ML18016A182
| ML18016A182 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/29/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18012A885 | List: |
| References | |
| 50-400-97-08, 50-400-97-8, NUDOCS 9709150161 | |
| Download: ML18016A182 (54) | |
See also: IR 05000400/1997008
Text
U. S.
NUCLEAR REGULATORY COHHISSION
REGION II
Docket No:
License
No:
50-400
Report
No:
50-400/97-08
Licensee:
Carolina
Power
8 Light (CP8L)
'Facility:
Shearon Harris Nuclear Power Plant, Unit 1
Location:
5413 Shearon Harris Road
New Hill, NC 27562
Dates:
June
22
- August 2,
1997
Inspectors:
J. Brady, Senior
Resident
Inspector
D. Roberts,
Resident
Inspector
G. HacDonald, Project Engineer
(Sections
H8.2, H8.5,
H8.6)
R. Chou,
Region II Reactor
Inspector
(Section 01.5)
B. Rankin, Senior Project
Hanager
(Sections R1.1-
R1.4)
Approved by:
H. Shymlock, Chief, Projects
Branch 4
Division of Reactor Projects
9709i50ibi 970829
ADOCK 05000400
8
Enclosur e 3
EXECUTIVE SUMMARY
Shearon Harris Nuclear
Power Plant, Unit 1
NRC Inspection Report 50-400/97-08
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
announced
inspections
by a regional radiation specialist,
a regional reactor
inspector,
and
a regional project engineer.
0 erations
~
The reactor tripped from 100 per cent power at 2:56 a.m.
on July 20,
1997
due to a failure of the turbine generator
All safety-systems
performed adequately.
(Section 01.2)
~
The post-trip review package
was adequate.
Plant Nuclear Safety
Committee discussions
about the package
were good, but
some attention to
detail
was lacking in that the package
provided to the
PNSC was not the
final package
ready for
PNSC review and signature.
(Section 01.3)
~
Operator performance for the July 25
- 26,
1997 start-up
was generally
adequate.
The synchronization to the grid was not as
smooth
as the
previous start-up.
(Section 01.4)
~
The licensee
performed
adequate
operations for the lifting,
transporting,
and unloading of a cask from the rail car to the spent
fuel pool. (Section 01.5)
Maintenance
Haintenance
and surveillance testing observed
were adequately
conducted.
(Sections Ml.l and M2.1)
An apparent violation was identified f'r a programmatic
problem
concerning deficient Technical Specification surveillance testing
procedures.
(Sections
M8.2 through M8.7)
A Non-Cited Violation was identified against
10 CFR 50.73 f'r two late
Licensee
Event Reports associated
with the apparent violation for TS
surveillance
procedure deficiencies.
(Sections
M8.2 and M8.4)
En ineer in
~
Two additional
examples
were identified where modification packages
did
not consider
associated
alarms during the design process.
The affected
alarms were the rod insertion limit alarm and
a computer
room
ventilation alarm.
These
examples
resulted in nuisance
alarms in the
control
room.
(Section E1.1)
2
~
A deviation from the corrective action for violation 50-400/96-01-01
and
Licensee
Event Report 96-001-00
was identified in relation to not
alarming Reactor Auxiliary Building Emergency
Exhaust
System doors
as
committed to. (Section E8.4)
Plant
Su
ort
~
Primary and secondary
chemistry parameters
were maintained well within
Technical Specification
and licensee administrative limits.
The water
chemistry control program was effectively implemented.
(Section R1.1)
~
The licensee
maintained
an effective program to control radioactive
effluents
and thereby limited doses to members of the public to a small
percentage
of regulatory limits.
The release of radioactive material to
the environment
was
a small fraction of regulatory limits (Section R1.2)
~
The radiological controls program was effectively implemented with good
occupational
exposure controls observed during normal plant operating
conditions.
(Section R1.3)
~
One Non-Cited Violation was identified for failure to control
contaminated
material in accordance
with procedure.
(Section R1.3)
The licensee
implemented
an effective program for packaging,
preparation,
and transport of radioactive material
and conducted the
program without incident.
(Section R1.4)
One violation was identified for failure to conduct
49 CFR 172 Subpart
H
training with training materials that matched current performance
requirements.
(Section R1.4)
~
Fire protection equipment
and activities observed
were acceptable.
The
licensee
was making progress in r educing the number of fire protection
surveillances
being performed in their grace period.
Re rt Details
Summar
of Plant Status
Unit 1 began this inspection period at 100 per cent power.
The unit tripped
from 100 per cent power on July 20,
1997 due to
a failur e of the turbine
generator
The exciter was replaced
and the unit went critical on
July 25,
1997.
Synchronization to the grid occurred
on July 26,
1997.
The unit reached
100 percent
power the next day and continued at 100 percent
power for the remainder of the period.
I. 0
rations
01
01.2
a.
Conduct of Operations
General
Comments
71707
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.
Reactor Tri
Ins ection Sco
e
93702
b.
C.
The inspector
reviewed plant response to the reactor trip from
100'ower
that occurred at 2:56 a.m.
on July 20,
1997.
Observations
and Findin s
The inspector
found that the trip was due to a turbine trip on generator
lockout.
This occur red due to
a fault in the generator exciter.
The
pumps started
as designed
on low-low level in all
three
Operators
responded to auxiliary feedwater flow
when average
reactor
coolant system
(RCS) temperature
dropped below 557
degrees
Fahrenheit
by reducing flow to limit the cooldown as described
in the Emergency Operating
Procedure
EPP-004,
Reactor Trip Response,
Revision 7.
Average
RCS temperature
bottomed out at 547 degrees
Fahrenheit.
Numerous fans/air handlers
and radiation monitors tripped
due to the voltage transient that occurred with the generator
problem.
The inspector
observed that operators
responded to the alarms per the
alarm response
procedures
and operating procedures.
Conclusions
All safety systems
responded
as designed.
Operator
response
was in
accordance
with plant procedures.
0
Post-tri
Review
Ins ection Sco
e
71707
The inspector
reviewed the post-trip review for the reactor trip that
occurred at 2:56 a.m.
on July 20,
1997 to determine if the cause of the
trip was addressed
and if procedure
OHH-004, Post-trip/Safeguards
Actuation Review, Revision 8/2,
was followed.
Observations
and Findin s
The inspector
observed the failed main generator exciter
and attended
licensee
meetings related to determining the cause of the exciter
failure.
The inspector
observed that the licensee
analyzed operating
experience for other plants that have
had exciter failures.
In
addition, the manufacturer of the exciter participated in the
investigation.
The inspector
found that the reactor trip root cause
discussions
were thorough
and were participated in by many levels of
site management.
A new exciter
was purchased
from the manufacturer
and
installed prior to startup.
The post-trip review addressed
the cause of the reactor trip and the
cause for the various equipment
problems.
The reactor trip was due to
tur bine trip on generator
lockout.
The equipment
problems
were due to
the voltage transient
caused
by the exciter failure.
The inspector
found all alarms that occurred
due to the trip adequately
evaluated
and
explained in the post-trip review package.
In addition, all equipment
that stopped
or
changed state after the trip was adequately
analyzed
and
explained in relation to the voltage transient.
The inspector
found one administrative error in the Reactor
Trip/Safeguards
Actuation Report which is Attachment
1 to the post-trip
review package.
In Section 1.5, Annunciators,
the reactor "first outs"
were listed.
One of the first outs was listed as
ALB 12 4-3 (Alarm
Light Box 12, window 4-3)
and was described
as
"RX trip Power Range
Hi
Flux trip".
The inspector
confirmed that this alarm was not
a power
range high flux trip but a power
range high flux rate trip, which was
an
expected
alarm on
a reactor trip due to the inward rod motion.
This
documentation
error
had no safety significance.
The inspector
attended
the Plant Nuclear Safety Committee
(PNSC) meeting
on July 30,
1997 where the post-trip review package
was discussed.
Procedure
OHH-004 describes this review under Section 5.4, Follow-up
Review.
The PNSC's
agenda
was to review and approve the post-trip
review package.
The version
reviewed by the
PNSC did not contain the
restart
authorization signatures
and did not contain the administrative
correction described
above that the inspector pointed out on July 25,
1997.
The missing signatures
were noted by several
PNSC members,
but
the administrative error was not detected.
The inspector
observed that,
despite the administrative errors,
the discussions
by the
PNSC
member s
were good and the cause of the trip and corrective actions
were
thoroughly discussed.
c.
Conclusions
The inspector
concluded that the post-trip review was adequate.
PNSC
discussions
were good, but
some attention to detail
was lacking in that
the package
provided to the
PNSC was not the final package
ready for
PNSC review and signature.
oi.4
~Uit St t
a.
Ins ection Sco
e
71707
The inspector
observed the unit startup to determine if procedures
were
followed.
Procedures
GP-4,
Reactor
Startup
(Mode 3 to Mode 2), Revision
16,
and GP-5,
Power Operation
(Mode 2 to Mode 1), Revision 17,
governed
these activities.
b.
Observations
and Findin s
The inspector
observed that procedures
were followed during the reactor
startup.
Reactor
startup
occur red on July 25,
1997 and the unit was
synchronized to the grid on July 26,
1997.
Synchronization
was not as
smooth
as the last startup
(June 9,
1997, described in Inspection Report
50-400/97-06).
The inspector noticed that the synchronization
was
accomplished
at about 6.5 percent indicated reactor
power
as compared to
the 8-9 percent
power
on June 9,
1997.
The inspector
observed that
operators
were using diverse indications
and controlling power based
on
the highest indication.
Loop delta temperature
was the highest
indication of reactor
power (8 percent)
which was used for the
.
synchronization
instead of nuclear instrumentation.
Synchronization at
a higher power allows for a smoother
transfer of steam
demand
from the
condenser
steam
dumps to the turbine generator.
The inspector observed
that the turbine picked up approximately 60-65 megawatts
instead of the
planned
45 megawatts.
The additional
load also contributed to the
rougher transfer.
The inspector
also noted that operators
kept feedwater regulating valves
in manual until 30 percent
power.
These valves are normally placed in
automatic at approximately 20 percent
power.
There were no particular
problems identified with the performance of the valves during the
startup.
The inspector considered this an anomaly that was picked up by
the oncoming shift, which immediately placed the valves in automatic.
c.
Conclusions
Operator
performance for the July 25
- 26,
1997 start-up
was gener ally
adequate.
The synchronization to the grid was not as smooth
as the
previous start-up.
4
01.5
S ent Fuel
Cask Unloadin
0 eration
a.
Ins ection Sco
e
86700
The inspectors
observed portions of the spent fuel cask unloading
oper ation (from the rail car to the spent fuel pool) to verify that the
activities were performed in accordance
with applicable procedures.
b.
Observations
and Findin s
The licensee
found an unreviewed safety question in regard to some steps
of the cask operations
as submitted in a letter dated
Harch 14,
1997 and
as reported in LER 97-004-00.
During cask lifting and movement,
an
increase
in radiation could occur if casks
were dropped with only 4 of
the 32 head closure bolts installed and/or with the valve cover s
removed.
A cask drop without all 32 bolts installed and/or
the valve
cover protection in place
was not analyzed
and documented in the
and became
an unreviewed safety issue.
The licensee evaluation
was
approved
by NRC on June 26,
1997, allowing cask operations to resume.
No procedure
changes
were required.
The procedures
used in the unloading operation for the spent fuel casks
transported
from Robinson Nuclear Plant,
another nuclear
power plant of
Carolina
Power
and Light Company, to Harris Nuclear Plant were:
~
Procedure
Spent
Fuel
Cask Handling (IF-300 Cask),
Rev.
20.
~
Procedure
FHP-014,
Fuel
and Insert Shuffle Sequence,
Rev,
12
~
Procedure
FHP-040,
RNP (Robinson)
Spent
Fuel Handling Operations,
Rev.
2
The inspectors
observed
the licensee
perform the following activities
for the cask unloading:
Lifting and transporting the cask from the rail car at the rail
bay to the decontamination pit
Preparation
and radiation level survey for cask unloading
Detention
and removal of all but four cask
head closure bolts,
leaving one in each quadrant
90 degrees
apart
Lifting the cask from the decontamination pit into the isolated
unloading pool
Removing the cask closure
head
and storing it inside the
decontamination pit
Unloading the spent fuel assemblies
through the transfer canals
into the assigned cells in the spent fuel pool
B
The licensee
followed approved written procedures
for the cask movement.
The lifting, transporting,
detensioning,
and unloading of the cask
proceeded
without incident.
The inspectors
also reviewed the data
recorded in the working copy of the procedures
and found them to be
adequate.
Conclusions
The inspectors
concluded that the licensee
performed adequate
operations
for the lifting, transporting,
and unloading of the cask from the rail
car to the spent fuel pool.
Licensee
Self-Assessment
Activities
40500
During the inspection period, the inspectors
reviewed multiple licensee
self-assessment
activities, including:
~
Plant Nuclear Safety Committee
(PNSC) meetings
on July 2,
1997;
July 16,
1997 and July 30,
1997;
~
Plant Review Heeting on July 31,
1997
~
Condition Reports
Self-assessment
activities were adequately
performed.
The Plant Review
Heeting on July 31,
1997 was attended
by upper level corporate
management
and was very probing in relation to site problems
and the
corrective actions being taken.
Hiscellaneous
Operations
Issues
(92901)
Closed
VIO 50-400/96-11-01:
Failure to follow procedure for chart
recorder
marking and temperature
monitoring.
The inspector
reviewed the licensee's
response
dated
Harch 3,
1997 and
reviewed the corrective actions taken.
Example
1 related to char t
recorders
not marking and operators
signing the chart during that
period.
Several felt tip pen installations
were reviewed in inspection
report 50-400/97-06.
The felt tip pen modification improved the
reliability of the marking pens.
Several
additional
instances of not
properly marking chart recorders
was identified by the licensee's
Nuclear Assessment
Section
on April 2,
1997
(CR 97-01417).
Corrective
action included counseling.
The inspectors
have observed
improved
performance
by both operators
and site management
in relation to the
recorder problems.
Example 2 involved operators
not adequately
responding to temperature
monitoring alarms.
The licensee
revised procedure
APP-111,
Freeze
Protection
and Temperature
Haintenance,
Revision 8, procedure,
OP-
161.01,
Revision 3,
and procedure
OHH-002, Shift Turnover Package,
Revision 11, to provide definitive guidance to
r adwaste control
room
operators,
main control
room operators,
and building operators.
The
guidance
was to ensure that the building operator
knew when alarms were
locked in so that more frequent monitoring of the temperature
monitoring
panels
could be conducted.
The inspector
verified that these
changes
were made.
The inspectors
have also observed shift turnovers to verify
that procedural
requirements
were implemented.
The number of logged operator workarounds
increased
from 13 to 39
shortly after the violation was identified indicating
a new employee
sensitivity to plant deficiencies.
This item is closed.
Ml
Conduct of Maintenance
Ml.1
Gener al
Comments
II. Maintenance
a.
Ins ection Sco
e
62707
The inspectors
observed all or portions of'he following work
activities:
WR/JO 97-AGYJ1
WR/JO 95-AKIB1
WR/JO AGGY-001
WR/JO AKFR-002
WR/JO ANPF-001
"8" Emergency
Ser vice Water
expansion joint
replacement
M-12 Digital Rod Position Indication problems
"A" Charging/Safety Injection Pump
(CSIP)
speed
changer coupling inspection
Calibrate stop-auto-start
differential pressure
switch for "A" CSIP
Inspect
and Clean
"A" Emergency Diesel Generator
jacket water heat exchanger
b.
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.
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.
c.
Conclusions
The maintenance
observed
was adequately
conducted.
7
Maintenance
and Material Condition of Facilities and Equipment
Surveillance Observation
Ins ection Sco
e
61726
The inspectors
observed all or portions of the following surveillance
tests:
HST-I0151, Nuclear
Instrumentation
System Source
Range
N32
Calibration, Revision
5
OST-1007,
CVCS/SI System Operability Train A Quarterly Interval
Modes 1-4, Revision
10
OST-1073,
1B-SB Emergency Diesel Generator
Operability Test
Monthly Interval
Modes 1-6, Revision
10
HST-I0320, Train
B Solid State Protection
System Actuation Logic 5
Master Relay Test,
Revision
15
Observations
and Findin s
The inspector
found that the testing
was adequately
performed.
Conclusions
The surveillance
performances
were adequately
conducted.
Miscellaneous
Maintenance
Issues
(61700,
92700,
92902)
Closed
LER 50-400/95-015-00:
Failure to identify Engineering Safety
Features
response
time testing requirements
during
a modification to the
flow control valve circuitry for the Motor Driven Auxiliary Feed
Water
pumps.
This
LER discussed
the failure to perform required response
time testing
for the motor-driven auxiliary feedwater
(HDAFW) flow control valves
after they were modified in 1994 to include an automatic
open feature
upon receiving
an Engineer ed Safety Features
Actuation System
(ESFAS)
signal.
As
a result of the
new automatic feature,
response
time testing
was required for these
valves by Technical Specification 4.3.2.2.
This
item was discussed
previously in NRC inspection report 50-400/96-01 at
which time a Non-cited Violation-was issued.
The
LER remained
open at
that time pending the licensee's
completion
and
NRC inspectors'eview
of corrective actions.
The licensee's
corrective actions included
revising procedures
OST-1044,
ESFAS Train A Slave Relay Test Quarterly
Interval
Modes
1
- 4 and OST-1045
ESFAS Train B Slave Relay Test
Quarterly Interval
Hodes
1
- 4 to incorporate the testing.
The
inspectors verified that all corrective actions
had been completed
and
that the valves responded satisfactorily during the most recent
response
time test in refueling outage
7.
This
LER is closed.
H8.2
Closed
LERs 50-400/96-002-00
96-002-02
96-002-03
96-002-04
96-002-05
96-002-06
96-002-07
96-002-08
96-002-09
96-002-10
96-002-11
96-002-12
and 96-002-13:
Failure to properly perform
Technical Specification surveillance testing.
0 en
LER 50-400/96-002-01:
Failure to properly perform Technical
Specification surveillance testing.
The technical
aspects of the above
LERs have all been discussed
in
detail in previous
NRC inspection reports.
They all involved long-
standing deficiencies in the original procedures
used to test safety-
related logic circuits or, in a few 'cases,
problems resulting from
inattention to detail during the procedure
change
process.
Collectively, these
procedural
deficiencies
represented
a programmatic
problem.
Since
1994, the licensee
has reported to the
NRC approximately
50 surveillance
procedure deficiencies that resulted in Technical
Specification violations.
Back round
'The licensee initially began finding problems with safety-related
logic
circuit testing in 1994.
The earlier findings were few in number
and
were considered to be isolated cases.
In mid-1995, the licensee
discovered
several
examples of missed testing requirements
prompting
a
comprehensive
TS surveillance
review which identified 36 additional
reportable violations of TS surveillance
requirements.
These
36
examples
were reported in LER 50-400/96-002
and its 13 supplements.
Hany of the procedural
deficiencies
were caused
by a lack of
understanding of logic test requirements
with respect to testing
parallel
or
over lapping logic circuit paths.
Hany of the missed testing
requirements
were not explicitly described
in the Technical
Specifications
(TS), but involved components
whose operations
were
crucial to the function being tested,
and were therefore implicit in the
TS requirements.
In some cases,
where two or
more independent circuits
caused the
same actuation,
the licensee's
procedures
had not verified
each circuit individually by isolating the other paths during the test.
In other instances,
components that received indirect actuation signals
from auxiliary relays following master
or slave relay actuations
were
not being verified to operate.
The
NRC had issued previous enforcement
actions for some of the findings
including Violations 50-400/95-02-01
and 50-400/96-11-02.
These
violations were either NRC-identified (96-11-02)
or required significant
NRC involvement before the licensee
implemented the appropriate
corrective actions
(95-02-01).
As mentioned in paragraph
H8.1 above,
a
Non-Cited Violation was issued in 1995 for failing to perform response
time testing
on
HDAFW flow control valves following a 1994 modification
to the valves.
The remaining
1994 and 1995 items were reported in LERs 50-400/94-001-
00, 95-003-00,
and 95-007-00.
These involved a total of seven
violations of TS surveillance
requirements
which were all licensee-
identified and involved testing deficiencies that existed since the
rocedures
were originally developed.
In LER 50-400/95-007,
the
icensee
committed to its comprehensive
review of Technical
Specification Surveillance
Requirements.
The three
LERs were previously
closed in Inspection Reports
50-400/96-10
and 50-400/97-06 after the
licensee's
corrective actions for the specific deficiencies
were
verified by the inspectors to be completed.
A total of 43 reported
items appeared
in LERs 50-400/94-001-00,
95-003-
00, 95-007-00,
96-002-00,
and related
LER supplements.
Forty-two of
those were related to deficient surveillance test procedures.
The
following table list each reported
TS violation and related
TS
requirement in order
by LER number.
Item
No.
94-001-00
95-003-00
95-007-00
Item sequence for multiple examples in same
LER included in parentheses
(). Item sequence for LER 96-002 based
on licensee's
assigned
numbers
(l)-(35) for items reported in all 13 supplements.
Descri tion of Issue or item not tested:
Equipment drain isolation valve lED-121 was not verified
to isolate during slave relay K623 testing in accordance
with TS 4.3.2.1.
(1) Emergency service water
room coolers
AH-86A and AH-
86B and related cooling coil isolation valves
(1SW-1000,
and 1HP-71) were not tested
by
auxiliary starting contacts
er
(2)
For
screenwash
valve 3SC-41,
a portion of the circuit
was not tested
per
due to installation or
removal of jum ers during test.
pump and containment
spray suction
valves
(1CT-102 and 105) contacts
were not properly
verified to o crate
er TS 4.3.2.1.
(4) Hain feedwater preheater
bypass isolation valve
solenoids
were not tested
per
TS 4.3.2.1 by independent
"A" and "B" train actuations.
(5) K601 slave relay for emergency diesel
generators
(EDGs) was not properly verified during Safety Injection
(SI) actuation testing
er TS 4.8.1.1.2.
Trip Actuation Device Operational
Testing
(TADOT) was not
performed for 86UVX relay that started the turbine-driven
(AFW) pump as required by TS 4.3.2.1.
10
Item
No.
10
12
13
16
17
18
96-002-00
96-002-01
96-002-02
96-002-03
96-002-04
Item sequence for multiple examples in same
LER included in parentheses
(). Item sequence for LER 96-002 based
on licensee's
assigned
numbers
(1)-(35) for items reported in all 13 supplements.
Descri tion of Issue or item not tested:
Slave relay testing
was not performed for high head SI
pump alternate miniflow motor-operated
valves
and 752)
er TS 4.3.2.1.
(1)
HDAFW pump
FCV automatic
open feature
from slave
relays
K635 and K640 was not tested
quarter ly per TS 4.3.2 '
after feature
was added in 1994.
(2) SI
8 Containment
Spray manual actuation switches
were
not tested
per TS 4.3.2.1
(due to their redundant
switches being tested exclusively during each refueling
outage).
(4) Loss-of-power isolation feature
was not tested
for
six radiation monitors
er TS 4.3.3.10
'5)
Overlap circuit for Fuel Handling Building
ventilation actuation
on high radiation signal
from
radiation monitor RN-FR-3567A-SA was not tested
per
TS 4.9 '2.
(6) Control
Room emergency filtration fans
(R2-A and
B)
parallel
paths
from high radiation start circuit was not
tested
er TS 4.3.2.1.
(7) Thermal overload bypass
feature
was not verified per
TS 4.3.2.1 for the Reactor Auxiliary Building electrical
equipment
room inlet isolation dampers
(1CZ-7 and 8)
associated
with isolation from Control
Room Ventilation
Isolation Signal.
(8) TADOT for main feedwater
pump trip on SI signal did
not test partial section of wiring in accordance
with TS 4.3.2.1,
due to lifting leads
or installing jum ers.
(9) For certain radioactive effluent monitors for
building ventilation stacks,
the channel
out-of-ser vice
and Control
Room alarm inputs were not tested in
accordance
with TS 4.3,3.11.
(10) Fourteen blocking relays (that block non-emergency
control signals
from actuating affected
components)
associated
with sequencer
panels
were not tested
per TS 4.8.1.1.2.
(11) Post-accident
(CV-D1,3,5,
and 7) for
containment building fan coolers were not verified full
open (verified "not closed" instead)
in accordance
with
11
Item
No.
19
96-002-05
20
21
22
23
24
96-002-06
25
26
27
28
96-002-05
29
96-002-06
30
Item sequence for multiple examples in same
LER included in parentheses
(). Item sequence for LER 96-002 based
on licensee's
assigned
numbers
(l)-(35) for items reported in all 13 supplements.
Descri tion of Issue or item not tested:
(12) A start-inhibit feature
(before emergency
sequencer
load block eight) for the chilled water system chillers
was not verified
er TS 4.8. 1.1.2.
(13) Chilled water chillers anti-recyle feature
bypass
was not tested
er
TS 4.8.1.1.2.
(14)
For the containment
spray automatic
sump swapover
logic, Refueling Water Storage
Tank valve limit switch
continuity was not tested for valves
1CT-102 and
105 in
accordance
with TS 4.3.2.1.
(15) Containment
spray suction valves
1CT-102 and
105
actuation
from relay K741 was not tested
per
(only the K731
ath was tested).
(16) Control
Room Dampers
(CK-D7-1 and 2; CK-D4-1 and 2;
CK-D8-1 and 2;
and CK-B11-1 and 2) were not tested
from
K603 relay LControl
Room Isolation Signal
(GRIS)j in
accordance
with TS 4.3.2.1.
(17) Computer
room and communication
room dampers
were
not tested
on Control
Room Isolation Signals in
accordance
with TS 4.3.2.1.
(18) Emergency Safeguards
Sequencer
(ESS) Block 2 and
Block 4 start circuits for containment
spray
pumps were
not verified inde endently
er
TS 4.8.1.1.2.
(19) Electrical breakers
1A3A and
1B3B were not verified
to open following load shed
from the
ESS per TS 4.8 ~ 1 ~ 1.2.
'20)
Gross Failed Fuel Detector isolation on SI actuation
was not verified for valve 1CC-304 in accordance
with TS 4.3.2.1.
(21) Computer
and communication
room dampers
next to the
main control
room (CK-D11-1 and 2; CK-D12-1 and 2) were
not verified properly during GRIS testing (verified "not
shut" vs. "full o en") in accordance
with TS 4.3.2.1.
(22) Certain
EDG loads were not calculated
every 18
months per TS 4.8.1.1
~2.f.8.
However, the additional
loads did not violate any design
or
FSAR limits for the
EDGs.
(23) Several
damper s with indirect signals
from fans were
not verified for control
room area ventilation actuation
in accordance
with TS 4.8.1.1.2.f.
12
Item
No.
31
32
33
34
35
36
37
38
39
40
96-002-07
96-002-08
96-002-09
96-002-10
96-002-11
96-002-12
96-002-13
Item sequence for multiple examples in same
LER included in parentheses
(). Item sequence for LER 96-002 based
on licensee's
assigned
numbers
(1)-(35) for items reported in all 13 supplements.
Descri tion of Issue or item not tested:
(24) A inhibit inter lock circuit was not tested for
rimary shield
8 reactor
su
ort fans
er TS 4.8.1.1.2.f.
(25) Fuel Handling Building emergency
damper automatic
closure feature following high radiation was not tested
for
a parallel
path involving indirect closure
from fans
E12 and
E13 starting in accordance
with TS 4.9.12.
(26)
TADOT was not performed f'r 6.9KV emergency
bus
degraded grid voltage secondary
relays in accordance
with
TS 4'.2.1.
Only primary undervoltage
relays
had been
tested in the
ast.
(27) Emergency Safeguards
Sequencer
(ESS)
LOCA-1 and
LOCA-2 XS actuation relay contacts
and the 2D-2E and
1E-
1F reset contacts
were not tested
er
(28)
ESS timing between load blocks was not adequately
verified
er
TS 4.8.1.1.2.f.3.
(29) Parallel start signals
from either
"A" or "B" train
recirculation fans were not tested for computer
and
communication
room inlet dampers
CK-D7-1 and 2 in
accordance
with TS 4.3.2. 1.
(30) Emergency Service Water
pump room exhaust
fans
(E-88A and B) indirect start signal
from temperature
switch when greater
than 90 degrees
Fahrenheit
was not
tested in accordance
with TS 4.8.1.1.2.
(31) Battery Room Exhaust
Fans
(E-28 and E-29) operation
from a GRIS signal (following an SI actuation)
was not
tested in accordance
with TS 4.3.2.1.
(32) An indirect start signal
from AH-5A and
5B fans was
not tested for the main control
room normal supply inlet
dam ers
(CZ-D1SA and
D2SB)
er TS 4.3.2.1.
(33)
HDAFW pump pressure
control valves were not verified
per TS 4.7.1.2 to control pressure
(at runout conditions)
following AFW actuation.
They were previously tested
after flowrate
had already
been adjusted.
(34) Independent verification of Train "A" vs. Train "B"
logic for tripping non-emergency
containment building
fans following a Phase
"A" isolation (slave relay K622)
was not performed in accordance
with TS 4.3.2.1.
This
also involved valve 1SW-231.
13
Item
No.
Item sequence for multiple examples in same
LER included in parentheses
(). Item sequence for LER 96-002 based
on licensee's
assigned
numbers
(1)-(35) for items reported in all 13 supplements.
Descri tion of Issue or item not tested:
(35) Parallel circuit paths
were not tested
per TS 4.3.2.1 for slave relays actuating
contairiment building
ventilation isolation components,
including dampers
1CP-4,7,
and 10;
and fans AH-82A and B, AH-81A and B,
and
E-5A and B.
The preceding table included 42 of the total
43 reported items.
Of
those 42,
39 involved procedures
that were deficient since their initial
development after the plant received its operating license.
The other
three were caused
by plant personnel
errors during the procedure
revision process
or because
a plant modification package did not
identify the appropriate testing requirements
for a newly revised
circuit.
The one item not in the above table was reported in LER 50-
400/97-006-01
as example
number 3.
That example involved a personnel
performance
issue which was unrelated to the surveillance
procedure
rogram issue.
LER 50-400/96-002-01 will be reviewed
separ ately at
a
ater
date in relation to surveillance
performance
issues.
Safet
Si nificance
For the 42 procedure-related
deficiencies listed in the table above,
each circuit was either
r etested
or evaluated
as acceptable
based
on
data
from a previously run similar test or an actual
event.
In all of
the retests,
the circuits performed
as required.
Only one set of
components
(two containment
cooler post-accident
failed a
retest,
but those failures were due to lubrication and actuator sizing
roblems with the components
themselves,
and did not involve failed
ogic circuitry.
Re ulator
Si nificance
With one exception, all of the 42 items were reported in accordance
with
requirements
in 10 CFR 50.73.
The one exception
was
an item (Example
21
in LER 50-400/96-002-05)
for which the licensee identified that they
missed the 30-day reporting requirement.
The TS non-compliance
was
identified on February 26,
1996 and reported
on May 16,
1996.
The late
LER was caused
by personnel
error within the organization responsible
for communicating/resolving potentially reportable
items generated
from
the comprehensive
logic review.
Proper corrective actions were taken
for the late reported item.
Failure to report the TS non-compliance
within 30 days of identification was considered
a violation of
This licensee-identified
and corrected violation is being
treated
as
a Non-Cited Violation, consistent with section VII.B.1 of the
Enforcement Policy (NCV 50-400/97-08-01).
14
The 42 logic circuit testing deficiencies
were considered in the
aggregate
to represent
a programmatic
problem in the area of
surveillance test procedures.
This problem primarily existed
because of
a common misunderstanding
of TS testing requirements
among site
personnel
responsible for developing,
reviewing,
and revising the
affected test procedures.
This lack of understanding
was carried
forward through years of plant oper ation until industry generic
communications
and
a heightened
sense of awareness
among licensee
personnel
resulted in the identification of several
related findings in
1994 and 1995.
Technical Specification 6.8.1.a
and Regulatory Guide 1.33, Appendix A,
Section 8.b requires that written procedures
shall
be established,
implemented,
and maintained for each surveillance test,
inspection,
or
calibration listed in the Technical Specifications.
Technical Specification 4.0.1 requires that Surveillance
Requirements
shall
be met
during the Operational
Nodes or other conditions specified for
individual Limiting Conditions for Operation unless
otherwise stated in
an individual Surveillance
Requirement.
This is further delineated in
specific testing requirements
located throughout Technical Specification Sections 3.0 and 4.0, Limiting Conditions for Operation
and Surveillance
Requirements.
TS surveillance testing is an integral part of assuring
that safety systems will perform their intended functions when called
upon during an accident situation.
The licensee's
failure to establish
adequate
surveillance testing procedures
to demonstrate that components
and systems
would perform their intended function was considered
an
Apparent Violation of Technical Specification 6.8.1.a
(EEI 50-400/97-08-
02).
The inspectors
confirmed that corrective
actions
have
been either
completed or planned for all of the reported deficiencies.
Those
procedures
needed before
and during Refueling Outage
7 were revised
prior to being used.
Action items have
been generated
through the
licensee's
corrective action program for outstanding
changes to
procedures
that will not be performed until Refueling Outage
8 (Fall
1998).
All of the above
LERs, with the exception of LER 50-400/96-002-
Ol, are closed.
As stated
above,
LER 96-002-01 will be closed
upon
further
NRC review of the performance
issues
related to example 3.
The licensee's
comprehensive
review of'ogic circuits had been
considered
thorough by the inspectors in Inspection Report 50-400/97-03.
The licensee
has completed its review of logic circuit testing but is
continuing with its comprehensive
review of other Technical
Specification Surveillance
Requirements.
Several
Condition Reports
have
already
been generated
by this continuing review project.
The
inspectors will address
each additional
item as they are identified.
15
Closed
LER 50-400/96-007-00:
Failure to perform Technical
Specification surveillance testing in accordance
with Specification
4.7.6.d.3.
This
LER was associated
with not performing pressure differential
testing of all adjacent
areas to the control
room.
The control
room
must be higher in pressure to assure that leakage during an accident
will be out of the control
room, not into it.
The inspector
reviewed
the corrective actions which included testing the adjacent
areas
per
procedure
OST-9021T,
Temporary Procedure to Heasur e Delta
P between the
PIC Room and Surrounding Areas,
Revision 0,
and revising procedure
OST-
1231, Control
Room Emergency Filtration System,
Revision 6.
An
additional
problem was identified in that the computer
room was capable
of being pressurized,
as described in the
FSAR.
However, this was in
conflict with Technical Specification 3.7.6 in that the computer
room
was not included in the control
room envelope.
The computer
room damper
was failed shut to prevent pressurization
and the area successfully
tested.
A temporary modification was developed to make this
configuration change.
The inspector
reviewed
ESRs 96-00275
and 97-00024
which supported
making the temporary change.
The
ESRs were not prompt
which resulted in the modification being identified as
an additional
item of concern in Violation 50-400/96-11-06 for using clearance
tags
as
a temporary modification (Section E8.3).
The temporary modification was
completed prior to the end of Refueling Outage 7.
The inspector
verified that the corrective actions
were completed.
The inspectors
concluded that the item discussed
in this
LER represented
a longstanding
procedural
deficiency with a similar root cause to that
of the programmatic problem discussed
in Section H8.2 of this report
(licensee
personnel
not understanding
the full scope of'echnical
Specification testing requirements
and
how they were implemented
by
procedures).
The inspectors
considered that this surveillance
procedure
deficiency was identified as
a result of the licensee's
overall
increased
awareness
and sensitivity to literal compliance with Technical
Specification surveillance
requirements.
Because of the similarities
between this example
and the issue discussed
in Section
H8 ~ 2, this
violation of Technical Specifications is considered
another
example of
Apparent Violation 50-400/97-08-02.
The
LER is closed.
Closed
LER 50-400/96-010-00
-01
and -02:
Surveillance testing
deficiencies that caused
past entries into TS 3.0.3.
The original
LER was previously discussed
in Inspection Report 50-
400/96-009.
The
LER described test procedure deficiencies that resulted
in system alignments that rendered
both trains of the Residual
Heat
Removal
(RHR) system inoperable
and both trains of'he Containment
Vacuum Relief System inoperable.
The licensee's
analysis of past
operability concluded that these deficiencies
had caused multiple
inadvertent entries into TS 3.0.3.
In the case of the
RHR system,
the
test methodology incorporated into procedures
in October
1992 resulted
in cross-tying the two redundant
"A" and "B" trains while verifying the
capability of the "A" train
RHR pump discharge
16
The alignment could have resulted in a significant reduction in low head
safety injection flow to the Reactor Coolant System in the event of an
accident.
Procedure
OST-1008,
lA-SA RHR Pump Operability Quarterly
Interval, Revision 8;
and OST-1092,
RHR Pump Operability Quarterly
Interval, Revision 4, were both revised to eliminate the cross-
connecting of the two RHR trains.
In the case of the Containment
Vacuum
Relief System,
a monthly relay actuation logic test for the Containment
Ventilation Isolation System generated
a signal
which blocked the
automatic containment
vacuum relief function of both redundant
vacuum
breakers.
The deficient test procedure
(MST-I0417, Containment
Ventilation Isolation Area Radiation Monitors Relay Actuation Logic
Test,
Revision 5) caused the Containment
Vacuum Relief System to be
inoperable for approximately 45 minutes during each monthly test.
As a
result of this finding, the procedure
was revised to prevent the
inoperability of both trains of the system simultaneously.
LER 50-400/96-010-01
discussed
that the containment
vacuum relief
discrepancy
was initially identified by operator s in 1995.
However,
plant personnel
then did not realize the reportability of short duration
entries into TS 3.0.3 caused
by surveillance testing.
This item
resurfaced
while the licensee
was investigating the
RHR situation.
The
licensee took appropriate corrective actions for the missed
repor tability.
The requirement of TS 3.0.3 were met.
The failure to
report the TS 3.0.3 entries
caused
by MST-I0417 when the problem was
initially discovered in 1995 is considered
a violation of the
requirements of 10 CFR 50 '3.
This licensee-identified
and corrected
violation is being treated
as the second
example of Non-Cited Violation
50-400/97-08-01
discussed
in paragraph
M8.2 above,
consistent with
section VII.BE 1 of the Enforcement Policy.
Concerning the procedural
deficiencies,
the inspectors
concluded that
each
case
was related to the programmatic surveillance
procedure
problem
described in Section
M8.2 above.
Each case
represented
longstanding
~
~
~
roblems with surveillance
procedure technical
content
due to the
icensee's
lack of understanding
as to how these
procedures
implemented
TS testing requirements.
Because of the similarities, the items
identified in LERs 50-400/96-010-00
through
-02 are being included as
additional
examples of Apparent Violation 50-400/97-08-02.
The
LER and
its supplements
are closed.
Closed
LER 50-400/96-016-00:
Failure to perform reactor trip bypass
breaker surveillance testing required by Technical Specifications.
This
LER was associated
with testing the reactor trip bypass breaker's
remote manual
shunt trip feature with the breaker s in service.
Technical Specification
(TS) Table 4
~ 3-1 requires
a remote
manual
trip test prior to placing the reactor tr ip bypass
breakers
in service.
Testing of the remote manual
shunt trip at Harris had been previously
conducted after the reactor trip bypass
breakers
were racked into the
connected position and closed.
FSAR section 7.2.2.2.3.10
contained
conflicting wording regarding the testing.
The inspectors
reviewed the
corrective action which included procedure revision,
FSAR clarification
17
and event review with Haintenance
and Operations
personnel.
Procedures
HST-I0001 (HST-I0320), Train A (B) Solid State Protection
System
Actuation Logic and Haster Relay Test,
Revision 10(11)
and OP-104,
Rod
Control System,
Revision
11 were revised to implement this TS
requirement.
The inspector verified that the corrective actions
were
adequately
completed.
The inspectors
concluded that the item discussed
in this
LER represented
a longstanding
procedural
deficiency with a similar root cause to that
of the programmatic
problem discussed
in Section
H8.2 of this report
(licensee
personnel
not understanding
the full scope of Technical
Specification testing requirements
and
how they were implemented
by
procedures).
The inspectors
considered that this surveillance
procedure
deficiency was identified as
a result of the licensee's
overall
incr eased
awareness
and sensitivity to literal compliance with Technical
Specification surveillance
requirements.
Because of the similarities
between this example
and the issue discussed
in Section H8.2, this
violation of Technical Specifications is considered
another
example of
Apparent Violation 50-400/97-08-02.
The
LER is closed.
Closed
LER 50-400/96-009-00:
Reactor Auxiliary Building Emergency
Exhaust
System testing deficiency.
This
LER was associated
with a failure to verify that Reactor Auxiliary
Building Emergency Exhaust
System
(RABEES) maintained
a negative
pressure
greater than or equal to 1/8 inch water gauge in the
Charging/Safety Injection Pump
(CSIP)
Rooms
as required by TS 4.7.7.d.3.
On Hay 30,
1996, it was discovered that no pressure
sensing taps
wer e
located in the CSIP
Rooms
and past testing
had not verified this TS
requirement.
An additional
concern
was identified in that the Waste
Processing
Building and Fuel Handling Building normal ventilation
exhaust
fans
had been running during previous testing which aided the
RABEES system in maintaining
RAB negative pressure.
Corrective action
included procedure revision, retesting,
and evaluating the acceptability
of the Reactor Auxiliary Building (RAB) differential pressure
indication
installed in the main control
room.
Procedure
OST-1052,
RAB Emergency
Exhaust
System Operability 18 Honth Interval All Hodes,
Revision 7/1 was
revised
and retesting
was performed.
The retesting
was described in NRC
Inspection Report 50-400/96-05.
The evaluation of the main control
room
RAB differential pressure
installed instrumentation
concluded that the
instrumentation
should not be used f'r TS surveillance verification.
Instead,
local manometer
instrumentation
should be used for TS 4.7.7.d.3
verification.
The inspectors
reviewed the corrective actions which were
adequately
completed.
The inspectors
concluded that the item discussed
in this
LER represented
a longstanding
procedural
deficiency with a similar root cause to that
of the programmatic
problem discussed
in Section H8.2 of this report
(licensee
personnel
not understanding
the full scope of Technical
Specification testing requirements
and
how they were implemented
by
procedures).
The inspectors
considered that this surveillance
procedure
deficiency was identified as
a result of the licensee's
overall
18
increased
awareness
and sensitivity to literal compliance with Technical
Specification surveillance
requirements.
Because of the similarities
between this example
and the issue discussed
in Section H8.2, this
violation of Technical Specifications is considered
another
example
of'pparent
Violation 50-400/97-08-02.
The
LER is closed.
Closed
LER 50-400/96-011:
Inadequate
surveillance
procedures
failed
to provide
a means for identifying deactivated
automatic containment
isolation valves which are to be subjected to verification every 31 days
in accordance
with Technical Specifications.
This
LER was previously discussed
in Inspection Report 50-400/96-09.
The licensee identified and reported the failure to verify the
deactivated
shut status of two containment isolation valves,
1FW-221 and
on
a monthly basis
as required by Technical Specification
(TS)
Surveillance
Requirement 4.6.1.l.a.
Valve 1FW-221 had failed a stroke
time test in December
1995 and,
along with 1FW-223,
was deactivated
shut
at that time to comply with TS 3.6.3 requirements.
In June of 1996,
an
operator
questioned
whether the monthly verification procedure
had
included these valves.
The licensee
discovered that the monthly
surveillance
procedures
(OST-1029,
Containment Penetration
Outside
Isolation Valve Verification Monthly Interval,
Modes 1-6;
and OST-1069,
Containment Building Penetration
Inside Manual Isolation Valve
Verification Quarterly Interval,
Mode 5) which implemented
did not include those motorized valves that were deenergized
shut to
comply with the TS 3'.3 requirement.
Upon discovery,
the licensee
revised the test procedures,
along with plant procedure
PLP-106,
Technical Specification Equipment List Program
and Core Operating Limits
Report,
which now include the requirement to verify the
valves'eactivated
shut status
every 31 days.
The licensee
found no other
examples of this situation occur ring with other valves.
were caused
by the licensee's
misinterpretation
of the requirement
contained in TS 4.6.1.1.a.
The error occurred during
initial procedure
development
and was brought forward through numerous
procedur e revisions.
The inspectors
concluded that this example
was
representative
of the programmatic
problem discussed
in report sections
H8.2 through H8.6, concerning the licensee's
earlier lack of
understanding of Technical Specification requirements.
Accordingly, the
inspectors
considered this issue to be another
example of Apparent
Violation 50-400/97-08-02
discussed
in the aforementioned
report
sections.
The
LER is closed.
19
E1
El.1
a.
Conduct of Engineering
En ineerin
Desi
n In uts
Ins ection Sco
e
37551
III. En ineerin
b.
C.
E7
The inspector
reviewed
numerous
Engineering Service
Requests
(ESRs)
during review of corrective actions for various
open items.
These
were reviewed against the requirements
in procedure
EGR-NGGC-0005,
Engineering Service Requests,
Revision 4, to determine if procedures
were followed.
Observations
and Findin s
The inspector
observed
two additional
examples of the
ESR implementation
weakness identified in Inspection Report 50-400/97-06,
Section El.l.
Section 01.5 of that
same report identified that
a rod insertion limit
alarm had not cleared during the start-up.
The licensee
investigated
the cause during this inspection period and found that during the core
design for fuel cycle 8 the park position for the rods was changed to
225 steps
as
a control rod wear distribution step.
During this process,
procedure
PLP-106, Technical Specification
Equipment List Program
and
Core Operating Limits Report,
Revision 15,
was changed to include the
225 step park position.
These
changes
did not consider the rod
insertion limit alarm reset point at 225.5 steps
and is considered
an
additional
example of the weakness
where
a design input/alarm was not
considered
during the design
change.
Section E8.3 pertaining to the closure of violation 50-400/96-11-06,
discusses
another
example in relation to an alarm in the control
room
caused
by ESR implementation.
ESR 9700024,
related to computer
room
ventilation,
caused
a nuisance
alarm in the control
room which
necessitated
a field change for correction.
Conclusions
The inspector
concluded that the additional
examples of not considering
alarms
as design inputs when designing modifications caused additional
nuisance
alarms.
Quality Assurance in Engineering Activities
E7.1
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 f'r a special
focused review that compares plant
practices,
procedures
and/or
parameters
to the
FSAR descriptions.
While
20
E8
E8.1
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
CPEL sites.
The
program
has
gener ated
a large
number of condition reports at the Harris
Plant
(325 by the end of the inspection period).
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.
Hiscellaneous
Engineering Issues
(92700,
92903)
Closed
VIO 50-400/96-10-01:
Failur e to promptly submit
a Technical
Specification
change for main reservoir level.
The inspector
reviewed the licensee's
responses
dated January
20,
1997
and February 7,
1997.
The corrective actions included submitting
a
Technical Specification
change
request
(October 31,
1996) for main
reservoir level, reviewing other technical specification interpretations
(TSIs), revising procedure
AP-107, Technical Specification
Interpretations,
a lessons
learned
review for licensing personnel,
and
a
review of the
new emergency service water "A" pump after installation to
determine if'n additional license
amendment
was needed.
One other
was identified in the response
as needing
a license
amendment,
and was
submitted
on February
18,
1997.
The inspector
reviewed procedure,
AP-107, Revision 11,
and found that
the changes
incorporated
included the performance of a
review for TSIs and included words that TSIs may not be used to meet
10 CFR 50.36 instead of submitting
a license
amendment.
The inspector
reviewed the licensee's
TSI review program
(TSI Action Plan,
Revision 5,
July 16,
1997) which currently projects to reduce the number of TSIs
from 29 (at time of violation) to approximately 6.
The licensee
was
performing
10 CFR 50.59 reviews for all existing TSIs.
This has
resulted in 2 LERs (97-008 and 97-011).
The inspector
noted that two
additional Technical Specification
changes
had been submitted
as
a
result of this effort, and that three additional
ones
were projected to
be submitted.
The inspector
reviewed the performance of the
new "A" Emergency Service
Water
pump in NRC Inspection
Report 50-400/97-06.
The licensee
had
committed in the February 7,
1997 supplemental
response
to submit
a
license
amendment if the
new pump did not meet the projected
performance.
A license
amendment will not be needed
per Engineering
Service Request
9700428,
Revision 0.
The inspector
reviewed the corrective actions taken
and concluded that
this violation had been corrected.
This item is closed.
E8.2
21
Closed
VIO 50-400/96-10-02:
Failure to provide an up-to-date
amendment for main reservoir level.
E8.3
E8.4
The inspector
reviewed the licensee's
response
dated January
20,
1997
and reviewed the corrective actions taken.
FSAR change
request
Review
Approval
Form (RAF) 2180 was approved
November
22,
1996 which adequately
addressed
the
FSAR changes
necessary
to correct the violation.
The
inspector verified that
RAF 2180 would be incorporated in the next
annual
submittal
(amendment 48).
This item is closed.
Closed
VIO 50-400/96-11-06:
Failure to identify and correct
deficiencies
associated
with deletion of ESW flow from AH-86.
The inspector
reviewed the licensee's
response
dated
Harch 3,
1997 and
reviewed the corrective actions taken.
OHN-014, Operation of the Work
Control Center,
Revision 15,
was revised to include in the quarterly
clearance
audit the requirement to write a condition report for
clearances
that are more than three months old.
The system engineer
was
required to evaluate these
items through the condition reports.
The
inspector verified that this requirement
was being complied with.
The
audits
had identified several
items that were similar to the AH-86 item
and the response
committed to having those resolved prior to the
completion of Refueling Outage 7.
The inspector verified that these
were completed
and the clearance
tags
removed.
During review of these
items the inspector
noted
an additional
example of a weakness identified
in IR 50-400/97-06 with ESR implementation associated
with consider ation
of alarms during design changes.
During review of the corrective
actions,
the inspector
noted that
a field change to ESR 9700024.resulted
from not considering
an alarm during the design
change process.
As a
result, the modification caused
a nuisance
alarm in the control
room
which necessitated
the field change.
The
ESR field change
adequately
corrected the nuisance
alarm.
The inspector concluded that the
corrective actions for the
LER issue
were adequately
completed.
This
item is closed.
Closed
VIO 50-400/96-01-01:
Inadequate
corrective actions for
improper control of RABEES doors.
The inspector
reviewed the licensee's
response
dated April 8,
1996,
LER 50-400/96-001-00,
and reviewed the corrective actions taken.
The
cause of the violation was attributed to inadequate
controls to ensure
that the door s are closed or properly controlled.
The corrective action
was to install
a modification to provide alarming capability for the
RABEES boundary doors by September
30,
1996.
The inspector verified
that the modification to alarm certain
RABEES boundary doors
had been
completed
and the alarms were functional.
No other
examples of RABEES
doors being blocked open have occur red since completion of the
modification.
However, not all
RABEES doors were provided with the
alarms.
The inspector
found that the doors to the charging/safety
injection pump rooms,
RHR heat exchanger
rooms,
and the door from the
Reactor Auxiliary Building (RAB) 236-foot elevation mechanical
room to the north hallway were not alarmed,
but were locked.
22
The inspector
found that the root cause investigation
was approved the
same day that
LER 50-400/96-001
was signed.
The inspector
reviewed
95-00979 which installed the alarms
and found that the
ESR provided for
the doors to be locked rather than alarmed.
The locking was
accomplished
under
ESR 9600199.
The failure to provide alarms for all
RABEES doors
as committed to in the violation response
and
LER 50-
400/96-001-00 is identified as
a Deviation from a written commitment
(50-400/97-08-03).
The inspector questioned
how locking the
RAB 236-foot elevation
mechnical
room door would address this issue since access to
this area could be obtained
from unlocked doors in the personnel air
lock area
and the sample sink area.
This item is adequately
addressed
in the licensee's
supplemental
response to the initial violation, which
was received after the end of this inspection period.
This item is
closed.
IV. Plant
Su
rt
Radiological Protection
and Chemistry (RPK) Controls
Water Chemistr
Controls
Ins ection Sco
e
84750
The inspectors
evaluated
the licensee's
water chemistry control program
for maintaining reactor coolant system chemistry parameters
within
Technical Specification
(TS) requirements.
The licensee's
water
chemistry program was evaluated
against the specific requirements of TS 3.4.7 (Tables 3.4-2 and 3.4.8) which specify the concentration limits
for dissolved
(DO), chloride (CL), fluoride (FL) and dose
equivalent iodine (DEI) in the Reactor Coolant System
(RCS).
The water
chemistry program was also evaluated
against the requirements of TS
Tables 4.4-3 and 4.4-4 which specify required surveillance frequencies.
Observations
and Findin s
The licensee's
water chemistry control procedures
included provisions
for sampling
and analyzing reactor coolant at the prescribed
frequency
for the parameters
required to be monitored by TSs.
Action levels
and
responses
for out of limit chemistry parameters
were also reviewed.
The
licensee's
water chemistry procedures
included provisions for monitoring
water quality based
on established
industry guidelines
and standards.
The inspectors
noted that licensee
procedures
specified the sampling.
frequency
and typical values for each
parameter
to be monitored.
Action
levels applicable to various operational
modes were given where
appropriate.
Guidance
was also provided for actions to be taken if
analytical results
exceeded
prescribed limits.
The inspectors
determined that the licensee's
procedures
were consistent with
applicable
TS requirements.
23
The inspectors
reviewed chemistry statistical
analysis reports,
primary
chemistry data,
related data trend plots,
and records of analytical
results
for selected
parameters
at power operations
and at shutdown
during the period January
1,
1996 through June 24,
1997.
The parameters
selected
included dissolved
oxygen, fluorides, chlorides, sulfates,
and dose equivalent iodine-131.
A review of chemistry data
disclosed that the licensee
had an elevated
RCS sulfate sample during
the recently completed refueling outage
RFO-7.
Although within
administrative limits (118 parts per billion (ppb) sample value versus
150 ppb limit), upon investigation,
the elevated
reading
was explained
based
on
a specimen
cup used for sample dilution that was
a source of
sulfate cross contamination.
Dissolved oxygen reached
a high level of
800 ppb during RF0-7, which exceeded
the TS limit applicable during
modes
1-4 of power operations of 100 ppb.
The elevated level
was
permitted,
however, during refueling when the
RCS was open to
atmosphere.
The licensee
also entered administrative action levels for
primary and secondary
water
chemistry, in accordance
with administrative
procedures,
on several
occasions
during the period of review with small
variances
from normal parametric values indicated during power
operations.
In each of these
cases
evaluated
by the inspector,
the
licensee
was able to provide an adequate
basis for the
RCS anomaly such
as
a reactor trip, expended
cleanup filters, or a planned reactor
evolution that affected water
chemistry values.
All anomalous
values
were determined to be within TS or administrative limits.
Conclusions
Primary and secondary
chemistry parameters
were maintained well within
TS and licensee administrative limits.
The licensee's
water chemistry
control program for maintaining water quality was effectively
implemented.
Annual Radioactive Effluent Release
Re ort
Ins ection Sco
e
84750
TS 6.9.1.4 required the licensee to submit
an Annual Radioactive
Effluent Release
Report covering liquid and gaseous effluent releases
resultant
from facility operations
during the prior year of operation.
In addition to activity released
in liquid and gaseous
effluents, the
report provided required estimates of radiation doses to members of the
public from effluents released to unrestricted
areas.
The inspector
evaluated the licensee's
effluent release
program to determine if the
licensee
had implemented
an effective program to monitor
and control
radiation doses
associated
with effluent releases.
Data on solid
radwaste
shipments
was also provided in the report and evaluated.
Observations
and Findin s
The inspectors
evaluated
report feeder data to identify adverse effluent
trends, identify increases
in estimated
doses to the public from
effluents, if any,
and explain these variances
in the context of
24
operational
experience.
The inspector
evaluated
supporting
raw data f'r
effluent release
reports covering
1996 and 1997 through Hay with
emphasis
on identifying elevated
release
trends or data anomalies.
As
shown in the effluent release
summary below, the amount of activity
released
during 1996 and 1997 through Hay in liquid effluent streams
remained relatively stable at low levels,
and well within regulatory
release limits.
The amounts of activity released
during 1996 as fission
gases,
and particulates
in gaseous
effluents were also at low
levels
and within release limits.
Hinor variances in gaseous effluent
parameters
within operational limits were identified between
1996 and
1997 indicative of normal steady state
power operations.
No abnormal
releases
were identified during the period.
However,
one unplanned
release
occurred in Harch 1997 when the licensee failed to maintain
a
negative pressure
for 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> in the reactor auxiliary building.
The
calculated
release to the environment through auxiliary building
amounted to
a relatively low 1.788E-3 curies of
predominantly noble gases.
Licensee corrective actions
were found to be
appropriate.
Harris Radioactive Effluent Release
Summar
1996
1997(to 5/31)
Abnormal Releases
Liquid
Gaseous
Activity Released
(curies)
a.
Liquid
1. Fission
and Acti-
vation Products
2. Tritium
3. Gross Alpha
b.
Gaseous
1. Fission
and Activation
Products
2. Iodines
3. Particulates
4. Tritium
6.00E-02
2.96E-02
4.61E+02
<LLD
1.76E+02
<LLD
4. 29E+01
1. 74E+01
9.53E-07
8.25E-06
4.04E-05
1.36E-04
2.50E+01
7.80E+00
The January
1996 through Hay 1997 data indicated
above
was trended
against
data from the years
1991 through 1995.
This analysis indicated
either
a stable or gradually declining trend in liquid and gaseous
releases
with no significant anomalies identified.
Slight variances
were explained adequately
by the licensee
based
on operational
history.
Tritium release
levels,
which remained well within limits, were slightly
elevated in 1996 when compared with 1995 liquid release
levels,
but
remained well below the approximate
1000 curies of tritium released
in
liquid effluents in 1994.
Although tritium releases
are within
regulatory limits, the licensee
recognized elevated concentrations
of
tritium in Harris Lake as
an area
for improvement
and initiated
a
Radioactive Effluent Reduction Plan approved for implementation
on
25
July 31,
1996.
The objective of this plan is to significantly reduce
detectable radioactivity in Harris Lake to include Tritium.
The
licensee's
goal is to reduce concentrations
in Harris Lake from the
current approximate
4000 picocuries
per liter to 900 picocuries per
liter by the end of 1999.
Short-term tritium reduction strategies
were
judged by the inspector to be reasonable
and included recycling tritium
back into the plant and restricting releases
of tritiated liquids to
periods of high rainfall in order to benefit from dilution factors.
The inspectors
evaluated for 1996 and
1997 through
Hay the maximum
annual
dose estimates to the public from gaseous
and liquid effluent
streams.
Dose limits are provided in the TS and include
a limit of 3
millirem for the total body from liquid effluents,
10 millirem for the
liquid critical organ
dose,
and
15 millirem for the airborne critical
organ dose.
Doses
were calculated
by the licensee in accordance
with
the methodology in the licensee's
Offsite Dose Calculation Hanual
(ODCH)
as
a function of the release
point, the isotopic mix, total curies
released,
and exposure
pathways.
All calculated
doses
from liquid and
gaseous
releases
were determined to be less than
1 percent of applicable
TS dose limits.
The licensee
also achieved reductions in doses
for all
dose
pathways during 1996 over 1995 and offsite doses
were gener ally on
a favorable reducing trend.
The licensee
has undertaken initiatives to reduce solid radwaste
volume
during 1996 and 1997.
Ongoing efforts in radwaste
include radwaste
volume reduction
and minimization initiatives.
The licensee is
currently shipping most of'ts low level radwaste offsite for processing
and volume
r eduction
due to the unavailability of offsite low level
radwaste
storage
for radwaste
generator s in North Carolina.
During
1996, licensee
operations
resulted in a relatively low 4.16 cubic meters
of solid radwaste
(62 curies) for interim storage onsite after
processing.
This was reduced
from 9.059 cubic meters
(77 curies) during
1995.
This radwaste
was processed offsite and retur ned to the licensee
for interim storage until final disposition.
The inspector noted that
current radwaste
performance resulted in continued reduction in radwaste
generation overall.
However, during the recently completed
RFO-7
refueling outage,
the licensee
exceeded its goal for solid radwaste
volume generated
(136 cubic meters
generated
against
a goal of 89 cubic
meters).
This was due primarily to an unanticipated
extended
outage
duration with expanded
outage
scope.
c.
Conclusions
The licensee
maintained
an effective program to monitor and control
liquid and gaseous
radioactive effluents
and thereby limited doses to
members of the public to a small percentage of regulatory limits.
The
release of radioactive material to the environment
from liquid and
gaseous
effluents for 1996 and 1997 through Hay 31 was
a small fraction
of the
10 CFR 20, Appendix
B and
10 CFR 50, Appendix I limits.
26
R1.3
Radiolo ical Controls Durin
Power 0 erations
a.
Ins ection Sco
e
83750
The inspectors
evaluated the adequacy of licensee radiological controls
with emphasis
on external
occupational
exposure controls during normal
plant operations.
Areas inspected
included radiation area postings,
radiation work permit controls,
and effectiveness
of the As Low As
Reasonably Achievable
(ALARA) program.
The inspector toured the
radiation controlled area
(RCA) and observed
compliance of licensee
personnel
with radiation protection procedures for routine work
evolutions.
b.
Observations
and Findin s
The inspector s verified observed controls for external
occupational
exposures
met applicable regulatory requirements
and were designed to
maintain exposures
The inspector
reviewed several
radiation work
permits
(RWPs) utilized to control ongoing work within the
RCA and noted
that the controls observed
were appropriate for the described
tasks
and
radiological conditions.
Interviews were conducted with radiation
worker s in order to determine the level of understanding of radiation
work permit requirements
from a representative
cross-section
of plant
workers.
The wor kers interviewed were verified to have signed onto an
RWP, were wearing dosimetry appropriate to their work activities within
the
RCA in accordance
with plant procedures,
and were performing
specific work activities on appropriate
RWPs.
The workers generally
demonstrated
a good knowledge of RWP requirements
and of radiological
working conditions.
The inspectors
noted good posting practices
throughout the plant.
During a tour of'he spent fuel pool the inspector
observed
no items
hanging from the side of the pool
and good radiological controls in
place in this area overall.
During peak traffic periods radiation
workers were observed exiting the
RCA in accordance
with procedures
for
frisking out of the
RCA to include properly clearing small articles with
the small articles monitor.
Pre-job
briefings for observed
ongoing work evolutions were found to be
conducted in an effective manner.
During tours of the plant, the
inspectors
observed Radiological Control technicians
performing
radiation
and contamination
surveys in accordance
with procedure.
Also,
during inspection of the tool issuance
rooms,
good controls for slightly
contaminated tools inside the
RCA were noted.
The licensee's
program overall continues to be effective in achieving reductions in
site exposure during normal
power operations.
However, during refueling
outage
RF0-7, the licensee
incurred 135.09 person
rem outage
dose which
exceeded
the outage
goal of 121.40 person
rem.
This was attributable
to unanticipated
expanded
outage duration
and growth in scope.
27
During a routine plant walkdown the inspector
observed
a 55-gallon drum
of'iscellaneous
scaffold parts located in the hallway outside the gas
decay tank valve gallery of the 236-foot elevation of the waste
processing building.
The drum was open,
not controlled or labelled
as
radioactive material,
and was readily accessible
to workers passing
through or working in the area.
Upon survey,
two scaffold knuckles were
identified that had removable surface contamination
(5000-6000
dpm/100
sq.
cm.) which exceeded
the procedural limit of 1000 dpm/100 sq.
cm.
as
specified in HPS-NGGC-0003,
Radiological Posting,
Label.ing and Surveys,
Rev. 2,
Paragraphs
3.4 and 9
~ 1.7.
HPS-NGGC-0003 requires
contaminated
material with these levels of removable surface contamination to be
controlled as contaminated
material in a posted Contamination Area.
Another scaffold knuckle was identified that had
12000 dpm/100 sq.cm.
fixed contamination that was not controlled in accordance
with paragraph
9'.4 of the
same procedure.
The licensee
issued
a condition report on
these NRC-identified adverse
conditions
(CR 97-03207 dated 6/24/97)
and
took prompt actions to correct these
contaminated
material control
discrepancies.
Licensee actions included
a full sweep of the
RCA to
confirm if any other examples of improperly controlled radioactive
material
could be identified and none were.
Based
on the licensee's
corrective actions,
the relatively low safety significance of the
contaminated
material control discrepancies
identified, this failure
constitutes
a violation of minor significance
and is being treated
as
a
Non-Cited Violation consistent with Section
IV of the
NRC Enforcement
Policy.
This is designated
NCV 50-400/97-08-04:
Failure to control
contaminated
material in accordance
with procedure
HPS-NGGC-0003.
c.
Conclusions
The radiological controls program was being effectively implemented with
good occupational
exposure controls observed
during normal plant
operating conditions.
One non-cited violation was identified for
failure to control contaminated
material in accordance
with procedure.
Rl.4
Trans ortation of Radioactive Haterial
a.
Ins ection Sco
e
86750
10 CFR Part 71 established
the requirements for packaging,
preparation
for shipment,
and transportation of licensed material.
required the licensee to comply with the applicable requirements of the
Department of'ransportation
(DOT) in 49
CFR Parts
170 through
189 when
transporting
licensed material outside of the confines of the plant.
The inspector evaluated
the licensee's
transportation of radioactive
materials
program for implementation of these
requirements
as well as
implementation of the revised 49 CFR Parts
100 through
179 and
28
b.
Observations
and Findin s
The inspectors
evaluated
the licensee's,preparation
of packages
for
transport
and discussed
applicable procedural
controls with the licensee
for shipments
conducted during 1996 and 1997 through the end date of
inspection.
The inspectors
evaluated detailed checklists
prepared
by
the licensee at the time of shipments to ensure
proper packaging,
labeling,
and placarding of vehicles
had occur red prior to shipping
radioactive material offsite.
The inspectors
determined,
based
on
a
sample of shipments
conducted,
that provisions for marking and labeling
packages
and for placarding vehicles were in accordance
with the
requirements.
The inspector
determined that licensee
procedures
included provisions for performing required surveys
and for assuring
that the radiation
and contamination limits were met for each
package
offered for shipment.
The inspectors
reviewed the licensee's
records
for several
shipments of radioactive material
and found that those
records indicated the required surveys
had been performed
and the
radiation
and contamination limits had been met.
The inspectors
determined that the licensee's
procedures
included provisions for
preparing shipping papers
and manifests in accordance
with the above
requirements
and for recording the required information thereon.
The
inspectors
reviewed the shipping paper s for selected
shipments of
radioactive materials
and determined that they had been prepared in
accordance
with procedure.
Licensee
procedures
for shipping radioactive materials included
provisions f'r providing drivers with required instructions
and the
inspector
verified shipping papers for selected
shipments
included
a
copy of those instructions.
Interviews with two drivers for resin
shipments that occurred during the period of inspection were conducted.
It was determined during these interviews that the drivers were
adequately
knowledgeable of emergency
response
procedures
although more
in depth knowledge would enhance their response
in the event of an
accident.
The inspectors
determined that the licensee's
procedures
for
shipping radioactive materials included provisions for making the
required
advance notifications and that the licensee's
records for
selected
shipments
included copies of'he forms used to make the
required notifications.
The inspectors
reviewed selected
shipping
records
and determined that the required information was being retained
as required.
The licensee classified
and characterized
waste shipments
through the use of the current release of RADHAN computer software.
Radionuclide concentrations
and physical description data for packaged
waste were input to the computer
and the program generated
a manifest
form.
The printed manifest form included the information required to be
included on waste manifests
and the certifications that the waste
had
been properly classified,
described,
packaged,
marked,
and labeled;
and
were in proper condition for transport in accordance
with applicable
State
and federal regulations.
29
Concurrent with this evaluation of the licensee's
implementation of
transportation
and shipping programs,
the inspector verified that the
licensee
had revised their procedures to be consistent with the revised
DOT and
NRC transportation
regulations.
This evaluation included
a
review of training
and qualification of personnel
on the
new
regulations,'changes
made to the licensee's
procedures
for the
processing
and packaging of low specific activity (LSA) and surface
contaminated
objects
(SCO), the use of the inter national
system of units
(SI), expansion of the radionuclide list and related
changes
in limits,
and use of the transport
index and related
changes
in fissile material
classification.
The inspectors
reviewed training materials
prepared
by the licensee to
comply with the requirements of 49 CFR Part 172, Subpart
H, Section
172.704, Training Requirements,
which specified that hazmat employee
training shall include general
awareness/familiarization
training.
The
inspector
reviewed the training material entitled
"DOT Hazardous
Haterial
General
Awareness Training," designated
lesson
number
EV601G,
and determined that it met the scope
and intent of the training
.requirement
but that the training had not been updated or made current
with the revised transportation rule which was effective April 1,
1996.
Specifically, the training did not contain any reference to SI units or
to revised definitions such
as
LSA or to any other
aspect of the revised
transportation
rule needed to provide radiation workers with a general
awareness
of the basic changes to the transportation
rule.
The
inspector
had verified that all radioactive material receipt
and
shipping procedures
being utilized in the plant had been revised prior
to the effective date of the
new transportation rule to incorporate the
performance
requirements of the new rule.
The inspectors verified that
the licensee
had conducted training of hazardous
material
workers during
1997 that used the out-of-date lesson plan and training materials.
The
finding that training being provided to worker s was not current
or
updated with current plant implementing procedures
was contrary to the
requirements of Plant Operating Hanual,
Volume 8, Part 1, Procedure
Number TPP-100,
"Conduct of Training", Rev. 4, Paragraph
5.2.5.c,
which
states that training shall
be conducted
using current training materials
that match job knowledge and/or performance
requirements.
The licensee
was informed that the failure to conduct training using current training
materials that match performance
requirements
was
a violation of a
procedural
requirement.
This is designated Violation 50-400/97-08-05,
Failure to conduct training using current training materials.
c.
Conclusions
The licensee
implemented
an effective program for packaging,
preparation,
and transport of'adioactive material
and had conducted the
program without incident during the period reviewed.
One violation was
identified for failure to conduct training using cur rent training
materials that matched current performance
requirements.
30
R8
R8.1
S1
S1.1
F1
F1.1
Hiscellaneous
Plant Support Issues
(92904)
Closed
URI 50-400/97-300-03:
Placing, contaminated
items outside
boundary
The inspectors
reviewed posting
and procedural
upgrades
completed
by the
licensee in response to an
NRC concern that small articles that cleared
the small article monitors
(SAHs) at the
RCA exit are placed across
the
RCA boundary prior to the worker 's hands
being checked for
contamination.
The inspectors
did not identify any examples
where
contaminated
items were improperly released
from the
RCA.
However, this
practice could have resulted in loose contamination outside the
RCA.
The licensee
revised plant procedures
and upgraded postings at the
SAH
to require
hand frisking while small articles were being monitored
and
prior to moving SAH cleared articles'outside
the
RCA boundary.
The
inspector
observed radiation worker compliance with the
new procedure
and determined that these
upgrades
adequately
address
the
NRC concern.
This item is closed.
Conduct of Security and Safeguards Activities
General
Comments
71750
The inspector
observed security and safeguards
activities during the
conduct of tours,
and observation of maintenance activities.
During the
conduct of tours the inspector noted
a security guard that was less than
fully alert on the top of the reactor auxiliary building.
The licensee
wrote
CR 97-03736
and counselled the individual.
Compensatory
measures
were posted
when necessary
and properly conducted.
Control of Fire Protection Activities
General
Comments
71750
The inspector
observed fire protection equipment
and activities during
the conduct of tours
and observation of maintenance activities and found
them to be acceptable.
The inspector
observed that the licensee
was
making progress
in reducing the number of fire protection surveillances
being performed in their grace period (IR 50-400/97-04,
Section F7).
V. Mana ement Heetin s
X1
Exit Meeting Smeary
The inspectors
presented
the inspection results to members of licensee
management
at the conclusion of the inspection
on August 4,
1997.
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.
31
PARTIAL LIST OF PERSONS
CONTACTED
Licensee
D. Batton, Superintendent,
On-Line Scheduling
D. Braund, Superintendent,
Security
B. Clark, General
Manager,
Harris Plant
A. Cockerill, Superintendent,
I8C Electrical
Systems
J. Collins, Manager,
Haintenance
J.
Dobbs,
Manager,
Outage
and Scheduling
J.
Donahue,
Director Site Operations,
Harris Plant
J.
Eads,
Supervisor,
Licensing and Regulatory Programs
R. Duncan,
Superintendent,
Mechanical
Systems
W. Gurganious,
Superintendent,
Environmental
and Chemistry
H. Hamby, Supervisor,
Regulatory Compliance
H. Keef', Manager, Training
D. HcCarthy, Superintendent,
Outage
Management
B. Heyer,
Manager,
Operations
K. Neuschaefer,
Superintendent,
Radiation Protection
W. Peavyhouse,
Superintendent,
Design Control
W. Robinson,
Vice President,
Harris Plant
G. Rolfson,
Hanager,
Harris Engineering Support Services
D. Tibbitts, Manager,
Nuclear Assessment
NRC
V.
H.
Rooney, Harris Project Manager,
Shymlock, Chief, Reactor Projects
Branch 4
32
IP 37551:
IP 61700:
IP 61726:
IP 62707:
IP 71750:
IP 84750
IP 86700:
IP 86750:
IP 92901:
IP 92902:
IP 92903:
IP 92904'P
93702:
TI 2515/
133
INSPECTION PROCEDURES
USED
Onsite Engineering
Effectiveness of Licensee Controls in Identifying, Resolving,
and
Preventing
Problems
Surveillance
Procedures
and Records
Surveillance Observations
Maintenance Observation
Plant Operations
Plant Support Activities
Occupational
Radiation Exposure
Radioactive
Waste Treatment,
and Effluent and Environmental
Monitoring
Spent
Fuel
Pool Activities
Solid Radioactive
Waste
Management
and Transportation
of'adioactive
Materials
Onsite Followup of Events
Followup
- Plant Operations
Followup
- Maintenance
Followup
- Engineering
Followup
- Plant Support
Onsite Response to Events
Implementation of Revised
49 CFR Parts
100-170
and
~0ened
50-400/97-08-01
50-400/97-08-02
50-400/97-08-03
DEV
50-400/97-08-04
50-400/97-08-05
Closed
ITEHS OPENED,
CLOSED,
AND DISCUSSED
Failure to provide Licensee
Event Report within 30
days for missed technical specification surveillance.
(Sections
H8.2 and H8.4)
Sur veillance Procedure
Program breakdown.
(Sections
H8 ~ 2 through H8.7)
Failure to provide alarms for RABEES doors
as
committed to in VIO 50-400/96-01-01
and
LER 50-400/96-
001.
(Section E8.4)
Failure to control contaminated
material in accordance
with procedure
HPS-NGGC-0003.
(Section R1.3)
Failure to conduct training using current training
materials.
(Section R1.4)
50-400/97-08-01'CV
Failure to provide Licensee
Event Report within 30
days for missed technical specitication surveillance.
(Sections
H8.2 and H8.4)
50-400/97-08-04
50-400/96-01-01
50-400/96-10-01
50-400/96-10-02
50-400/96-11-01
50-400/96-11-06
50-400/95-015-00
LER
50-400/96-002-00
LER
50-400/96-002-02
LER
50-400/96-002-03
LER
50-400/96-002-04
LER
50-400/96-002-05
LER
50-400/96-002-06
LER
50-400/96-002-07
LER
50-400/96-002-08
LER
50-400/96-002-09
LER
50-400/96-002-10
LER
50-400/96-002-11
LER
50-400/96-002-12
LER
50-400/96-002-13
LER
50-400/96-007-00
LER
50-400/96-009-00
LER
50-400/96-010-00
LER
33
Failure to control contaminated
material in accordance
with procedure
HPS-NGGC-0003.
(Section Rl.3)
Inadequate
corrective actions for improper control of
RABEES doors.
(Section E8.4)
Failure to promptly submit
a Technical Specification
change for main reservoir level. (Section E8.1)
Failure to provide an up-to-date
FSAR amendment
for
main reservoir level. (Section E8.2)
Failure to follow procedure
for chart recorder
marking
and temperature
monitoring. (Section 08.1)
Failure to identify and correct deficiencies
associated
with deletion of ESW flow from AH-86.
(Section E8.3)
Failure to identify Engineering Safety Features
response
time testing requirements
during
a
modification to the flow control valve circuitry for
the Hotor Driven Auxiliary Feed Water pumps.
(Section
H8.1)
Failure to properly per form Technical Specification
surveillance testing.
(Section H8.2)
Failure to properly perform Technical Specification
surveillance testing.
(Section H8.2)
Failure to properly perform Technical Specification
surveillance testing.
(Section H8.2)
Failure to properly perform Technical Specification
surveillance testing.
(Section H8.2)
Failure to properly perform Technical Specification
surveillance testing.
(Section H8.2)
Failure to properly perform Technical Specification
surveillance testing.
(Section H8.2)
Failur e to properly perform Technical Specification
surveillance testing.
(Section H8.2)
Failure to properly perform Technical Specification
surveillance testing.
(Section H8.2)
Failur e to properly perform Technical Specification
surveillance testing.
(Section H8.2)
Failure to properly perform Technical Specification
surveillance testing.
(Section H8.2)
Failure to proper ly perform Technical Specification
surveillance testing.
(Section H8.2)
Failure to properly perform Technical Specification
surveillance testing.
(Section H8.2)
Failure to properly perform Technical Specification
surveillance testing.
(Section H8.2)
Failure to perform Technical Specification
surveillance testing in accordance
with Specification
4.7.6.d.3
~ (Section
H8 ~ 3)
Reactor Auxiliary Building Emergency Exhaust
system
testing deficiency.
(Section H8.6)
Surveillance testing deficiencies that caused
past
entries into TS 3.0.3.
(Section H8.4)
50-400/96-010-01
LER
50-400/96-010-02
LER
50-400/96-011-00
LER
50-400/96-016-00
LER
50-400/97-300-03
34
Surveillance testing deficiencies that caused
past
entries into TS 3.0.3.
(Section H8.4)
Surveillance testing deficiencies that caused
past
entries into TS 3.0.3.
(Section H8.4)
Inadequate
surveillance
procedures
failed to provide
a
means for identifying de-activated
automatic
containment isolation valves which are to be subjected
to verification every thirty one days in accordance
with Technical Specifications.
(Section H8.7)
Failure to perform reactor trip bypass
breaker
surveillance testing required by Technical
Specifications.
(Section H8.5)
Placing contaminated
items outside
HP boundary.
(Section R8.1)
Discussed
50-400/96-002-01
LER
Failure to properly perform Technical Specification
surveillance testing.
(Section H8.2)
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II