ML18016A216

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Insp Rept 50-400/97-09 on 970803-0913.Violations Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support
ML18016A216
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 10/09/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18016A214 List:
References
50-400-97-09, 50-400-97-9, NUDOCS 9710230043
Download: ML18016A216 (38)


See also: IR 05000400/1997009

Text

U. S.

NUCLEAR REGULATORY CONMISSION

REGION II

Docket No:

License

No:

50-400

NPF-63

Report

No:

50-400/97-09

Licensee:

Carolina

Power

8 Li,ght (CPBL)

Facility:

Shearon Harris Nuclear

Power Plant, Unit 1

Location:

5413 Shearon Harris Road

New Hill, NC 27562

Dates:

August

3

- September

13,

1997

Inspectors:

Approved by:

J.

Brady, Senior Resident

Inspector

D. Roberts,

Resident

Inspector

G. HacDonald,

Project Engineer

(Section E8.3)

H. Shymlock, Chief, Projects

Branch 4

Division of Reactor Projects.

9710230043

971009

PDR

ADOCK 05000400

8

PDR

Enclosure

2-

EXECUTIVE SUHMARY

Shearon Harris Nuclear

Power Plant, Unit 1

NRC Inspection Report 50-400/97-09

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 Project Engineer.

~0erations

In general,

the conduct of operations

was professional

and safety

conscious.

The unit shutdown for the forced outage

was handled well by

the operations

crew.

An unresolved

item was opened to review issues

related to the turbine-driven auxiliary feedwater

pump forced outage

work and recovery efforts (Section 01.1

and 01.2).

o

A violation was identified concerning the marking of a main control

room

chart recorder

(Section 02. 1).

Low employee morale has existed in the Operations organization during

1996 and 1997.

Licensee

management

was aware of recent morale

and

performance

issues

and has undertaken efforts to improve both areas

(Section 04.1)

.

A weakness

was identified in relation to three examples of operator

inattention to plant status

and conditions (Section 04.2).

Safety committee meetings

and Nuclear Assessment

Section

assessments

were good.

The equality Check program

needed

some

improvements.

The

self-assessment

of Non-Licensed Operator cross qualification was

thorough.

Self-assessment

activities, in general,

were thorough

and

identified problems

(Section 07.1).

Haintenance

The inspector

concluded that several

maintenance

and testing errors

caused

and extended

the turbine-driven auxiliary feedwater

pump

(TDAFW)

forced outage.

An unresolved

item was identified in relation to overall

performance

in dealing with the turbine-driven auxiliary feedwater

pump

problems

and the root cause of the errors

(Section H1.2).

The surveillance

performances

observed

were adequately

conducted

(Section H2.1) .

Non-cited violations were identified for items reported in three

LERs;

50-400/96-02-01,

96-17-00,

and 96-05-00 (Sections

H8.1, H8.2,

and H8.5).

En ineering

Several

examples of a weakness

were identified where system description

procedures

were not being thoroughly validated or updated

(Section

E3.1) .

A weakness

was identified in trouble-shooting

the

TDAFW pump problems

prior to obtaining all available data

(Section

E4. 1).

A non-cited violation was identified f'r the item reported in LER 50

400/96-013-00

(Section

E8. 1).

The

FSAR upgrade

work was being accomplished

in accordance

with the

FSAR

Improvement Plan.

The initial FSAR screening

review was thorough.

Issues identified were properly categorized

and entered into the

corrective action program for resolution (Section E8.3).

'~ltt,t

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 (Section R1).

Security activities,

Emergency

Preparedness

activities,

and Fire

Protection activities were adequately

conducted

(Sections

P1,

S1,

F1,

F2).

4

Re ort Details

Summar

of Plant Status

Unit 1 began this inspection period at 100 percent

power.

On August 16,

1997,

at approximately midnight,

power

was reduced to approximately

30 percent in

order to investigate

a main condenser

tube leak.

Power was returned to 100

percent

on .August 17,

1997 after the tube leak was repaired.

The unit was

shutdown

on August 29,

1997 due to problems with the turbine-driven auxiliary

feedwater

pump

(TDAFWP).

The unit restarted

on August 31,

1997 and reached

100 percent

power

on September

1,

1997.

The unit remained at 100 percent

power for the rest of the inspection period.

Ol

Conduct of Operations

01.1

General

Comments

71707

I. 0 erations

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.

01.2

F

'

Sb t:6 ~dSC

a.

Ins ection Sco

e

71707

The inspector

reviewed the shutdown

and subsequent

startup

from the

turbine-driven auxiliary feedwater

pump outage to determine if

procedures

were followed.

Procedure

GP-006,

Normal Plant Shutdown from

Power Operation to Hot Standby,

Revision 13,

was applicable to the

shutdown

and procedure

GP-005,

Power Operation

(Node

2 to trode 1),

Revision 18,

was applicable to the startup.

b.

Observations

and Findin s

The inspector

observed that the shutdown conducted

on August 29,

1997

was conducted in accordance

with plant procedures.

Operators

shutdown

the plant due to Technical Specification (TS) 3.7. 1.2 action (a) which

required the plant to be in hot standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after expi ration

of the

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> provided to repair

and make operable the turbine-driven

auxiliary feedwater

pump.

Section

t11.2 discusses

the maintenance

problems that caused the shutdown.

The inspector

observed the subsequent

unit startup

on August 31,

1997.

Reactor

startup

was in accordance

with procedures

and was handled well

by the operating

crew.

Synchronization to the grid occurred that

same

day and was not handled

as well.

The inspector

observed that procedures

were followed prior to synchronization.-

Reactor

power

was at 9.5

ercent prior to synchronization.

After synchronization,

reactor

power

ad jumped

5 per cent to 14.5 percent

which was consistent with previous

synchronizations.

Due to the power increase,

steam generator

levels

,swelled followed by a reduction in level

as the feed regulating bypass

valves attempted to control level.

Steam flow had increased

above feed

water

flow immediately at synchronization.

The combination of the

closing of the bypass

valves

due to the swell

and the steam flow/feed

flow mismatch

caused

a level transient

which caused

level to decrease.

The steam generator

level

downward transient

continued

due to the bypass

valves being close to the limit of their flow capability.

Operators

opened the main feedwater regulating valves,

intending to supplement

the

bypass

valves.

However, the block valves upstream of the feed

regulating valves

had not been opened.

Operators

were not immediately

aware of the block valves being closed

and did not identify why level

was not responding.

The Operations

manager

was observing the

synchronization to the grid and pointed out to the operators that the

block valves were not open.

The inspector considered that the opening

of the feedwater regulating valves prior to opening the block valves

was

different than described

in step

102 in procedure

GP-005.

The

Operations

manager

counseled

the operating shift on attention to 'detail

and proper procedural

compliance.

Condition Report

(CR) 97-04109

was

initiated to document this problem.

Based

on current plant performance,

the inspector determined that the feedwater control valve unblocking

steps

should

be prior to their existing location in GP-005.

The inspector

observed that this crew was on shift when the

TDAFWP dead

headed

(section H1.2)

and had difficulty in the latest licensed operator

requalification exam.

In addition, the operator not identifying the

closed block valve was from the most recent initial qualification class.

The examination of this class

was discussed

in Inspection Report

50-400/97-300

and

a training staff weakness

was noted in Inspection

Report 50-400/97-03.

The inspector questioned

why a step increase

in power was necessary

at

synchronization.

The step increase

unnecessarily

challenged

the control

systems

(feedwater flow, steam generator level,

and reactor temperature

control).

The steam

dump system provides

an automatic

method for the

licensee to set

power at the synchronization level prior to

synchronization

and transfer

steam

demand

from the steam

dump system to

the turbine at synchronization.

The appropriate

use of the steam

dump

system during synchronization

allows for

a smooth transfer

without

having

a significant step increase

in power.

The licensee

was

investigating

why a smooth transfer

had not occurred.

During review of operator logs and condition reports,

the inspector

reviewed the circumstances

surrounding

a turbine runback that occurred

later in the startup

on September

1,

1997.

The inspector

found that

CR

97-04112

was initiated due to the runback.

The

CR identified that the

Unit Senior Control Operator

(SCO)

had misread

Procedure

GP-005 for

where to stop the power increase

and start

a second

feed

pump.

The

SCO

misread the procedure to indicate 370 psig turbine first-stage pressure

instead of 310 psig.

The investigation of this event

found that four

procedures

contained conflicting runback initiation setpoint values.

(GP-005,

OP-134.01,

AOP-010,

and APP-ALB-020, t1ain Control Board).

The values varied from 370 to 330 to 310 psig.

The inspector

observed

that the

SCO was also from the latest initial license class

discussed

in

Inspection Report 50-400/97-300.

The inspector

remembered

a runback in 1996 that was documented in CR 96-

01254.

The 1996

CR documented

a conflict with the

same procedures.

Corrective actions to revise the procedures

had not been completed

and

the condition report was still open.

The licensee

was performing

a root cause investigation of'll personnel

errors noted during the

TDAFWP forced outage.

The inspector considered

the root cause of startup errors unresolved

and will be identified as

unresolved

item,

URI 50-400/97-09-01,

TDAFWP Forced

Outage

Problems.

Conclusions

02

02.1

The forced shutdown

was handled well by the operations

crew.

An

unresolved

item was opened to review issues

related to the

TDAFW pump

forced outage

work and recovery efforts.

Operational

Status of Facilities and Equipment

Review of Shi ft Lo s

Ins ection Sco

e

71707

The inspectors

checked the main control

room chart recorders to assure

that pens

were marking properly and the recorders

were timing correctly.

Observations

and Findin s

On August 17,

1997 at approximately 8:45 a.m.,

the inspector identified

where the licensee

had failed to properly check

and initial the main

control

room chart recorders

once

per shift as required

by Procedure

OMM-016, Operator

Logs, Revision

13'hart recorder

PR 649,

Component

Cooling Water red pen,

was not inking and

had not been since

approximately 1:00 p.m. the previous day.

This period of time included

two shift turnovers

and one entire shift period.

The chart

had not been

initialled'ince 11:00 a.m. the previous

day when chart inking problems

were corrected

and the chart motor was restarted.

Procedure

OMM-002,

Shift Turnover Package,

Revision 12, stated that individuals are

responsible

for personally verifying important parameter s,

and reviewing

and understanding

logs applicable to their shift position before

relieving the shift.

The failure to check

and note chart recorder

PR

649 marking problems through two shift turnovers

and one shift marking

period is identified as

a violation of TS 6.8. l.a and is designated

violation 50-400/97-09-02.

failure to properly check main control

room

chart recorders.

This violation is similar to violation 50-400/96-11-01

where operators

were initialing the chart recorder

logs even though the

pens were not marking.

4

The operators

immediately corrected

the inking problem and restarted

the

chart.

Condition Report 97-03888

was initiated to address

the cause of

the problem.

The licensee

found that

a communication

problem during the

shift had caused

the failure to .properly check

and initial some charts.

During the period of time identified,

a condenser

tube leak had been

discovered

and the unit was reducing

power to enable the leak to be

identified.

Procedure

OIN-16 requires that the charts

be marked for

significant events.

This was accomplished

except that the

down power

did not affect component cooling water pressure,

and therefore the chart

was not,marked.

The operator

who marked the charts for the

down power

and the main control

room operators

inadequately

communicated to each

other that riot all charts

had been marked.

Conclusions

A violation was identified concerning the marking of a main control

room

chart recorder.

04

04.1

Operator

Knowledge and Performance

JOD

N

1

die

El'f t

P f

Ins ection Sco

e

71707

The inspectors

reviewed

a 1996 employee opinion survey and interviewed

operators

in order to determine whether employee

morale problems existed

and whether there

was- any discernable

impact on operator

performance.

Observations

and Findin s

The inspectors

reviewed

a 1996 employee opinion survey which indicated

that responses

obtained

from the Operations unit were generally less

favorable than those obtained

from other organizational

units.

Areas

evaluated by the opinion survey included the licensee's ability to deal

fairly with employees

and treat employees with respect.

The inspector informally interviewed several

operators

(licensed

SROs,

ROs,

and non-licensed auxiliary operators)

including some

who performed

non-shift work such

as procedure writing or work coordination duties.

Everyone interviewed agreed that declining morale

had been

an issue over

the last two years.

The disparity was whether

employee

morale

was still

an issue at the time of this inspection

and whether there

was

a link to

employee

performance

and safety issues.

Some felt employee morale

had

improved in the last few months,

and was better

than that of a year

ago

(when it was generally perceived to be at its worst), while others

thought morale was still pretty low.

The inspector

perceived that the

opinions expressed

were based partially on recent treatment in relation

to personnel

actions or employee. appraisals.

For the most part,

operators

expressed

that employee

morale

had improved over the last

several

months.

In general,

those interviewed'were

happy with some of the recent

management

changes

in Operations.

The consensus

was that the

new

operations

manager

had

made progress

in his attempts to remove

some of

the barriers to good performance

(administrative burdens,

excessive

overtime, external distractions).

They generally felt that the

new

manager

had

made progress

in achieving

some of the objectives in the

site's recently implemented

Near Term Improvement Plan,

allowing

operators to focus more on safely operating the plant.

Recent efforts

to realign the operations organization,

including personnel

changes

in

first-line and middle management,

were viewed positively.

Some negatives still existed,

including

a perceived "pass/fail" approach

to performance

appraisals,

and licensee

management's

alleged

casual

approach to communicating

a recent organization

change.

The results of the above-mentioned

interviews

and employee survey review

were not surprising to the inspectors,

who were aware of recent operator

errors

and

an attempt

by licensee

management

to focus

on performance

issues.

In essence,

operators

have

been

under

a "microscope" for the

year or two because of performance

problems.

The combination of the

"microscope" effect and recent operational

challenges

and

an

unexpectedly lengthy refueling outage

have likely contributed to low

employee morale.

Licensee

management

was aware of the morale

issu~

and

had identified it as

an improvement item in its newly implemented

Near

Term Improvement Plan.

During the above survey review and employee interviews, the inspector

did not identify any immediate safety concerns.

However, it was clear

that low operator morale

had been

an issue in 1996

and 1997.

There

was

no conclusive evidence that linked the low morale to the increased

human

error rate in either year.

However, it was considered likely that the

increased

management

scrutiny of employee

performance

has highlighted

a

morale problem that may have

been developing for

a period of time.

Conclusions

Low employee

morale

has existed in the Operations organization during

1996 and 1997.

Licensee

management

was aware of recent morale

ar 6

performance

issues

and has undertaken efforts to improve both areas.

No

violations or deviations

were identified by the inspectors.

~0 erator

Knowled e of E ui ment Status

and Plant Conditions

Ins ection Sco

e

71707

The inspectors

reviewed operator

performance

during the period in

relation to knowledge of equipment conditions.

Observations

and Findin s

The .inspector

observed

several

instances

where operators

were not fully

aware of plant conditions.

The first related to the feedwater

c

regulating valve block valves discussed

in section 01.2 of this report.

Operators

were attempting 'to use the feedwater

regulating valves without

having the associated

block valves open.

A second

example involved the

chart recorder identified in section 02.2 of the this report where

operators

were not aware that a'ontrol

room chart recorder

was not

marking for over

18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

The third involved the performance of OST-1005,

Control

Rod and

Rod

Position Indicator Exercise Monthly Interval, Revision 7,

when the bank

insertion limit alarm did not clear.

This had occurred

on three

startups

since refueling outage

7 when the park position for the rods

was changed.

Inspection Reports 50-400/97-06

and 97-08 discussed

the

design

problem associated

with the alarm.

On August 8,

1997 while

performing OST-1005,

the bank insertion limit alarm again did not clear.

The inspector observed that the operating

crew was surprised that the

alarm did not clear.

During the previous

two startups,

which were

observed

by the inspector, this alarm not clearing

was expected

because

operators

had reviewed the work request

and engineering

service request

that

was generated

as

a result of the problem.

A yellow dot had been

placed

on the alarm light box to alert the operators to this previously

identified problem.

The August 8 operations shift did not know why the

dot had been placed

on the main control board.

Condition Report 97-

03822

was initiated to address this unawareness

problem.

In addition,

discussions

were held at the monthly Plant Nuclear Safety Committee

meeting concerning operator attention to plant conditions.

Conclusions

07

07.1

a.

A weakness

was identified in relation to three examples of operator

.inattention to plant status

and conditions.

Quality Assurance in Operations

Licensee

Self-Assessment

Activities

0

~40000

During the inspection period, the inspector s reviewed multiple licensee

self-assessment

activities to determine whether the licensee

was

adequately

finding problems.

These included:

Plant Nuclear Safety Committee

(PNSC) meeting

on August 27,

1997

Nuclear Safety Review Committee

(NSRC) meeting

on September

2,

1997

Nuclear

Assessment

Section

(NAS) Audits on Technical Specification

Survei llances

(HNAS97-101) Maintenance

(HNAS 97-0117),

Vendor

Services

(HNAS97-081),

and Biennial Procedures

Review

(HNAS 97-

102)

Condition Reports

Line Organization Self Assessments

Quality Check

(Employee Concerns)

b.

Observations

and Findin s

The inspector

observed that the safety committees

(PNSC

and

NSRC) were

thorough in their review of the scheduled

discussion

issues.

Senior

corporate

management

was involved in the

NSRC including the Executive

Vice President,

who has

been at all

NSRC meetings

observed

by the

inspectors

in 1996 and 1997.

The inspector

found these activities good.

NAS Audits reviewed were probing in the areas

reviewed.

The inspector

interviewed the lead auditor concerning the audits

and found him to be

knowledgeable

about the findings and their significance.

The inspector

reviewed the Quality Check Program described in Procedure

REG-NGGC-0001,

Revision 3, with the Quality Check representative

end the

Manager-Performance

Evaluation

and Regulatory Affairs (PERAS).

The

inspector

was told that

a change to the Quality Check Program

was being

prepared.

A sample file was used to demonstrate

implementation of the

procedure.

The inspector

had the following general

observations,

which

were being considered

by the licensee for inclusion in the

new program

revision:

Quality Check files are considered

closed after investigation

completion,

even if corrective actions

are not completed.

The term "resolved"

was not used equivalently with "corrected".

Resolved

concerns

may be those

where investigation is complete

and

corrective actions

agreed

upon,

as opposed to corrective actions

completed

and the concern resolved.

Concerned individuals were not necessarily

informed of corrective

action completion, only of investigation completions

Corrective actions

were being tracked through

a data

base

used

by

Quality Check personnel.

Actions to line organizations

may not be

in a site-wide tracking system.

Procedure

AP-615, Condition Reporting,

Revision 24,

exempts

Quality Check items from the condition reporting program.

However,

Procedure

REG-NGGC-0001 discusses

writing condition

reports for Quality Check items.

Licensee

personnel

were

preparing

a change to AP-615 in response

to this observation.

The inspector

observed

the following related to the Quality Check file:

The investigation

appeared

to be thorough

and well documented.

File organization

needed

improvement.

Corrective actions

were given

a due date which had long since

passed,

but there

was

no evidence in the file that the corrective

actions

were complete.

The inspector

concluded

from discussions

with licensee staff that this was

a documentation

and

administrat

~n issue only.

The file inuicated that

a condition report

(CR) had not been

written for the investigation findings even though they

represented

potential

procedure

implementation

problems.

The

inspector

found that the line organization

had written a

CR, but

the Quality Check staff was not aware.

The inspector

reviewed

a line organization self-assessment

conducted

Hay 7-10,

1996, titled "Assessment of OJT/TPE for cross-qualification of

Non-Licensed Operator

(NLO) Systems".

The self-assessment

was conducted

by the training department to determine if cross-qualification

implementation

on

NLO systems

was effective.

The assessment

identified

two weaknesses.

The first was that the distinction between on-the-job

training (OJT)

and task performance evaluation

(TPE) were not

consistently observed.

The second

was that operators

were allowed to

assume

rad-waste

watch-standing

duties without properly completing the

identified qualification requirements.-

Ten corrective actions

were

identified by this self-assessment

with organizations

and due dates

assigned.

The inspector

reviewed Condition Report 96-01284 which

implemented the corrective actions.

The corrective actions

were

, completed

on July 17,

1997.

The inspector

discussed

the corrective

actions with the former operations

manager

who stated that cross-

qualification was stopped

as

a performance

appraisal

objective in the

fall of 1996.

The former operations

manager

had discussed this action

with the inspector at that time.

That action was not included in the

condition report corrective actions.

The inspector

found the self-

assessment

thorough.

Conclusions

Safety committee meetings

and

NAS assessments

were good.

The equality

Check program needed

some

improvements.

The self-assessment

of Non-

Licensed Operator cross-qualification

was thorough.

Self-assessment

activities, in general,

were thorough

and identified problems.

H1.1

Conduct of Maintenance

General

Comments

62707

II. Haintenance

The inspectors

observed all or portions of the following work

activities:

WR/JO AKLT-001

WR/JO AIWI-002

o

WR/JO 97-AIHH1

WR/JO AIVH-002

WR/JO AIYF-002

Replace

Solenoid

on 1CC-305,

Gross Failed Fuel

Detector

"8" Train

CCW isolation valve.

Perform

PM-M0014 on 1CC-167,

RHR heat exchanger

"B" CCW outlet isolation valve

Fire Door 615 door closer broken

Limitorque PH-H0014 on valve 1CT-1g

Limitorque PM-H0014 on valve 1CT-26

In general,

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.

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.

In addition,

see the specific discussions

of maintenance

observed

under

H1. 2

Turbine-Driven Auxiliar

Feedwater

Pum

Maintenance

Ins ection Sco

e

62707

The inspectors

observed portions of the maintenance activities to repair

the turbine-driven auxiliary feedwater

pump

(TDAFWP) between

August 27

and August 31,

1997.

These activities were covered

under

WR/JO 97-AJCX1

and Procedure

CH.M0071, Ingersoll-Rand Turbine Driven Feedwater

Pump

Size 4 x 9 NH-7 Disassembly

and Maintenance,

Revision 6.

The inspectors

also reviewed the circumstances

associated

viith a post-maintenance

test

in which the

TDAFW pump was deadheaded

for five minutes.

The inspectors

reviewed the test procedure,

OST-1080, Auxiliary Feedwater

Pump

1X-SAB

Full Flow Test Quarter ly Interval, Revision 1,

and the licensee's

corrective actions

as described

for condition report

(CR) 97-04104.

Observations

and Findin s

The work was initiated due to vibration problems

found during the

initial performance of OST-1411, Auxiliary Feedwater

Pump

1X-SAB and

1AF-68.

1AF-106,

1AF-87 forward flow operability test.

Vibration on the

inboard bearing

was approximately double what it had been in the

previous test.

The licensee

was

aware that at the pressure

and flow

being used,

hydraulic pulsation

was being experienced

when using the

recirculation line to the condensate

storage

tank.

The line was not

sized for full flow.

NRC Bulletin 88-04. Safety-related

Pump Loss,

had warned of flow

instability at low flows while on recirculation.

Flow instability

becomes

more severe

as flow is decreased,

and can cause

pump damage

from

pump vibration, excessive

forces

on the impeller,

and cavitation.

The

bulletin recommended that the limitations associated

with these

hydraulic phenomena

be considered

when specifying minimum flow capacity.

The licensee's

response

to the bulletin dated July 11 and November

1,

1988 did not identify any problems with the auxiliary feedwater

system.

The licensee

determined that the inboard bearing

needed to be replaced.

This was confirmed with the vendor.

The work request

was initiated to

replace the inboard

pump bearing.

After replacement,

the turbine-to-

pump coupling was erroneously installed backwards.

While attempting to

remove the reversed

coupling,

several

other problems occurred.

First

the coupling had to be heated to be removed.

Not all of the oil from

the bearing replacement

had been cleaned

up and the torch was placed too

close causing

some

smoke

and in a later attempt,

a small fire.

Neither

caused

equipment

damage.

In pulling the coupling off the shaft, the

shaft

and coupling galled.

This necessitated

complete disassembly

and

replacement of the rotating element

and coupling.

During disassembly

10

the oil for the outboard bearing

was found discolored.

i>s indicated

that the outboard bearing

was really the one that had caused

the problem

(see section E4.1).

Problems with the

pump leaking occurred during reassembly.

The first

involved jacking bolts for removal of the stuffing box which were left

inserted too far on reassembly.

The second

involved the discovery that

the upper case to lower case

gasket

was slightly undercut in the

stuffing box 0-ring seal

area.

The licensee later discovered that the

gasket

undercut

problem had occurred in the past but had never

been

documented.

The third involved

a slight leak (1 drop every 4 seconds)

that stopped after the

pump was started

and its speed

increased

to 4100

rpm.

These

problems

caused

the limiting condition for operation

(LCO)

time to expire

and

a unit shutdown

was accomplished

(see section 01.2).

Post maintenance

testing included vibration testing, full flow testing,

and the verification of the

pump curve for the

new rotating element.

The inspector

observed the vibration testing of the

pump which was

successfully

accomplished

on recirculation

(procedure

OST-1411).

During

full flow testing of the

new rotating assembly,

performed using

procedure

OST-1080,

the operators

encountered

a situation where steam

generator

(SG) level

was high and flow needed to be secured.

The

operators

forgot that during the full flow test the recirculation line

was isolated.

The operators

closed the flow control valves, prior to

reestablishing

a recirculation flow path,

causing the

pump to be dead-

headed for about five minutes.

Procedure

OST 1080, step 37, established

recirculation flow, followed by the shutting of the flow control valves

in step 38.

These steps

were not followed.

Subsequent

inspection

by the licensee

and vendor

concluded that the

pump

was probably not damaged.

Testing was accomplished

by repeating

procedures

OST-1411

and OST-1080 which confirmed that the

pump was not

damaged.

Then EPT-115,

Dynamic test of Auxiliary Feedwater

Pump 1X-SA8,

Revision 2,

was used to verify the

pump curve.

These tests

had

satisfactory results.

The inspector

found that the maintenance

and testing problems that

caused

the

TDAFWP forced outage

were related to personnel

errors.

However, there were other factors associated

with these

problems that

bear further analysis.

These included the previous history of problems

during assembly of this

pump which had caused

rework,

and supervision

and monitoring of the work.

In addition, operator

performance

during

the post-maintenance

test should be analyzed collectively with the other

operator errors performed during this period to determine if their is

a

common relationship

(see Section 01.2).

The licensee

was performing

a

collective root cause investigation of the

TDAFWP forced outage errors

which was not complete.

The inspector considered

the root cause of the

maintenance

and testing errors unresolved

pending review of the

licensee's

root cause investigation

and resulting corrective actions.

These

issues

are considered

part of the overall

TDAFW forced outage

issue

and are included in the unresolved

item,

URI 50-400/97-09-01,

11

TDAFWP Forced Outage

Problems,

identified in section 01.2 of this

report.

Conclusions

H2

H2.1

The inspector

concluded that several

maintenance

and testing errors

caused

and extended

the forced outage.

An unresolved

item was

identified in relation to overall performance

in dealing with the

TDAF'l

(ith the normal service water pump breaker and discharge valve operation as referenced in procedure AOP-22, Loss of Service Water, General Section, and in training lesson plan AOP-SIM-3.07. Operators uiere unaware of this feature which con:ributed to a 1996 manual reactor trip event as described in LER 50-400/96-018-01. The inspectors observed numerous cases during review of 1996 and 1997 LERs where operator lesson plans were updated to include important information about how systems operate. However, the inspectors could not remember a single instance where a system description was called out for updating as a corrective action for an L'ER. The inspectors also held discussions with operators and training department personnel concerning their perception of system descriptions. The overwhelming opinion was that the system descriptions were not as good as training lesson plans in describing how systems work. In Inspection Report 50- E4 15 400/96-10, the inspector identified where the emergency boration function was not described in the Chemical and Volume Control System description (SD-107). This function was one of the most important functions of that system. The inspector concluded that these procedures, which are controlled documents, should contain current and accurate information about system design and operation to serve as reliable aids to operators and others who may reference them. This is identified as a weakness. Engineering Staff Knowledge and Performance Turbine- dri ven Auxi1iar Feedwater Pum Ins ection Sco e 37551 The inspectors observed the performance of engineering personnel in resolving problems identified from the performance of quarterly turbine driven auxiliary feedwater pump vibration testing. Observations and Findin s Section H1.2 discussed problems with the repair of the turbine-driven auxiliary feedwater pump. As a result of increased vibration found on the inboard pump bearing while performing quarterly pump testing (OST 1411), Engineering became involved to determine the cause of the problem. Vibration on the inboard bearing was approximately double what it had been in the previous test. Licensee engineering personnel were aware that at the pressure and flow being used, hydr'aulic pulsation was being experienced when using the recirculation line to the condensate storage<. tank. The line is not sized for full flow. NRC Bulletin 88-04, Safety-related Pump Loss, had war ned of flow instability at low flows while on recirculation. Flow instability becomes more 'severe as flow is decreased, and can cause pump damage from ump vibration, excessive forces on the impeller, and cavitation. The ulletin recommended that the limitations associated with these hydraulic phenomena be considered when specifying minimum flow capacity. The licensee's response to the bulletin, dated July 11 and November 1, 1988, did not identify any problems with the auxiliary feedwater system. The licensee had considered that the vibration readings could indicate a lack of stiffness in the rotating element and support components. The inboard bearing was considered one of those components. The licensee determined that the inboard bearing needed to be replaced. The decision was based solely on the vibration data which indicated little if any increase in vibration on the outboard bearing.'roblems with the rotating lement stiffness would entail a complete pump disassembly which was being considered if the bearing rep'lacement did not correct the vibration problem. The licensee confirmed with the pump vendor that the appropriate initial action would be to replace the inboard bearing. The bearing was replaced, but no problems were found with the bearing. E7 E7.1 E8 E8.1 16 After replacement, the pump coupling was inadvertently installed backwards, as discussed in section H1.2 of this report. This resulted in a complete pump disassembly and rotating element replacement. During disassembly the oil for the outboard bearing was found discolored. This indicated that the outboard bearing was really the -one that had caused the problem. Discussions with the vendor indicated that the balance drum on the outboard end can mask bearing problems in relation to vibration. The inspector observed that the licensee made a decision that the problem was a bad bearing without taking oil samples. The oil sample is a quick way to get an indication of bearing failure. The inspector considered that the licensee's troubleshooting plan did not include obt'aining and evaluating all available data for determining the cause of the problem prior to setting the course of action. Inspection Report 50-400/97-06 also discussed a problem with troubleshooting. In that report the licensee began executing a plan for determining the cause of a failed tast bus transfer without obtaining all available data. The inspectors considered the problem with the turbine-driven auxiliary feedwater pump similar, in that, had oil samples been taken, the correct bearing would have been initially replaced. The inspectors con'sidered the two examples a weakness in troubleshooting in relation to not obtaining and evaluating all available data prior to implementing a course of action. Conclusions A weakness was identified in troubleshooting iA relation to determining a course of resolution prior to obtaining and evaluating all available data. Quality Assurance in Engineering Activities S ecial FSAR Review (3~7531 ~A recent discovery of a licensee operating their facility in a manner contr ary 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. This issue is discussed in section E8.3 under Unresolved Item 50-400/96-04-04, Tracking FSAR Discrepancy Resolution. Hiscellaneous Engineering Issues (92700) Closed LER 50-400/96-013-00 50-400/96-013-01 and 50-400/96-013-02 Condition outside of design basis where RWST had been aligned with a non-seismically qualified system. This LER and its'upplements were issued to address connecting nonseismic portions of systems to seismic portions of systems. Systems 17 and components involved were the refueling water storage tank (RWST) lines to spent fuel pool cooling and the hydrotest pump; chemical addition lines to component cooling water and essential services chilled water; and boric acid tank (BAT) lines to the refueling water storage tank and recycle holdup tank. The inspector found that the corrective action was to declare the affected components inoperable when isolation valves at the seismic interface were opened. Corrective action for the BAT included a procedure revision to declare the BAT inoperable when pumping through the non-seismic piping. The inspector verified that a note was added to OP-107, Chemical and Volume Control System, in Revision 14. A similar change was made to OP-148, Essential Services Chilled Water System, in Revision 8, to declare the system inoperable when the chemical addition valves are open. For the RWST lines, similar actions were prescribed in OP-116, Fuel Pool Cooling and Cleanup, in Revision 9 for the RWST to spent fuel pool cooling, and OP-112, Containment Spray, in Revision 10 for the hydrotest pump. The corrective action for the component cooling water system was found inadequate as described in Violation 50-400/97-04-02 and will be reviewed under that item. The issue of operating the plant outside the design basis which resulted in violation of various TS LCOs was considered a non-repetitive, licensee-identified and corrected violation and is being treated as a Non-Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement Policy (50-400/97-09-06). These LERs are closed. = Closed LER 50-400/96-008-00 and 50-400/96-008-01: Reactor trip due to the failure of a switchyard breaker disconnect switch. This LER was issued due to a reactor trip/turbine trip caused by a switchyard disconnect failure. This issue was addressed'in NRC Inspection Reports 50-400/96-05 sections 01.2, 01.8. and E1.1; and 50- 400/96-07 section H8.2. The corrective action for the switchyar d disconnect problem was addressed in those reports. The inspector verified that thermography of the disconnects was being conducted to ensure that overheating does not occur. In addition, the inspector verified during refueling outage 7 that switchyard work was integrated into the site outage schedule. Engineering review of the pressurizer pressure master controller concluded that the controller worked as designed. The inspector reviewed the operations analysis of'he trip that was used to train the operators. The inspector determined that the analysis was thorough and emphasized the appropriate places where improvement was needed. The inspector reviewed the attendance sheets for the training and determined that operators were trained on the event. Performance during the September 1996 manual reactor trip, the January 1997 reactor trip, the June 1997 reactor trip, and July 1997 reactor trip showed that the training was effective in relation to limiting primary plant cooldown after the trip. The inspector considered that the information learned in relation to the normal service water pump and discharge valve logic was important to E8.3 include in the system description (SD-139), however, it had not been included. This observation is addressed in section E3.1. Section H8.4 of this report for LERs 50-400/96-018-00 and 01 further discuss normal service water pump problems. This item is closed. Closed URI 50-400/96-04-04: Tracking FSAR Discrepancy Resolution This URI was opened in NRC Inspection Report 50-400/96-04 to track the licensee's resolution of discrepancies identified between plant configuration, plant practices, procedures and/or parameters and the descriptions in the FSAR. A meeting was held on Nay 30, 1996, between NRC and CPSL to discuss the UFSAR Review and Upgrade Plan for the three CP8L nuclear facilities. The UFSAR Review and Upgrade Plan contained 5 basic elements: Accountability for FSAR sections, Performance of an initial FSAR review to identify significant discrepancies, Validation of selected FSAR sections, Deficiency Resolution, and Effectiveness assessment. The Harris Nuclear Plant (HNP) FSAR Improvement Plan was issued to licensee staff on Hay 14, 1996. The accountability element was implemented by assignment of FSAR sections to individual owners for initial review and ongoing maintenance. This was verified by the . nspectors review of the FSAR Section Responsibility Hatrix. The Initial FSAR Screening Review was performed by the individual section owners in accordance with Attachment 2 to the improvement plan, "Objective and Instructions for Performing Initial FSAR Section Reviews." The initial review was intended to be a qualitative review not a complete FSAR validation. Individual discrepancies including minor typographical changes were documented on Condition Reports (CRs) and entered into the Corrective Action Program. Each FSAR Discrepancy processed as a CR received a 10CFR50.59 unreviewed safety question determination screening. When discrepancies required FSAR changes, corrections to the FSAR were documented on FSAR Change Request Review Approval Forms (RAFs) .in accordance with administrative procedure AP- 603, FSAR Revisions. Individual FSAR discrepancies were categorized per AP-603 as: Category A (Potential Operability or Reportability Concern), Category B (Technical or Substantive Discrepancy Requiring Reconciliation of FSAR), Category C (Low Significance Low Impact Technical Discrepancy) and Category D (Editorial Items). Procedure AP- 603 provided target FSAR discrepancy disposition guidelines by category for completion of operability/reportability evaluations, CR evaluations, RAF completions, and completions of CR actions. The initial screening effort was completed on September 1, 1997 with 5 Category A CRs (1 open), 68 Category B CRs (31 open), 200 Category C CRs (61 open), and 62 Category D CRs (14 open) for a total of 335 FSAR discrepancies identified. The inspectors reviewed the Reactor Trip System (RTS) Safety System Functional Evaluation which was performed as an FSAR validation effort using nuclear industry consultants. The review assessed RTS engineering and maintenance and compared the design of the RTS to FSAR section 7.2. 19 The review identified 2 strengths and 25 issues of which 14 were categorized as CRs. All the issues were thoroughly evaluated and dispositioned and tracked under. the licensee's corrective action program. The inspectors reviewed the following FSAR Discrepancy CRs and the related RAF packages: 9602260 9601796 9700865 9603593 9600936 9403625 9502976 9600140 9700087 9602590 9601667 9602546 9601338 9602268 9602534 9600699 9601946 9602683 9603161 The sample selected included the closed category A CRs and 15 closed, category B CRs. The inspectors concluded that the CRs were properly categorized, additional unresolved safety question items which should have been reported were not identified in the population of category B CRs reviewed. The RAF packages reviewed were found to be in accordance with AP-603 requirements, however the timeliness goals for RAF and CR completion were not being met. During review of CR 9601338/RAF 2160 the inspectors identified that the revision to FSAR table 9.2.2-3 "Typical System Flowrates During Normal Operation" for the Component Cooling Water System failed to include the 160 gallons per minute flow to the Sample Heat Exchanger Package which was a non-safety related load. Since this was a non-essential load and was isolated on a safety injection signal, this had no safety impact. The licensee initiated CR 97-04222 to correct this issue. The initial FSAR screening review was thorough. Issues from the FSAR review and Reactor Trip System SSFI were properly categorized and entered into the corrective action program for resolution. Hany CRs were identified and 67%%d of the CRs remained open as well as several of the RAF packages. Further review of FSAR discrepancy CRs is planned as part of routine corrective action assessment. The inspectors concluded that the licensee was accomplishing the FSAR upgrade work in accordance with the FSAR Improvement Plan. This item is closed. IV. Plant Su ort Radiological Protection and Chemistry (RPEC) Controls G 1 C t it71750 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 . 20 P1 Conduct of EP Activities P1.1 General Comments 71750 The inspectors observed portions of an emergency preparedness drill conducted on September 9, 1997 from the simulator control room and tne Emergency Operations Facility. The drill was being appropriately monitored by drill controllers. The inspectors found that when transitioning back to the plant, security personnel at the road gate were prepared to deny the inspectors access, had they been drill participants, because they were not on the licensee's emergency response organization roster. Access was not denied and security management took immediate corrective action. S1 S1.1 Conduct of Security and Safeguards Activities Gener al Comments 717~50 The inspector observed security and safeguards activities during the 'onduct of tours, observation of maintenance activities, and the emergency preparedness drill, and found them to be generally good. Compensatory measures were posted when necessary and properly conducted. A comment related to the emergency drill is contained in section Pl.l. Control of Fire Protection Activities F1.1 General Comments 71750 F2 F2.1 The inspector observed fire protection equipment and activities during the conduct of tours and observation of maintenance activities and found them to be generally acceptable (see section H1.2 for one exception). Status of Fire Protection Facilities and Equipment Safe Shutdown Anal sis 71750 90712 The licensee initiated Condition Report 97-03861 to document a problem found during review of the safe shutdown analysis under Engineering Service Request 9500433. The problem involved a lack of adequate fire protection measures for several cables associated with the emergency diesel generator fuel oil transfer pump electrical cable for each train. The cable was routed through the unit 2 auxiliary building which was never completed. No fire suppression or detection was provided in that area. The inspector walked down the area with the associated engineer and verified that fire watches were established. The issue was appropriately reported to the NRC under 10 CFR 50.72 and 10 CFR 50.73 (LER 50-400/97-020-00). 21 V. Hang ement Heetin s Exit Heeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on September 12, 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. 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, 18C Electrical Systems J. Collins, Manager, Maintenance J. Donahue, Director. Site Operations, Harris Plant J. Eads, Supervisor, Licensing and Regulatory Programs W. Gurganious, Superintendent, Environmental and Chemistry H. Hamby, Supervisor, Regulatory Compliance H. Keef, Manager, Training B. Meyer, Manager, Operations B. Morrison, Manager, Outage and Scheduling 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; Superintendent, Mechanical Systems D. Tibbitts, Manager, Nuclear Assessment C. Vandenburgh, Hanager, Regulatory Affairs NRC Y. Rooney, Harris Project Manager, NRR H. Shymlock, Chief, Reactor Projects Branch 4 0 IP 37551: IP 40500: IP 61726: IP 62707: IP 71707: IP 71750: IP 92700: IP 90712: 22 INSPECTION PROCEDURES USED Onsite Engineering Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems Surveillance Observations Maintenance Observation Plant Operations Plant Support Activities Onsite Followup of Events In-Office Review of Written Reports of Non Routine Events at Power Reactor Facilities ITEHS OPENED, CLOSED, AND DISCUSSED ~0ened 50-400/97-09-01 50-400/97-09-02 URI VIO 50-400/97-09-03 NCV 50-400/97-09-04 NCV 50 '00/97-09-05 NCV 50-400/97-09-06 NCV TDAFW forced outage problems (Section 01.2 and H1.2). Failure to properly check main control room chart recorder (Section 02.1). Failure to test valve 1CS- 196 constitutes a violation of TS surveillance requirement 4.3.2. 1 (Section H8. 1). Failure to perform procedure OST-1052 between March and June 1996 (Section H8.2). Failure to test PAL door caused violation of TS 4.6. 1.3.a. (Section H8.5) Operation outside design basis by connecting non- seismic piping to RWST causing TS violations. (Section E8.1) Closed 50-400/97-09-03 NCV 50-400/97-09-04 NCV 50-400/97-09-05 NCV 50-400/97-09-06 NCV 50-400/96-002-01 LER 50-400/96-017-00 LER 50-400/96-017-01 LER 50-400/96-021-00 LFR 50-400/96-018-00 LER Failure to test valve 1CS-197 constitutes a violation of TS surveillance requirement 4.3.2. 1 (Section HS. 1). Failure to perform procedure OST-1052 between March and June 1996 (Section H8.2). Failure t'o test PAL door caused violation of TS 4.6. 1.3.a. (Section H8.5) Operation outside design basis by connecting non-'eismic piping to RWST causing TS violations. (Section E8. 1) Failure to properly perform TS surveillance testing (Section H8.1) . Failure to perform surveillance testing required by TS (Section H8.2). Failure to perform surveillance testing required by TS (Section M8.2). Inadequate post maintenance testing f'ollowing repairs on containment isolation valve 1SP-208 (Section H8.3). Manual reactor trip due to loss of normal service water (Section H8.4). 50-400/96-018-01 LER 50-400/96-005-00 LER 50-400/96-013-00 LER 50-400/96-013-01 LER 50-400/96-013-02 LER 50-400/96-008-00 LER 50-400/96-008-01 LER 50-400/96-04-04 URI Discussed 50-400/97-020-00 LER 23 Hanual reactor trip due to loss of normal service water (Section H8.4). Failure to properly test the containment building outer personnel air lock door (Section H8.5). Condition outside of design basis where RWST had been aligned with a non-seismically qualified system (Section E8.1) ~ Condition outside of design basis where RWST had been aligned with a non-seismically qualified system (Section E8.1) . Condition outside of design basis where RWST had been aligned with a non-seismically qualified system (Section E8.1). Reactor trip due to the failure of a switchyard breaker disconnect switch (Section E8.2). Reactor trip due to the failure of a switchyard breaker disconnect switch (Section E8.2). Tracking FSAR discrepancy resolution (Section E8.3). Inadequate fire protection provided for safety-related EDG fuel oil transfer pump cables resulting in operation outside design basis (Section F2.1).