ML18016A242
| ML18016A242 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/20/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18016A239 | List: |
| References | |
| 50-400-97-10, NUDOCS 9712040078 | |
| Download: ML18016A242 (25) | |
See also: IR 05000400/1997010
Text
~
~
U. S. -NUCLEAR REGULATORY COMMISSION
REGION II
Docket No:
License
No:
50-400
Report
No:
~ ~
50-400/97-10
Licensee: .....:
Carolina
Power
8 Light (CP8L)
t
~
~
Faci 1 ity
I
I
Shearon Harris Nuclear Power Plant, Unit 1
Location:
5413 Shearon Harris Road
New Hill. NC 27562
Dates:
September
14 - October 25,
1997
Inspectors:
J.
Brady, Senior
Resident
Inspector
G. MacDonald, Project Engineer
(Sections.M8.2,
El. 1,
E8.1)
Approved by:
M. Shymlock, Chief. Projects
Branch 4
Division of Reactor
Projects
97i2040078 97ii20
ADOCK 05000400
8
EXECUTIVE SUMMARY
Shearon Harris Nuclear
Power
Plant, Unit 1
NRC Inspection
Report 50-400/97-10
This integrated
inspection included aspects
of licensee operations,
maintenance,
engineering,
and plant support.
The report covers
a 6-week
period of resident inspection; in addition, it includes the results of
announced
inspections
=by a regional projects inspector
.
~0erati ons
~
Operations
per formance during the period was acceptable.
(Section 01.1)
~
Self-assessment
activities were acceptable.
The root cause
investigation
and Plant Nuclear, Safety Committee discussion
related to
the turbine-driven auxiliary. feedwater
pump
(TDAFWP) forced outage
was
good.
(Section 07.1)
P
~
A violation was identified for Failure to Establish
and Implement
Operating
and Surveillance
Procedures.
Three examples
were identified:
1) opening the feed regulating valves prior to opening the associated
block valves,
2) not placing
a second
pump in service at the
required point causing
a turbine runback,
and 3) failing to establish
adequate
procedures for when to place
a second
pump in service
and when
a turbine runback occurs.
(Section 08. 1)
Maintenance
Maintenance
and surveillance activities observed
were being properly
conducted.
Maintenance
and Operations
personnel
performing the
surveillances
were appropriately sensitive to potential
problems
and
appropriately performed peer checking to identify potential
problems
before they impacted plant operations.
(Sections Hl.1 and M2.1)
~
A noncited violation was identified for failure to establish
and
implement
TDAFWP Maintenance
procedures.
Two examples
were identified:
1) failure to follow a maintenance
procedure for installation of the
and 2) failure to establish
an adequate
procedure for
gasket cutting and assembly of the
(Section
H8. 1)
~
A fourth example of the Failure to Establish
and Implement Operating
and
Surveillance
Procedures
was identified for deadheading
the
(Section H8.1)
En ineerin
In general,
Engineering acti vities were being adequately
conducted in
accordance
with requi red procedures.
A noncited violation was
identified for the unapproved
extension of a temporary modification due
date.
(Section El. 1)
Communications within engineering
management
related to the
needed
improvement.
(Section
E7.2)
~PI tt
The control of contamination
and dose for the site was good and was
attributable to good teamwork between the various departments.
(Section
R1. 1)
1
Emergency
Preparedness
activities, in general.
were adequately
'onducted.
(Section Pl. 1)
The performance of Security and Safeguards
activities were good.
(Section Sl.l)
I
Fire Protection activities were being adequately
conducted.
(Section'1.1)
IP
Re ort Details
Summar
of'lant Status
Unit 1 began this inspection period at 100 percent
power.
The unit remained
at essentially
100 per cent power for the rest of the period.
01
Conduct of Oper ations
01.1
Gener al
Comments
I. 0 erations
a.
Ins ection 'Sco
e
71707
The inspectors
conducted
frequent reviews of ongoing plant operations
including plant simulator training activities.
Simulator activities
were observed during the, emergency exercise
and are also addressed
in
Section Pl.l.
b. Observations
and Findin s
,. In general.
the conduct of operations
was professional
and safety-
conscious.
Routine activities were adequately
performed.
Operations
shift crews were appropriately sensitive to plant equipment conditions
and maintained
a questioning attitude in relation to unexpected
equipment
responses.
Abnormal
and emergency activities observed during
observation of plant simulator training was good.
c.
Conclusions
Operations
performance during the period was acceptable.
02
Operational
Status of Facilities and Equipment
02.1
En ineered Safet
Feature
S stem Walkdowns
71707
The inspectors
used Inspection
Procedure
71707 to walk down accessible
portions of the following ESF systems:
~
Control
Room Ventilation (FSAR Sections
9.4. 1 and 7.3. 1)
Equipment operability, material condition,
and housekeeping
were
acceptable
in all cases.
Several
minor discrepancies
in System
Description SD-173, Control
Room
HVAC System,
Revision
6 were brought to
the licensee's
attention.
The inspectors identified no substantive
concerns
as
a result of these
walkdowns.
07.1
Quality Assurance in Operations
Licensee Self-Assessment
Activities
Ins ection Sco
e
40500
During the inspection period, the inspectors
reviewed multiple licensee
self-assessment
activities, including:
I
~
Plant-Nuclear Safety Committee
(PNSC) meetings
on September. 17,-
1997; September.25,
1997October
10, 1997,
and October 22,
1997;
~
.
~
-
p
f II(
~ I
~
.
Nuclear Assessment
Section Audits on Radwaste
Shipping
(HNAS97-134), Operations
(HNAS97-109),
and Corrective Action (HNAS97-151);
Obser vations
and Findin s
~
~
"\\I
II
~
The inspector considered
the root cause analysis for the turbine-driven
pump
(TDAFWP) forced outage
and the
PNSC meeting
(September
25,
1997) discussing the root cause analysis
good.
There was
considerable
discussion
at the
PNSC meeting concerning the broad
implications of the overall problems associated
with the
TDAFWP forced
outage
and recovery efforts.
The
PNSC discussed
the inspector 's
observations
documented in Inspection Report 50-400/97-09.
section 01.2
and Ml.2.
The observations
included
common ties between the operations
events
and recent training weaknesses
identified during initial licensed
operator qualification exams.
and also with recent requalification
failures.
These aspects
were included in the cor rective actions for
condition report
(CR) 97-04094
and involved development of skills
remediation plans for some of the recent initial licensed class
and
revision of the instant senior
reactor operator
(SRO) program to
incorporate
lessons
learned.
An additional observation
from the 97-09
Inspection Report, in relation to generator
synchronization
problems,
was also included in the corrective actions for
CR 97-04094.
PNSC
discussions
revealed that the plant and simulator do not perform.
similarly on synchronization.
Participation in the
PNSC by the members
was good.
In addition, the chairman did a good job of controlling the
flow of the meeting.
The specific issues
are discussed
in Sections
08. 1
and M8.1.
Conclusions
Self-assessment
activities were acceptable.
The root cause
investigation
and
PNSC discussion
related to the
TDAFWP forced outage
was good.
08
08.1
.3
Hiscellaneous
Operations
Issues
(92901)
Closed
URI 50-400/97-09-01:
TDAFWP Forced Outage
Problems
This item was left unresolved
based
on review of the root, cause
determination-for the
TDAFWP problems.
The inspector reviewed'the root
cause investigations for condition reports
(CR) 97-04094.
97-04109.
97-04112-1.
LER 50-400/97-022-00.
and attended
the
PNSC meeting that:
discussed
the root cause analysis
for these 'condition reports
on
(September
25, 1997).
Condition report 97-04109 dealt with feedwater regulating block valves
not being opened prior to opening..the
feedwater,regulating
.valves.
The
inspector
had observed .i.n Inspection Report-50-400/97-09 that the<<
opening of the regulating valves prior to opening the block valves
was
contrary to:step
102 'of General
Procedure
.(GP)
005,
Power
Oper ation "
(Hode 2 to Hode 1); Revision 18.-
The root cause,
as determined
by the
investigation,
was that,.the, pre-evolution brief did not discuss the
operation of the feed regulating valves
as
a contingency source-of
water.
Consequently,
when they were needed.
the operator
assigned to
operate
them was not fully prepared,
and did not tollow the procedure.
A contributing cause identified was that the location in the procedure
of the steps to open the valves
was incorrect.
The inspector concluded
that this was based
on the current operation of the plant.
The
PNSC
discussion
concluded that the steps
were adequately
located for how the
simulator operated.,
However,
a
PNSC action item was opened to
investigate
why the simulator and plant were different for the
synchronization evolution.
The failure to follow procedure
GP-005 in
opening the feed regulating block valves
was
a violation of'S 6.8
~ 1 and
is designated
violation 50-400/97-10-01,
example
1, Failure to Establish
and Implement Operating
and Surveillance
Procedures.
Condition Report 97-04112-1 dealt with a turbine runback that occurred
while placing
a second
main feed
pump in ser vice.
The root cause
was
identified as the senior control operator
not following the note prior
to step 131.c of GP-005 which stated that
a second
feed
pump was to be
placed in service prior to 300 psig first stage turbine pressure after
exceeding
6.0 million pounds per hour total feed flow.
The senior
control operator
had stated that he thought the turbine runback
was at
370 psig instead of the 310 psig stated in the procedure.
Procedure
APP-ALB-020, Hain Control Board,
Revision
6 had listed the setpoint at
370 psig and was the one the senior
control operator
was recently
familiar with.
The failure to follow procedure
GP-005 in placing
a
second
main feed
pump in service
was
a violation of TS 6.8. 1 and is
designated
violation 50-400/97-10-01 'xample 2, Failure to Establish
and Implement Operating
and Surveillance
Procedures.
Two previous condition reports
addressed
the setpoint issue.
CR 95-
02730 addressed
changes to procedures
after the setpoint
was changed
during the performance of EPT-093, Turbine First Stage
Pressure
Data,
after refueling outage six.
Engineering Service Request
95-00946,
Revision 1, was issued in April 1996 to implement the corrective action
08.2
4
and identified that AOP-012,
Malfunctions,
and APP-ALB-016,
Hain Control Board,
needed to be changed.
CR 96-01254-2 addressed
a
turbine runback that, occurred
May 4,
1996 where
a second
feed
pump was
being placed in service at
a value too -close to the runback -set point.
Both of these condition =reports
had identified that procedures
were
inconsistent
in relation to the turbine runback setpoint.
These
procedures
included GP-005,
System,
and
APP-ALB-020.
The only procedure that was changed
was procedure
GP-005.
The personnel
error
which caused
the September
1997 runback could have
been prevented
by proper management prioritization of the identified
corrective -actions,.for, the.3995
and
1996 condition reports;
Consequently,
the inspector concluded that the operator would not have
had the incorrect value -stored in his mind had the proper prioritization
occurred.
..
,
'
-.;
.*
~ < '
~
~
p
'
\\
The inspector confirmed that the following conflicting statements
identified in the root cause investigation were in the procedures..
General
Procedure
(GP) 005,
Power Operation
(Mode 2 to Mode 1),
Revision 18, section 5.0; step
131 states that
a turbine runback will
occur at approximately
310 psig.
-.The second
main feedwater
pump should
be started prior to exceeding
300 psig turbine first stage
pressure
and
after exceeding
6.0 and before 6.7 million pounds
per
hour total feed
,flow.
Operating
Procedure
134.01,
System,
Revision 8,
Section 5, states that
a second
feedpump should be started
when total
flow to the steam generator s is in the range of 6.0 to 6.7 million
pounds per hour total feed flow.
Feedwater Malfunctions,
Revision 12, states that above
330 psig first stage pressure
(60K),
a
turbine runback will occur.
APP-ALB-020, Main Control Board,
Revision 6, states for windows 1-1, 1-2. 1-3. 1-4,
and 2-2, that
a
turbine runback occurs at greater
than 370 psig first stage turbine
pressure.
The inspector concluded that the conflicts in where the
turbine runback occurs
and when to start
a second
pump had
been identified by two previous
CRs and had been outstanding f'r
approximately two years.
The failure to establish
adequate
procedures
related to GP-005,
and APP-ALB-020 providing
different values for the turbine runback
and inconsistent
guidance
on
when the second
main feedwater
pump should be started is considered
an
additional
example of a violation of. TS 6.8.1
and is designated
violation 50-400/97-10-01,
example 3, Failure to Establish
and Implement
Operating
and Surveillance
Procedures.
Closed
URI 50-400/97-01-01:
Tracking Operator
License Conditions in
the
This item was opened to review whether unqualified operators
were
allowed to stand watch due to a lack of an immediate license condition
verification log in the main control
room.
The inspector
discussed this
issue with numerous
licensee
personnel
and managers
including the
operations
manager, training manager,
and various shift superintendents.
The inspector
also reviewed various electronic mail messages
sent after
some recent requalification failures.
The inspector
was convinced that
the current practice of Training providing immediate notification of
08.3
failures to the Operations
manager. via electronic mail was effective.
The inspector
observed that the electronic mail was forwarded by the
.
operations
manager
to all shift superintendents
with instructions not to
allow the identified individuals to stand watch.
The inspector
also
reviewed .watch, standing lists to verify that qualified individuals stood
watch.
The combination of these
convinced the inspector that only
qualified personnelhave
stood watch.
The inspector
reviewed -a .beta test .of the Personnel
Qualification
Tracking System which'.when data
has,been
completely loaded will provide
the i'mmediate. tracking function for the. shift superintendent.
The
operations
support organization
was beginning the process of loading the
data into the program.
The inspector
was
shown
how training 'could
immediately place
a flag 'on.'the qualifi'cation of an individual that had
failed requalification.
The inspector
concluded that the program
addressed
the
NRC concern in this -area.
This item is closed.
Closed
LER 50-400/96-008-'02:.Reactor
Trip due to the failure of a
switch yard breaker
disconnect
switch.
This supplement
was issued
October
14,
1997 to update informati.on on normal service water
pump
problems.
The information was already provided in LER 96-018-01
and was
already considered
when supplement
1 was closed.
This item is closed.
II. Maintenance
Conduct of Maintenance
General
Comments
Ins ection Sco
e
62707
The inspectors
observed all or portions of the following work
activities:
~
WR/JO 97-AKRS1
Install N-42 detector current
~
WR/JO 97-AHHN1
Unload solidified waste ingot
~
WR/JO 96-ABFMl--
Install-spent fuel rack in "B" spent fuel pool
~
WR/JO 97-AJZSl
Ground Isolation on
OC bus
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.
Peer-checking
and self checking techniques
were being used.
When
applicable,
appropriate radiation control measures
were in place.
Conclusions
Maintenance activities observed
were being properly conducted.
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:
~
0, Monitor OAI-21WG-1101 Calibration,
Revision
7
Nuclear Instrumentation
System
Power
Range
N-42
Calibration. Revision
9
OST-1005
Control
Rod and
Rod Position Indicator Exercise
Monthly Interval, Revision
7
~
OST-1124
-6.9 kv Emergency
Bus Undervoltage Trip Accuatuation
Device Operational
Test,
Monthly Interval,
Modes 1-2-
3-4, Revision
10
Observations
and Findin s
The inspector
found that the testing
was adequately
performed.
During
the performance of HST-I0045 technicians
perf'orming the surveillance
found that the detector current values that were input were incorrect.
The error resulted
from an improper transfer of the engineering
data to
the surveillance data sheet.
The technicians
found this prior to the
completion of the test
and prior to instrumentation
channel
N-42 being
declared operable.
As
a result,
a portion of'he surveillance
had to be
reperformed.
The error occurred
due to inadequate
self-checking.
Condition Report 97-047-33
was written to address
the data transfer
error.
The inspector
found that the peer checking performed during this
surveillance
was positive and was the technique that resulted in the
problem being found.
During performance of OST-1005 the operators
found
a potential
problem
with the in-hold-out switch related to the time it took for the rods to
move from step
224 to step
225 for shutdown
bank "C".
The operators
appropriately stopped the test
and formulated
a troubleshooting
plan.
The operators
found that for the last step the switch had to be held in
the out position for
a longer period of'ime.
Condition Report 97-04483
was written to address this issue.
The operators
also found that the
same problem had been encountered
during the previous performance
but
had not been
documented.
The test
was then successfully
completed.
The
inspector
found the operators to be appropriately sensitive to problems
they encountered
during testing.
MB
H8.1
Conclusions
The surveillance
performances
were adequately
conducted.
Maintenance
and.Operations
persorinel
performing the survei llances were appropriately
sensitive to potential
problems
and appropriately performed peer
checking to identify potentia'1
problems before they impacted plant
operations..
Miscellaneous
Maintenance
Issues
(92700.
92902,
90712)
1
Clo'sed
URI 50-400/97-09-01:
TDAFWP Forced:Outage
Problems
This item.was left unresolved
based
on review of..the root cause
determination for the:turbine-driven auxiliary feedwater-
pump
(TDAFWP)
problems.-'he
inspector
reviewed the root cause investigation for
condition report 97-04094.
LER 50-400/97-022-00,
and attended the
PNSC
meeting that discussed
the root cause investigation.
The root cause
investigation
and
LER concluded that the root cause of the coupling
being installed backwards
was
a personnel
error caused
by not performing
adequate self checking.
In addition, other causes
were fatigue due to
overtime. and time pressure
due to the coupling being hot.
The overtime
had been properly authorized in accordance
with procedure
AP-012,
Control of Overtime Hours,
Revision 4.
The inspector concluded that the
root cause
was accurate
and that the failure to install the coupling
properly was
a violation of procedure
CH-H0071, Ingersoll-Rand Turbine
Driven Auxiliary Feedwater
Pump Size 4X9 NH-7 Disassembly
and
Maintenance,
Revision 6.
Corrective actions
included counseling
and
lessons
learned for maintenance
department
personnel.
This non-
repetitive. licensee-identified
and corrected violation is being treated
as
a Non-Cited Violation, consistent with Section VII.B.l of the
NRC
Enforcement Policy and is designated
NCV 50-400/97-10-02,
Inadequate
TDAFWP Maintenance Activities.
During TDAFWP reassembly
the
pump leaked
and was reassembled
several
times.
The investigation determined the problem to be
a gasket cutting
and reassembly
procedure
problem.
The procedure
reassembled
the
pump
such that the outer stuffing box was inserted prior to setting the upper
casing
on the gasket.
Thus. the stuffing box 0-ring could be affected
by the gasket being cut oversize or under size, without any method of
evaluating the 0-ring seating surface
adequacy prior to pressurizing the
pump.
The licensee
determined that the proper way,to perform this task
was to cut the gasket slightly oversize in the 0-ring area,
and then
retrim the gasket with the upper casing installed, prior to inserting
the stuffing box.
This would ensure that the 0-ring seating
area
was
smooth.
The root cause of the split casing gasket
problem was
identified as
a lack of adequate
technical
guidance in the Technical
Manual
and procedure
The technical
manual did not provide any
guidance
on gasket cutting for the split casing
pump, although the
vendor was aware that specific gasket cutting techniques
were necessary.
Consequently.
the procedure also did not have any specific guidance.
Corrective actions included review and revision of split casing
pump
maintenance
procedures
and maintenance
department training.
The
~
~
8
licensee did find. some minimal gasket cutting instructions in the motor
driven auxiliary feedwater
pump procedures.
The motor driven pumps are
also split casing
pumps but are
a different model.
The inspector
concluded that the root cause investigation
was accurate
and that the
inadequate
procedure
was
a violation of TS 6.8. 1.
This non-repetitive,
licensee-identified
and corrected violation is being treated
as "a Non'-
Cited Violation, consistent with Section VII.B.1 of the
NRC Enforcement
Policy and is considered
'a second
example of NCV 50-400/97-10-02,
Inadequate
TDAFWP Maintenance Activities.
The root -cause..of .the .TDAFWP deadheading
was attributed to a lack of
situational
awareness:regarding
equipment conditions related to flow
path and cooling status
of:,equipment being tested.
A contributing cause
included
a failure to relay 'important,information during the test to the
key decision
makers 'on shift regarding .the status of the
recirculation.
A second
cause
included that the risks and consequences
associated
with securing auxiliary"feedwater flow with recirculation
isolated were not adequately
reviewed/assessed.
The inspector
considered that there
was adequate
guidance in Procedure
OST-1080,
Pump
1X-SAB Full Flow Test Quarterly Interval,.
Revision 1. concerning securing
feed flow in steps
37 and 38, which
direct reestablishing
the recirculation flow path prior to securing
feed
flow.
The purpose of'hose steps
was to ensure that the
pump was not
deadheaded.
The failure to follow procedure
OST-1080 in securing
flow prior to establishing
a recirculation
flow path
was
a violation of TS 6.8. 1 for failure to follow procedures
and is
designated
violation 50-400/97-10-01,
example 4, Failure to Establish
and Implement Operating
and Surveillance
Procedures.
Closed
LER 50-400/96-022-00:
Wiring Discrepancy
Found in Reactor
Auxiliary Building Ventilation System Circuitry
This
LER was originally discussed
in NRC Inspection Report 50-400/96-11
section
M8.1 and described
a self-disclosing condition in which
a wiring
lead was terminated incorrectly in the "A" train reactor auxiliary
building ventilation system.
The
LER remained
open pending the
licensee's
completion of further corrective actions to train maintenance
and quality control personnel
on this event.
The inspector's
reviewed the valida'tion package for LER 50-400/96-022-00
and verified through inspection of training records that required
training was completed.
This item is closed.
E1
Conduct of Engineer ing
III. En ineerin
El. 1
En ineerin
Service
Re uests
Ins ection -Sco
e
37551
I
The inspectors
reviewed all or portions of the following Engineering
Service Requests
to determine if procedure
EGR-NGGC-005
Engineering
Service Requests,
Revision 5, was being followed:
~ ,
'-
ESR 9500278 Installation of Additional
BWR Spent
Fuel
Racks in "B"
Spent
Fuel Pool. Revision 0:
.
~
ESR 9700747
AH-7 (1A-SA)* Operability Determination,
Revision
0
l
~
ESR 9700745
1BD-48 (PCV-8400c) Simulated
Open Signal,
Revision
0
~
ESR 9700024
Computer
Room HVAC, Revision 3
Observations
and Findin s
In general,
the
ESRs reviewed were adequate.
ESR 9700024,
Computer
Room HVAC, was prepared to resolve
an issue for
Technical Specification 4.7.6.d.3 which requires the main control
room.
to be maintained'at
a positive pressure of 1/8 inches of mercury gauge
with respect to adjacent
areas
(computer room).
The issue
was
originalty identified during surveillance testing
when pressure
differential testing of adjacent
areas to the main control
room was not
performed.
An additional
concern
was identified that if the computer
room was pressurized,
the main control
room could not meet its
surveillance
requirement.
A 10 CFR 50.59 safety evaluation
was written
to remove requirements
in the
FSAR to pressurize
the computer
and
communication
room and
FSAR Review and Approval
Form (RAF) 2082 was
prepared.
An Engineering Disposition Engineering Service Request
(ESR)
9600243
was prepared to address
which dampers to reposition to prevent
computer
room pressurization.
Clearance
tags were hung to implement
9600243.
LER 96-007-00
was prepared for this issue.
'emporary Modification 9700024 included
FSAR changes
which were
different from the
FSAR page markups
(RAF 2082) initially prepared.
Licensing rejected
RAF 2082 due to these differences.
In April, 1997,
the clearance
tags were removed
and dampers
were locked in their safety-
related position per
ESR 9700024.
On May 24,
1997,
ESR 9700024 Revision
3 was approved
by the Plant Vice President
designee to move the
expi ration date for the temporary modification to August 1,
1997, after
completion of refueling outage
RFO-7.
Temporary modification extensions
past the next refueling outage required approval, by the Plant Vice
President
or designee
per licensee
procedure
EGR-NGGC-005,
Engineering
Service Requests,
Revision 4, Attachment
3 section A3.6.3.
On July 22,
E7.1
E7.2
10
1997, engineering
personnel
processed
an extension of temporary
modification 9700024 from August 1,
1997, till May 1,
1998.
This
extension
was inot reviewed
and approved
by the Plant Vice President
or
designee
as required.
After being informed by the inspectors of the
unauthorized
extension.
licensee
management
took corrective action which
included initiation of condition report 97-0448,
review of the temporary
modification,:.and issuance of a
memo to all members of the Harris
Engineering Section regarding procedural
requi rements for temporary
modification approval
and extension. " The
FSAR change for this item was
rescheduled .to.,be included in the December,
1997,
FSAR amendment
package.
I
The extension .of temporary modification 9700024 past
May 24,
1997; was
a
violation of licensee.~procedure
EGR-NGGC-005;
Engineering Service
Requests,
Revision 4.. 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 (NCV 50-400/97-10-03).
Conclusions
In general,
Engineering activities were being adequately
conducted in
accordance
with required procedures.
A noncited violation was
identified for the unapproved
extension of a temporary modification due
date.
Quality Assurance in Engineering Activities
S ecial
FSAR Review
37551
A recent discovery of a licensee operating their facility in a manner
contrary to the Updated Final Safety Analysis Report
(UFSAR) description
highlighted the need for a special
focused
review that compares plant
practices.
procedures
and/or parameters
to the
FSAR descriptions.
While
performing the inspections
discussed
in this report, the inspectors
reviewed the applicable portions of the
FSAR that related to the areas
inspected.
The inspector s did not find any additional discrepancies
other than those identified by the licensee.
TOAFW Pum
Problems
Ins ection Sco
e
37551
The inspector
reviewed the root cause investigation for condition report
97-04025 which described
engineering troubleshooting
problems associated
with the turbine-driven auxiliary feedwater
pump
(TDAFWP) forced outage
and attended
the associated
PNSC meeting conducted
September
25,
1997
(Section 07. 1).
Inspection
Report 50-400/97-09
(Section
E4. 1) discusses
a weakness
in troubleshooting
related to this issue:
The root cause
investigation also addressed
rebaselining
the pump at
a different flow
point.
Observations
and Findin s
.11
E8
E8.1
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
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 ll and November
1,
1988,.did'not describe
any problems with the auxiliary feedwater
system.
There was. no mention of the licensee.'s
investigation
and response to
NRC
Bulletin 88-04, in the root cause investigation,
LER.
or at the
PNSC
meeting.
Although the inspector
had informed licensee
management of the
bulletin at the time. the-maintenance
was being performed,
the inspector
found that the system engineer
who performed the root cause
assessment
had not been told about. it.
The inspector
concluded that poor
communication within engineering
management
was the cause of the
problem.
Conclusions
Communications within engineering
management
related to the
needed
improvement.
Miscellaneous
Engineering Issues
(92700)
Closed
LER 50-400/96-024-00:
Common
Mode Failure in the Reactor
Auxiliary Building Electrical
Equipment Protection
Rooms Ventilation
System
This
LER was discussed
in NRC Inspection Report 50-400/96-11 section
E8.2 and described
a
common
mode failure that could prevent both Reactor
Auxiliary Building (RAB) Electrical
Equipment Protection
Rooms Supply
Fans
AH-16A and AH-16B from operating.
This failure was related to two
nonsafety-related
ionization detectors
in the AH-16 ductwork that are
wired in parallel to form a fire detection
zone permissive.
Due to the
system's
design,
a failure of either detector would preclude satisfying
the fan's start permissive
and prevent the fans from maintaining area
temperatures
to ensure the operability of safety-related
equipment,
following a safety injection signal.
This deficiency had been
identified on November 21,
1996,
and the licensee
concluded that the
condition was contrary to the design basis of the plant.
The safety significance of this deficiency was low because
the fans
would be manually started
as directed
by operating
procedures
following
a safety injection signal.
The fans were not credited in the Harris
Plant Probabilistic Safety Assessment
and would not affect core damage
frequency.
The
LER was due to inadequate
original plant design.
Review of FSAR
sections 9.4.5, 7.3.1,
3. 1,
and 8.3.1 confirmed that the plant's design
basis for the
RAB Electrical
Equipment Protection
Rooms Supply Fans
. 12
AH-16A and, AH-16B called for the fans to be designed for single failure
and that the use of fire detection
zone
151 for both fans was
an
original design basis
common
mode failure.
The inspectors
reviewed
modification
ESR 96-00573 which added
new fire detectors
in new fire
protection
zone
151A to eliminate the
common
mode failure potential.
The inspectors
reviewed the circuit modifications,
performed
a
modification walkdown,'nd reviewed the post modification testing.
\\
Based
on review of the circuit .changes
and plant walkdowns the
inspectors verified that the new detectors
and
new fire zone eliminated
the potential
common
mode failure.
The inspectors
noted that the post
modification testing verified the fan trip interlocks within each safety
train but did not positively verify that fan operation
was not affected
by fire defector, actuation in the opposite train fire zone.
Despite not
positively verifying that fire detection would not impact fan operation
in the opposite train, the inspectors
determined that the modification
was adequate
based
on the post modification testing performed
and the
circuit reviews
and plant walkdowns.
This original design basis
common
mode failure was
a violation of 10 CFR 50 Appendix A. Criterion 3 - Fire Protection.
This non-repetitive,
licensee-identified
and corrected violation is being treated
as
a Non-
Cited Violation, consistent with Section VII.B.1 of the
NRC Enforcement
Policy
(NCV 50-400/97-10-04).
This
LER is closed.
IV. Plant
Su
ort
R1
Rl.1
C.
Radiological Protection
and Chemistry
(RP8C) Controls
General
Comments
Ins ection Sco
e
71750
The inspector
observed radiological controls during the conduct of tours
and observation of maintenance activities.
Observations
and Findin s
The inspector
found radiological controls to be acceptable.
The general
approach to the control of contamination
and dose for the site was good.
Teamwork between the various departments
continued to be
a major
contributor to the good control of dose.
Conclusions
The control of contamination
and dose for the site was good and was
attributable to good teamwork between the various departments.
~
P1.1
Conduct of EP Activities
General
Comments'
.=13-
Ins ection Sco
e
71750
The inspectors'bserved
Emergency
Preparedness
activities to determine
their effectiveness.
b; *'Observations
and Findin s
I
~
S1
~
Sl.l
a.
~ The Harris Emergency Exercise
was conducted
On October
7,
1997.
The
Exercise
was conducted with full NRC participation.
The evaluation of
the exercise
was documented in Inspection
Report 50-400/97-11.
Si'mulator
Control
Room activities were observed
during
NRC participation
in the drill and found to be acceptable.
-The operations shift crew was
observed to be followi'ng Emergency
and Abnormal Operating Procedures.
'Conclusions
Emergency-Preparedness
activities, in general,
were adequately
conducted.
Conduct of Security and Safeguards Activities
General
Comments
Ins ection Sco
e
71750
The inspector
obser ved security and safeguards
activities during the
conduct of tours, observation of maintenance activities,
and the
emergency
preparedness
dri 1 1 .
Observations
and Findin s
The inspector
found the performance of these activities was good.
Compensatory
measures
were posted
when necessary
and properly conducted.
One communications
issue
was identified by the licensee during the
Emergency
Preparedness
exercise.
The inspector
found that Security
management
was appropriately investigating
and resolving this
observation.
Conclusions
The performance of Security and Safeguards activities were good.
14
F1
Control of Fire Protection Activities
Fl. 1
General
Comments
a.
Ins ection Sco
e
71750
I
The inspector
obser ved Are protection equipment
and activities during
the conduct of tours
and observation of maintenance activities.
I
1
I'
i
b.
Observations
and Findin 5 "
The inspector
found the fire protection activities to be acceptable.
c.
Conclusions
J
f'ire
Protecti'on activities were being adequately "conducted.
V. Mana ement Meetin s
Xl
Exit Meeting Summary
The inspectors
presented
the inspection results to members of licensee
management
at the conclusion of the inspection
on October 30.
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.
Licensee
15
PARTIAL LIST OF PERSONS
CONTACTED
D.. Batton, Superintendent,
On-Line Scheduling
D. Braund, Superintendent,
Security
B. Clark, General
Manager,
Harris Plant
A. Cockeri ll, Superintendent,
I&C 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
M. Hamby, Supervisor,
CAP/OEF
M. Ke'ef,=Manager'<i Training
B. Meyer, Manager,
Operations
K. Neuschaefer,
Superintendent;
Radiation Protection
W. Peavyhouse,
Superintendent,
Design Control
W. Robinson,
Vice. President,
Harris Plant
S. Sewell. Superintendent,
Mechanical
Systems
D. Tibbitts, Manager.
Nuclear Assessment
C.
VanDenburgh,
Manager,
Regulatory Affairs
NRC
V. Rooney.
Harris Project Manager,
M. Shymlock, Chief, Reactor Projects
Branch 4
16
INSPECTION
PROCEDURES
USED
IP 37551:
Onsite Engineering
IP 40500:
Effectiveness of Licensee Controls in Identifying, Resolving,
and
Preventing
Problems
IP 61726:
Sur veil lance
Obser vations
IP 62707:
Maintenance
Observation
IP 71707:
Plant Operations
IP 71750:.
Plant Support Activities
IP 90712:
In-office Revi,ew of LERs
IP 92700:
Onsite.Followup-of Events
- =
Followup - Plant Operations
IP 92902:
Followup - Maintenance
50-400/97-10-02
50-400/97-10-03
50-400/97-10-04
NCV
Closed
~Den ed
50-400/97-10-01
ITEMS OPENED,
CLOSED,
AND DISCUSSED
r'
S
"I
Failure to establish
and implement operating
and
surveillance
procedures;
4 examples
(Section 08.1:
Section M8.1).
Inadequate
TDAFWP maintenance activities;
2 examples
(Section M8.1).
Computer
Room
HVAC tempor ary modification extension
(Section E1.1).
Common
Mode Failure in the Reactor Auxiliary Building
Electrical
Equipment Protection
Rooms Ventilation
System
(Section E8.1).
50-400/96-022-00
50-400/96-024-00
50-400/97-09-01
50-400/97-10-02
50-400/97-10/03
50-400/97-10-04
50-400/97-01-01
50-400/96-008-02
LER
Wiring discrepancy
found in Reactor Auxiliary Building
~
ventilation
system circuitry (Section M8.2).
LER
Common
mode failure in the Reactor Auxiliary Building
Electrical
Equipment Protection
Rooms Ventilation
System (Section E8.1).
TDAFWP forced outage
problems
(Section
MB.1).
NCY
Inadequate
TDAFWP maintenance activities;
2 examples
(Section M8.1).
Computer
Room
HVAC temporary modification extension
(Section E1.1).
NCV,
Common
Mode Failure in the Reactor Auxiliary Building
Electr ical Equipment Protection
Rooms Ventilation
System (Section
EB. 1).
Tracking Operator
License Conditions in the
(Section 08.2)
LER
Reactor Trip due to the failure of a switch yard
breaker
disconnect switch.
(Section 08.3)