment
request to change the
Technica'I Specification value.
The other involved not providing the new
design basis
when Final Safety Analysis Report
(FSAR) Amendment 46 was
submitted.
(Section E8.1)
Plant
Su
ort
The general
control of contamination
and dose for the site was good.
The performance of a Reactor Coolant System
sample using the Post
Accident Sampling System
was good.
(Section Rl.l)
Management
commitment to the performance of the emergency
response
function was good.
(Section Pl.l)
~
The security and safeguards
activities were we1] performed.
(Section
S1.1)
Fire Protection activities were acceptable
(Section Fl.l)
Re rt Details
Summar
of Plant Status
Unit 1 maintained 100'ercent
power during this entire inspection period.
01
01.1
Conduct of Operations
General
Comments
71707
~l. 0
02
02.1
04.1
Using Inspection Procedure 71707,
the inspectors
conducted frequent
reviews of ongoing plant operations.
In general,
the conduct of
operations
was professional
and safety-conscious;
specific events
and
noteworthy observations
are detailed in the sections
below.
Operational
Status of Facilities and Equipment
En ineered Safet
Feature
S stem Walkdowns
71707
The inspectors
used Inspection
Procedure
71707 to walk down accessible
portions of the following Engineered
Safety Features
(ESF) systems:
~
High Head Safety Injection
(FSAR Section 6.3.2)
~
Chemical
8 Volume Control System
(FSAR Section 9.3.4)
Equipment operability, material condition,
and housekeeping
were
acceptable
in all cases.
The inspector
observed that the system
description for the Chemical
and Volume Control System,
SD-107.
Revision 5, did not describe the emergency boration function of the
system.
That function was described in FSAR section 9.3.4,
and in
rocedure
Emergency Boration, Revision 10, which is referenced
y several
Emergency Operating Procedures.
The licensee
was taking
action to add
a description of this feature to the system description.
Operator Knowledge and Performance
General
Comments
71707
Inspection Reports 50-400/96-07
and 96-09 documented
a negative trend in
human performance
associated
with the operation of plant equipment.
During the routine review of condition reports,
the inspectors
noted
that several
operator
performance
issues
were documented indicating a
continuance of the negative trend.
One involved an inadvertent control
switch manipulation in actuating the emergency
load sequencer test
switch instead of the lamp test switch
(CR 96-03278)
and another
involved the momentary deadheading of the boric acid transfer
pump
(CR
96-03327).
In these
two situations the errors were immediately detected
by the operators
and corrected without any safety consequences.
07
07.1
08.1
Quality Assurance in Operations
Licensee
Self-Assessment
Activities
40500
Ouring the inspection period, the inspectors
reviewed multiple licensee
self-assessment
activities, including:
Plant Nuclear Safety Committee
(PNSC) meetings
on October
28,
1996
and November 22,
1996;
Nuclear Assessment
Section Audits on Harris Nuclear Plant
(HNP)
and Corporate
Nuclear
Fuels
Program
(HNAS96-213)
and on Cold
Weather Preparations
(HNAS96-224);
Condition reports.
Self-assessment
activities were good during the assessment
period.
The
inspectors
noted that the Nuclear Assessment
Section
(NAS) has reviewed
the line organization self-assessments
as part of their audits.
NAS
used the number of condition reports that the line organization
has
issued
as
an initial indicator of the quality of'he self-assessments.
This has instilled in the line organization that the writing of
condition reports is good.
Hiscellaneous
Operations
Issues
(92700,
90712)
Cl'osed
LER 50-400/95-012-00:
Containment Pre-entry Purge Valve
drifted open during Node
1 power operation.
This item was reported
due to Containment Pre-entry
Purge Valve 1CP-1
drifting open on November 10,
1995.
This was reported
as
a violation of
Technical Specification (TS) 3.6.1.7
and 3.3.2.
The method for ensuring
this valve and 1CP-7 were sealed
shut was found to be deficient.
The
air isolation valves were locked shut to prevent air from opening the
valves.
In this case the air isolation valve for
1CP-1 leaked by during
performance of a Containment Pre-Entry Purge
Fan start causing the valve
to drift open.
The Pre-Entry Purge
Fan start generates
an open signal
which pressur izes the line to the 1CP-1 air isolation valve.
That
occurred at 12:10 p.m.
on November 10,
1995.
The valve was discovered
to have drifted open at 6:00 p.m. the
same day.
The operators
took
immediate action to close
1CP-1 when they noticed intermediate
indication.
Further corrective action was to open
a vent down stream of
the air isolation valve to ensure that pressure
cannot buildup and open
~ 1.7 states that with a containment pre-entry purge makeup and/or
exhaust isolation valve open or not sealed
closed,
close and/or seal
closed that valve or isolate the penetration(s)
within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />,
otherwise
be in at least
Hot Standby in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
and in cold
shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
The licensee
speculated that
the valve opened
no earlier than 12:10 p.m..
and that at 4:10 p.m. the
valve should have been shut to comply with the action statement.
The
inspector
was unable to independently verify at what time 1CP-1
came off
its closed seat.
The inspector
concluded that the licensee's
operability and reportability determinations
were appropriately
conservative
and followed the guidance in Generic Letter 91-18.
The inspector 's rev'iew of licensee
records
support the licensee's
conclusion that the root cause
was that opening air pressure
leaked by
1CP-1 isolation valve.
The licensee's
long term corrective action was
to revise procedures
to ensure the instrument air lines were
disconnected
between the air isolation valve and the valve actuators for
and 1CP-7.
The inspector verified that procedures
Containment Ventilation and Vacuum Relief, Revision 9, OST-1029,
Containment Penetration
Outside Isolation Valve Verification, Revision
7,
and OST-1055,
Containment Pre-Entry Purge
and Exhaust Valve Inser vice
Inspection,
Revision
6 included provision to disconnect
(or verify
disconnected)
the air lines to 1CP-1
and 1CP-7.
The inspector also
field verified that the air lines were disconnected.
This
LER is
closed.
II. Maintenance
Conduct of Maintenance
General
Comments
Ins ection
Sco
e
62707
The inspectors
observed all or portions of the following work
activities:
~
WR/JO 96-AHHI2, Repair/Replace
TCV for AH-15A
~
WR/JO 96-AMOS 002, Inspect
"A" CSIP Oil Cooler
~
WR/JO 96-ACWJl, Fabricate
and Install Emergency Diesel Generator
(EDG) Shaft Encoder
on
EDG A.
Observations
and Findin s
The inspectors
found the work performed under these activities to be
professional
and thorough.
All work observed
was performed with the
work package
present
and in active use.
Technicians
were experienced
and knowledgeable of their assigned
tasks.
Measurement
and test
equipment
was in calibration.
The inspectors
frequently observed
supervisors
and system engineers
monitoring job progress,
and quality
control personnel
were present
whenever required by procedure.
When
applicable,
appropriate radiation control measures
were in place.
Modification Engineering Service Request
96-00114
was performed by
maintenance
personnel
with oversight by the system engineer.
The
modification was implemented
by maintenance
work package
WR/JO 96-ACWJl.
The work activity was well managed to minimize the Limiting Condition
for Operation
(LCO) time.
Post installation checks were performed with
the
EDG operating to verify proper alignment,
ensure
no leakage,
and to
verify that the transmitter provided output signals.
Post installation
checks were satisfactory.
8
NSW Pum
Re air
Ins ection Sco
e
62707
The inspectors
observed portions of the following work activity:
~ 'R/JO 96-AHYFl,
8 Normal Service Water
(NSW)
Pump Repair
Observations
and Findin s
The inspectors
observed the installation of the repaired
8
NSW pump.
The work was performed in accordance
with-work documents actively in
use.
Haintenance
personnel
were knowledgeable of their assigned
tasks.
The system engineer
. supervisors,
and Quality Control
(QC) personnel
were noted to be monitoring'he job.
The installation of the
pump was
acceptable
and the work performed was professional.
Following the installation of the 8
NSW pump and motor,
an uncoupled
motor run was scheduled
as part of post maintenance testing to verify
proper operation.
The test
was conducted
per procedure
ORT-1413,
Revision 3,
Normal Service Water
Pump Uncoupled Hotor Operation.
The
motor failed to start
and the motor breaker did not close.
The licensee
wrote condition report
(CR) 96-003353
and initiated an investigation of
the failure.
Uncoupled motor operation required bypassing start permissive interlocks
by the use of electrical
jumper wires.
The licensee
determined that the
start failure was due to an incorrect jumper placement.
Operators
installed the jumpers in accordance
with procedure
ORT-1413.
However,
the procedure
was incorrect and resulted in the technicians
bypassing
the start permissive interlock for the running A NSW pump rather than
the 8
NSW pump as required.
The inspector
reviewed the procedure
and plant drawings
and confirmed
that the procedure
was incorrect.
The jumpers were correctly installed
in panel
ARP-11 in the relay room and from observation of the jumper
terminals the inspector determined that the incorrect jumper placement
was not caused
by an operator
error or a lack of attention to detail but
due to an incor rect procedure.
If the jumper had been in a trip circuit
rather than
a star t permissive circuit,
a 'ioss of normal service water
would have resulted which would have challenged operators
and could have
caused
a plant transient.
Installation of Kirk Ke
Interlock Hodification
Ins ection Sco
e
The inspectors
observed portions of the following work activities:
WR/JO 96-AFNUP1
Install Kirk Key Interlock For Charging/Safety
Injection Pump
(CSIP)
1A Breaker
WR/JO 96-AFNUQl
WR/JO 96-AFNU1
WR/JO 96-AFNUT1
Instal.l Kirk Key Interlock For CSIP
1C Breaker
Install Kirk Key Inter lock For
Component Cooling
Water
(CCW)
Pump
1C Breaker
Install Kirk Key Interlock For
CCW Pump
1A
Breaker
Observations
and Findin s
The inspectors
observed the implementation of modification ESR No. 96-
00422,
Revision 0, regarding the installation of kirk key interlocks for
the Charging/Safety Injection Pump (CSIP)
and the Component Cooling
Water
(CCW) pumps.
The objective of the modification was to prevent
loading either two CSIP or two CCW pumps onto
a safety related
electrical
bus at the
same time.
This modification implemented
corrective action for NRC Yiolation 50-400/96-06-01.
The modification was installed by maintenance
personnel
working
individual work requests
for each breaker.
The inspectors
observed the
interlocks being installed on the 1A-SA bus,
breaker
compartments 3,5,7
and 8.
The modification consisted of installing capture
key deadbolt
lock sets to control the position of the breakers in the compartments
with two locks and one key per interlocked breaker pair.
The Kirk Key
inter lock deadbolt.
when extended.
functioned to prevent a'reaker
from
being racked into the connect position by blocking the breaker shutter
guide on the right side of the breaker which prohibited further travel.
This would permit only one breaker to be racked into the connected
position at
a time.
The inspector observed that work was performed in
accordance
with the modification package
and the individual work
documents.
QC personnel
were available
whenever
required by the work
documents.
Engineering personnel
were coordinating the installation of
the modification.
All personnel
were knowledgeable
regarding the
modification workscope
and installation requirements.
Work was
professional
and thorough.
The
LCO time was not exceeded.
Good
coordination
was noted between engineering,
maintenance,
QC and
operations
personnel.
The inspector
observed the performance of the post installation testing
of the modification.
The testing met the acceptance criteria; however,
the inspector
identified that the interlock for the swing
1C
CCW breaker
compartment
was not tested with the
1C
CCW pump breaker.
An alternate
breaker
was used to test the interlock.
The
1C
CCW breaker
was
installed in the 1B-SB switchgear
which is located in an adjacent
switchgear
room.
The door between the switchgear
rooms is equipped with
a removable curb.
Rather than disassemble
and remove the curb to allow
the
1C
CCW breaker to be rolled into the
1A switchgear
room to test the
interlock, licensee engineering
personnel
made
a conscious decision to
utilize another breaker.
This necessitated
the removal of the
compartment
1 bracket to allow an alter nate breaker into the
1C
breaker
compartment.
The inspector
questioned
the licensee to determine if they had verified
that the swing
1C
GCW breaker
shutter bracket dimensions
were the
same
as the breaker
used to test the inter lock.
The licensee
had not
verified the shutter bracket dimensions.
The swing
1C
CCW breaker
compartment
was opened
and the dimensions
were verified to be acceptable
for interlock function.
The inspector
determined that the post
installation testing verified the objective of the modification.
However, the dimensions of the swing
1C
CCW pump breaker
were not
verified 'prior to 'testing the
1C
CCW pump breaker
compartment interlock
with an alternate
breaker until questioned
by the inspector.
Conclusions
on Conduct of Haintenance
Haintenance
personnel
were following procedures
during maintenance
activities and'modification installation activities.
The test procedure
for the nonsafety-related
NSW pump motor
was inadequate
which extended
the time that the plant was operated
in reduced
equipment status.
r
Hodification installation and post installation testing
was acceptable
for the
EDG shaft encoder modification and the switchgear kirk key
interlock modification.
The dimensions of the swing
1C
CCW pump breaker
were not verified prior to testing the
1C
CCW pump breaker
compartment
inter lock with an alternate
breaker until questioned
by the inspector.
Haintenance
and Hater ial Condition of Facilities and Equipment
Surveillance Observation
Ins ection Sco
e
61726
The inspectors
observed all or portions of the following surveillance
tests:
~
EPT-250,
A Train
ESW Flow Verification/Balance,
Revision 3.
~
OST-1013,
1A-SA Emergency Diesel Generator Operability Test.
Honthly Interval
Hodes 1-2-3-4-5-6,
Revision 9/l.
Observations
and Findin s
The inspector
found that the testing
was adequately
performed.
The
Emergency Service Water
(ESW) flow to containment
fan cooler
AH-2 did
not meet acceptance criteria.
CR 96-03304
was written for the adverse
condition.
The inspector discussed
the issue with engineering
and
operations
personnel
and determined that there was still margin between
the measured
value and the flow used in the safety analysis/FSAR.
The
licensee
had already identified long term corrective action for the
upcoming refueling outage to address
containment
fan cooler
ESW flow.
C.
H8
M8.1
H8.2
The corrective actions included containment
fan cooler
ESW orifice
modifications and
ESW pump modifications.
Conclusions
The surveillance
performances
were adequately
conducted.
Hiscellaneous
Haintenance
Issues
(92700)
Closed
LER 50-400/95-14-00:
Residual
Keat Removal
(RKR) System
components
removed from service for testing while required for
operability resulting in Technical Specification violation.
This
LER was issued to report
a condition that occurred in 1994, but was
not determined to be reportable until December
14,
1995 as
a violation
of Technical Specifications.
Inservice Inspection testing of RKR check
valves
was held up during refueling outage
6 due to the good questioning
attitude of several
licensee
personnel
pertaining to performance of a
ortion of this test with the plant in mode 6 and refueling cavity level
ess than 23 feet.
The procedure
(OST-1508,
Revision 2) did not specify
that refueling cavity level
needed to be above
23 feet for this test to
be performed in,mode 6.
Condition Report 95-2468 was issued to identify
this problem.
The licensee
reviewed previous occurrences
of the
rocedure to determine if they had occurred with refueling cavity level
elow 23 feet in mode 6.
The 1994 occurrence
was discovered
and
reported.
Procedure
OST-1508,
ISI Operability Test for 1CS-167,
1CS-
294,
was revised to add the 23 feet as
a prerequisite
for mode 6.
The inspector verified that it was added to Revision 3
which was the current revision.
The licensee identified potential
programmatic surveillance
procedure
problems in LER 50-400/95-07
and as corrective action committed to a
comprehensive
surveillance
procedure
review program which was still
ongoing.
That review also addressed
Generic Letter 96-01, Testing of
Safety-Related
Logic Circuits.
Collectively, in the past two years the
licensee
has reported over 40 items related to surveillance
procedure
problems.
Consequently,
the generic aspects
of surveillance
procedure
program deficiencies will be reviewed during closure of LER 50-400/95-
07.
This item is closed.
Closed
LER 50-400/94-001-00:
Technical Specification surveillance
violation due to inadequate
procedure.
This event report was issued to
report that the slave relay test for relay K623 did not verify actuation
of the reactor coolant drain tank pump discharge
valve (lED-121).
The
specific corrective actions were reviewed
as documented in IR 50-400/96-
07 and found acceptable.
In that report the inspector discussed
the
comprehensive
surveillance procedure
review program that was committed
to in LER 95-07 which was still ongoing.
As discussed
above,
the
generic aspects of surveillance
procedure
program deficiencies will be
reviewed during closure of LER 50-400/95-07.
This item is closed.
III. En ineerin
E2.1
E7
E7.1
E8
E8.1
Engineering Support of Facilities and Equipment
General
Comments
37551
Engineering support for the operation of the plant was observed to be
good during the inspection period.
Operations
personnel
informed and
routinely involved the system engineer
with abnormalities
found with a
particular
system.
Several
problems with containment isolation valves
during the period resulted in significant engineering effort to achieve
resolution.
Quality Assurance in Engineering Activities
S ecial
FSAR Review
37551
A recent discovery of a licensee
operating their facility in a manner
contrary to the Updated Final Safety Analysis Report
(UFSAR) description
highlighted the need for a special
focused review that compares plant
practices,
procedures
and/or
parameters
to the
FSAR descriptions.
While
performing the inspections
discussed
in this report, the inspectors
reviewed the applicable portions of the
FSAR that related to the areas
inspected.
The licensee
made
a presentation to the
NRC on Hay 31,
1996 concerning
their corporate-wide plan for reviewing the
FSAR at the CPSL sites.
The
program has generated
a large number of condition reports at the Harris
Plant
(264 by the end of the inspection period).
Three have resulted in
LERs.
The results
from this program will be reviewed in the closure of
Unresolved
Item 50-400/96-04-04,
Tracking
FSAR Discrepancy Resolution.
The inspectors
did not find any additional discrepancies
other than
those identified by the licensee.
Miscellaneous
Engineering Issues
(92903)
Closed
Unresolved
Item 50-400/96-09-03:
Emergency Service Water
(ESW) Technical Specification Interpretation.
This item was unresolved
pending the inspector's
review of previous main
reservoir level history and an overall regulatory assessment.
The
inspector
reviewed previous main reservoir
levels from 1987 until
current that was documented
from performance of procedure
OST- 1021,
Daily Surveillance Requirements.
The inspector verified that the level
had never
been below 217 feet.
Inspection Report 50-400/96-09
documented that
a Technical Specification
Interpretation
(TSI) had been put in place to change the Ultimate Heat
Sink Technical Specification (TS) 3.7.5 Limiting Condition for Operation
(LCO) value to apply the action statement
at the main reservoir level of
215 feet instead of the TS value of 205.7 feet.
The TSI had been in
place since June 28,
1995 and was currently at Revision 3.
Each
revision had been reviewed by the Plant Nuclear Safety Committee
and
approved
by plant management.
The TSI was corrective action for a
problem found during performance of a Service Water System Operational
Performance
Inspection.(SWSOPI)
conducted
by the licensee.
TSI Basis
The TSI-basis
was documented in Inspection Report 50-400/96-09.
The
report documented
the inspector 's review of licensee'ngineering
Service
Requests
(ESRs),
Adverse Condition and Feedback
Reports
(ACFRs),
(UHS) and 3.7.4 (ESW),.and the associated
TS bases.
The licensee
discovered during the resolution of a
SWSOPI question
related to UHS temperature that although the TS 3.7.5
LCO main reservoir
level of 205.7 feet was adequate
volume to dissipate the design heat
load over
a 30-day period (stated in TS Bases),
the level
was not
adequate
for the emergency service water system to provide sufficient
flow for all components to remove the design heat generated.
Since
an
ESW pump upgrade could not be immediately accomplished to increase
flow,
an a'lternative that was immediately put in place
was to raise the limit
on reservoir level.
A calculated reservoir level of 215 feet was
determined to provide adequate
flow to maintain all components
serviced
This administrative limit was put in place through the
TSI.
The inspector 's review of PNSC meeting minutes for the TSI found
that the licensee felt the TSI required them to apply the
LCO "ear ly" as
compared to the TS value and therefore the interpretation
was more
conservative
than TS.
No discussion of a license
amendment/TS
change
was documented.
ESR 9500548,
issued August 25,
1995.
concluded that the 215 feet
elevation main reservoir administrative limit (TSI) needed to be
maintained to ensure operability of some
ESW components.
The inspector
found that later
and design calculations
used the 215 feet
elevation
as
an assumption
and did not support retracting that limit.
The
FSAR change
markup in the
ESR did not include the 215 feet elevation
administrative limit.
The inspector
reviewed
FSAR section 2.4.11.7,
Heat Sink Dependability
Requirements,
FSAR section 9.2.1, Service Water System,
and
FSAR section
9.2.5, Ultimate Heat Sink.
None of the
FSAR sections
mentioned the main
reservoir level needing to be 215 feet to provide adequate
ESW flow for
heat removal.
These sections
were changed
by Amendment 46. submitted
April 12,
1996, to include many of the results
from the
SWSOPI question
on this issue.
ESR 9500707,
issued January
17,
1996, provided the basis
for the
FSAR changes to those sections
and included those from ESR
9500548,
but made
no mention of the 215 feet level.
The safety
evaluation for ESR 9500707 concluded that
a license
amendment
was needed
for UHS temperature.
No change
was discussed
for level.
On Hay 21,
1996, licensee
management
authorized the regulatory affairs
organization to develop
a TS change that enco'mpassed
TSI 95-003.
The
10
licensee
had not made
any meaningful progress
on the change prior to the
inspector discussing
the issue,
as documented in IR 50-400/96-09.
The
inspector
found that the licensee did not recognize that the TS did not
meet the definition of LCO in 10 CFR 50.36.
Re ulator
Im act
10 CFR 50.36 states that
LCOs are the lowest functional capability or
performance levels of equipment required for safe .oper ation of the
facility.- The inspector
found from review of the licensee's
calculation
and engineering evaluations that the TSI values were those values
required'by
10 CFR 50.36 for the TS.
The licensee initiated
administrative controls
(TSI) on June 28,
1995, that would have
pr'evented the plant from exceeding the design basis.
These controls
were in place for approximately
15 months prior to the inspector raising
this issue.
Hain reservoir
level
was never below the revised design
basis value during the life'of the plant.
10 CFR 50. Appendix B, Criterion XVI requires that conditions adverse to
quality be promptly identified and cor rected.
Procedure
AP-615,
Condition Reporting,
Revision 20, identifies non-compliance with
regulations
as
an adverse condition.
The licensee
did not promptly
submit
a change to TS 3.7.5.
Consequently,
the failure to promptly
revise
TS 3.7.5'to ensure that the
LCO was the limit for the lowest
performance
level of the ultimate heat sink and emergency service water
system is considered
a violation of 10 CFR 50, Appendix B, Criterion XVI
(50-400/96-10-01).
10 CFR 50.71(e) states that
FSARs shall
be updated annually or 6 months
after each refueling outage.
The revision must reflect all changes
up
to a maximum of 6 months prior to the date of'iling.
FSAR Amendment 46
updated the
FSAR relative to the ultimate heat sink temperature
and
emergency service water
component flows, but did not include information
relative to main reservoir level.
The minimum main reservoir level
had
been determined to be 215 feet instead of the 205.7 feet main reservoir
limit discussed
in FSAR section 2.4.11.7
and TS 3.7.5.
The 215 feet
level is important because it is the level that provides the minimum
flow required for all
ESW components to be operable.
Consequently,
the
failure to adequately
update the
FSAR for main reservoir level in
Amendment 46 is considered
a violation of 10 CFR 50.71(e)
(50-400/
96-10-02).
Licensee Corrective Actions
The inspector
found that the licensee
was adequately
pursuing corrective
action of the technical
issue
from a hardware standpoint including
modifications during the upcoming outage
(RF07) to replace the "B" ESW
pump with a larger capacity
pump and to enlarge the containment
fan
cooler orifices to allow greater flow.
The replacement of the "A" pump
is scheduled for the following outage
(RF08).
The licensee
submitted
a
TS change
request
on October 31,
1996.
and intends to revise the
FSAR to
include all the information in the TSI.
The licensee
performed
a review
of other TSIs and developed
a plan (November 12,
1996) to reduce the
total
number of TSIs to less than 10.
The licensee
also intends to
'revise the administrative controls for TSIs in procedure
AP-107.
Conclusions
The inspector
concluded that the licensee
had vigorously pursued the
design problem when it was discovered in 1995.
The licensee
promptly
ut in place the administrative limit to control main reservoir level.
owever,
a violation of 10 CFR 50 Appendix B Criterion XVI had occurred
in that
a TS change
was not promptly submitted to revise
In
addition,
FSAR Amendment 46 failed to identify that
UHS main reservoir
level could not go below 215 feet and
ESW perform its design function.
This was considered
a violation of 10 CFR 50.71(e) for not adequately
updating the
FSAR for main reservoir level in Amendment 46 to reflect
the current design basis of the plant.
This unresolved
item is closed.
IV~ Plant
Su
rt
R1
Rl. 1
P1
P1.1
Radiological Protection
and Chemistry
(RP&C) Controls
General
Comments
71750
The inspector
observed radiological controls during the conduct of tours
and observation of maintenance activities and found them to be
acceptable.
The general
approach to the control of contamination
and
dose for the site was good.
Teamwork between the various departments
continued to be
a major contributor to the good control of dose.
The inspector
observed the Post Accident Sampling System quarterly
sample using procedure
CRC-821, Post-Accident
RCS/RHR sampling,
Revision
18.
The drawing of the sample
by the chemistry technicians
was used
as
training.
The procedure
was followed and performance
was good.
Conduct of EP Activities
General
Comments
71750
The licensee
has evaluated their emergency
response
organization
assignments
and has
made
a number of changes.
Training drills and table
top sessions
were planned to train the personnel
in the new positions.
This indicates
a positive management
commitment to the performance of
the emergency
response
function.
The inspector
observed portions of a
training drill conducted
on November 7, 1996.
The scenario
was the
same
challenging scenario
described in Inspection Report 50-400/96-06.
These
training drills were considered
a good way for site emergency
response
personnel
to gain experience.
The inspector also attended the Harris Task Force meeting
on October 30,
1996.
The Harris Task Force consisted of representatives
from each of
the affected county governments,
state
government,
and CP8L personnel.
S1
Sl.l
F1
The task force jointly addresses
Harris site emergency
preparedness
issues that affect the local area.
Conduct of Security and Safeguards Activities
Gener al
Comments
71750
The inspector observed security and safeguards activities during the
conduct of tours, observation of maintenance activities,
and the
emergency
preparedness drill, and found them to be good.
Compensatory
measures
were posted
when necessary
and properly'onducted.
Control of Fire Protection Activities
Fl.1
General
Comments
71750
The inspector inspected fire protection equipment
and observed
activities during the conduct of tours
and observation of maintenance
activities on this equipment
and found them to be acceptable.
V. Mana ement Meetin s
X1
Exit Meeting Sugar y
The inspectors
presented
the inspection results to members of licensee
management
at the conclusion of the inspection
on November 26,
1996.
The licensee
acknowledged the findings presented.
The inspectors
asked the licensee
whether any of the material
examined
during the inspection should be considered proprietary.
No proprietary
information was identified.
13
PARTIAL LIST OF PERSONS
CONTACTED
Licensee
D. Alexander,
Supervisor,
Licensing and Regulatory Programs
D. Batton, Superintendent,
On-Line Scheduling
D.
Br aund,
Superintendent,
Security
B. Clark, General
Hanager,
Harris Plant
A. Cockerill, Superintendent,
IKC Electrical
Systems
J. Collins, Manager, Training
J.
Dobbs,
Manager,
Outage
and Scheduling
J.
Donahue,
Director Site Operations,
Harris Plant
R. Duncan,
Superintendent,
Hechanical
Systems
W. Gautier,
Manager,
Maintenance
W. Gurganious,
Superintendent,
Environmental
and Chemistry
H, Hamby, Supervisor,
Regulatory Compliance
H. Hill, Manager,
Nuclear
Assessment
D. HcCarthy, Superintendent,
Outage
Management
K. Neuschaefer,
Superintendent,
Radiation Protection
W. Peavyhouse,
Superintendent,
Design Control
W. Robinson,
Vice President,
Harris Plant
G. Rolfson,
Manager, Harris Engineering Support Services
S. Sewell,
Manager,
Operations
T. Walt, Hanager,
Performance
Evaluation
and Regulatory Affairs
NRC
T. Le, Harris Project Manager,
H. Shymlock, Chief, Reactor Projects
Branch 4
IP 37551:
IP 61726:
IP 62707:
IP 71707:
IP 71750:
IP 90712:
IP 92700:
IP 92903:
14
INSPECTION
PROCEDURES
USED
Onsite Engineering
Effectiveness of Licensee Controls in Identifying, Resolving,
and
Preventing
Problems
Surveillance
Observations
Haintenance
Observation
Plant Operations
Plant Support Activities
In Office Review of Written, Reports of Non Routine Events at Power
Reactor Facilities
Onsite Followup of Events
Followup - Engineering
~Qened
50-400/96-10-01
50-400/96-10-02
Closed
ITEHS OPENED,
CLOSED,
AND DISCUSSED
Failure to Promptly Submit
a Technical Specification
Change for Hain Reservoir
Level (paragraph
E8.1)
Failure to provide an up-to-date
FSAR Amendment for
Hain Reservoir Level (paragraph
E8.1)
50-400/95-012-00
LER
Containment Pre-entry
Purge Valve Drifted Open
(paragraph
08.1)
50-400/95-014-00
LER
Residual
Heat Removal
Check Valve Testing when Valves
Required for Operability (paragraph
H8.1)
50-400/94-001-00
LER
Inadequate
Surveillance
Procedure for Slave Relay Test
(paragraph
H8 ~ 2)
50-400/96-09-03
Discussed
None
UHS/ESW Technical Specification Interpretation
(paragr aph E8.1)