ML18016A374

Foreign Material Exclusion

seals

(Section F5.2).

The licensee's

1998 Nuclear Assessment

Section

assessment

of the

facility's fire protection program was of good quality and effective in

identifying fire protection program performance to management.

Corrective actions in response

to the identified assessment

issues.

were

being implemented

and completion was anticipated in 1998 (Section

F7. 1).

l

I

Summar

of Plant Status

Unit 1 began this inspection period at

100K percent

power.

The unit

maintained approximately

100K power for the entire period.

01

Conduct of Operations

01.1

General

Comments

a.

Ins ecti on Sco

e

71707

I. 0 erations

.The inspectors

conducted

frequent

reviews of ongoing plant operations to

determine if procedures

were followed and technical specification

(TS)

requi rements

were .met.

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.

Operators

were appropriately

responding to plant

alarms

and abnormal conditions.

In particular, the performance of post-

maintenance testing

on the rod control system

caused

a rod sequencing

problem,

as discussed

in section

M1.2,

and resulted in entering

Abnormal

Operating

Procedure

AOP-l, Malfunction of Rod Control

and Indication

System,

Revision ll.

Operators appropriately

responded to this

situation

and the shift superintendent

was involved in the trouble-

shooting to ensure that the problem was appropriately resolved.

One

operations error was described

in section

M7. 1 related to a missed

surveillance.

c.

Conclusions

Operations

performance

during the period was acceptable.

Operators

appropriately

responded to alarms

and abnormal conditions.

02.2 R~li

a.

Ins ection Sco

e

71707

The inspectors

observed

weekly alarm testing to determine if it

adequately satisfied Final Safety Analysis Report

(FSAR) commitments.

Observations

and Findin s

The inspector

observed that the sections of Operation

Management

Manual

OMM-1, Conduct of Operations,

Revision 25 applicable to this test

contained

references

to FSAR sections

9.5.2

and American National

Standards

Institute (ANSI) N18.7/ANS3.2.

The inspector

observed that

the ANSI standard

discussed

periodic testing of the communications

system.

FSAR section 9.5.2,

Communications

Systems,

described

inspection

and testing in subsection 9.5.2.7,

which indicated that all

systems

were to be inspected

regularly and undergo operational

checks to

ensure service readiness

and effectiveness.

The inspector

found that

the operational

checks

were implemented

by OMM-1.

In addition, the

licensee

indicated that the inspection

and testing requirements

were

~implemented per checklist in the preventive maintenance

system under

preventive maintenance

route CL-E0013.

The inspector

found that

OMM-1

did not have any test acceptance criteria.

When operators

were asked

what criteria they used to determine test

adequacy,

they responded that

they could hear the alarm,

and with some uncertainty.

the fact that

there was

an absence of a communications

system trouble alarm.

The

criteria stated

were not described'in

OMM-1.

The licensee initiated

CR 98-00353 to address this issue.

The licensee

determined that the approach to alarm testing did not follow the general

guidance laid out in procedure

AP-004, Description of the Plant

Operating

Manual, Revision 7.

Tests that fulfill regulatory commitments

other than

TSs were to be placed in periodic test procedures

(OPT,

MPT,

etc.).

The alarm tests

were regulatory commitments.

and identified as

such in procedure

OMM-1 by providing an "R" next to the steps that

requi re the weekly alarm testing.

The licensee

intends to remove this

test from OMM-1 and write an operational

performance test

(OPT) with the

appropriate

acceptance criteria.

The

PM checklist was also being

reviewed for inclusion in a maintenance

performance test

(MPT).

The inspector

found that. the

FSAR testing

and inspection criteria were

being implemented.

However, the testing

and documentation criteria were

weak.

Conclusions

Communications

system alarm testing

was being conducted

as committed to

in the

FSAR, although

documented

acceptance criteria were considered

~ weak.

07

07.1

(Iuality Assurance in Oper ations

Licensee

Sel f-Assessment

Activities

Ins ection

Sco

e

40500

During the inspection period, the inspe'ctors

reviewed multiple licensee

self-assessment

activities, including:

.

Plant Nuclear Safety Committee

(PNSC) meetings

conducted

on

February ll and 19.

1998;

Nuclear Safety Review Committee

(NSRC) meeting conducted

on

February

18,

1998;

~

Nuclear Assessment

Section Audits on Environmental

and Radiation

~ Control Assessment

(HNAS98-005);

Observations

and Findin s

The portion of the

NSRC meeting observed exhibited

a good questioning

attitude.

The inspector also reviewed

NSRC comments

on the corrective

action program

as captured

by the training manager in a February

20,

1998, E-Mail.

NSRC comments in the E-Mail were focussed

on industry

experience with various aspects

of the program and provided, best

practice

recommendations

for the site to consider.

The program was in

the final development

process

for a corporate corrective action

procedure

which site personnel

were reviewing.

The

PNSC meeting

on February ll, 1998,

discussed

the steam generator

blowdown event root cause investigation

(CR 975320)

from December

1997.

A discussion of that meeting is contained in section

E8. 1.

The meeting

was good and in general

exemplified

a good questioning attitude.

For the portion of the

PNSC meeting observed

on February

19,

1998. the

inspector

found the committee thorough, with one exception.

The

exception dealt with the discussion of a root cause investigation for

condition report

(CR) 98-00340,

pertaining to a missed surveillance

on

January

29,

1998, for not performing

a shutdown margin determination

with shutdown

rod bank

"C" on the hold bus

(TS 4. 1. l.l.a).

The root

cause investigation indicated that

a condition report

(CR 97-04513)

had

identified an inconsistency

between

TS 3. 1.3. 1, 3. 1. 1. 1

~

and 4. 1. 1. l.a.

on October 6,

1997.

The root cause

described that the .inconsistency

in

the requirement for shutdown margin had caused

the operations

crew to

miss the surveillance

on January

29,

1998.

The inconsistency

was

determined to be the root cause,

and was agreed to and approved

by the

PNSC.

However, the inspector determined that the root cause

was not the

inconsistency,

but lack of management

action to the

1997

CR when the

inconsistency

was first identified.

The inspector

observed that in

1997, the surveillance

was not missed.

Also, at the time, the

I

08

08.1

operations

and regulatory affairs organizations

had collectively

determined the appropriate

meaning of the TS.

However, the failure to

communicate that determination to the remaining operators

resulted in

the surveillance being missed in 1998 and was determined

by the

inspector to be the root cause.

As

a result,

no corrective action was

identified to address

the root cause of the missed surveillance.

After

the inspector

discussed this issue with the

PNSC chairman,

the

PNSC

reconvened 'and appropriately

addressed

this item.

This item will be

reviewed further after submission of the

LER.

Conclusions

Self-assessment

activities were acceptable,

even though the

PNSC's

discussion

associated

with a root cause investigation for

a missed

surveillance did not identify that

a root cause

had not been adequately

addressed.

Miscellaneous

Operations

Issues

(92901)

0 en

Violation 50-400/97-09-02:

Failure to properly check main

control

room chart recorder.

The inspector

reviewed the violation

response,

dated

November

12 '997

and the licensee's

corrective actions

which indicated they would be complete

by December

1.

1997:

The

corrective actions were completed,

but were not effective,

as evidenced

by an additional occurrence identified by the licensee.

However, the

licensee

also chose not to close the condition report for the violation

based

on the additional occurrence.

Condition Reports

97-05121

and

97-05167 were written to address

the additional

instance

which occurred

on November 30,

1997 where main control

room chart recorders

were not

properly marking and were not detected

by the operators

over two shift

turnovers

and one marking period.

The inspector

reviewed the root cause investigation for the additional

occurrence,

completed'n

December

18.

1997, which identified that the

wide range recorder for steam generator

"8" was not marking on recorder

LR-477 (green pen).

In addition, the root cause investigation

identified that the chart had not been set

on the correct time and was

approximately

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months off.

Procedure

OMM-16, Operator

Logs,

Revision 14, indicated in paragraph

5. 1.2.b that the chart recorders

are

to be checked

once per shift to ensure that they are marking properly

and timing correctly.

The chart had not been timing correctly and nine

different individuals had not identified this 'although the chart was

initialed and marked with the time the check

was performed.

The

inspector

found that the root cause investigation findings collectively

displayed

a general

misunderstanding

of the

OMM-16 requirement

and

management

expectations

for its implementation.

The inspector discussed this root cause investigation with the licensee

who intends to address

the timing aspect

during real time training for

the operators

(an identified corrective action in the root cause

investigation).

The licensee stated that the failure to time the

recorder properly was listed as

an inappropriate act in the initial

version of the root cause investigation,

but was

removed in the final

version.

That decision

was based

on focussing

on recorder

pen marking

as opposed to the broader issue of operators

checking the recorders

once

per shift to ensure they would perform their function of trend recording

(marking and timing correctly).

This narrow focussing diluted the

significance of the overall finding of the root cause investigation.

After discussion with the licensee,

the licensee

informed the inspector

that corrective actions identified in the root cause

were being

reassessed

and that

a revised

response

to violation 50-400/97-09-02

was

being prepared.

This is considered

an additional

example of'failing to implement

procedure

OMM-16 as requi red by TS 6.8. l.a.

This failure to follow

procedures

is designated

violation 50-400/98-01-01,

example

1; Failure

to Properly Check Main Control

Room Chart Recorders.

Conclusions

The licensee identified an additional

example of fai ling to ensure

main

control

room chart recorders

were properly marking and timing'hich

was identified as

a violation.

Corrective action for violation 50-400/

97-09-02

had not been effective and additional corrective actions

were

identified from a root cause investigation for the additional

occurrence.

The root cause investigation

found that chart recorder

timing had not been properly checked but it was not addressed

as

an

inappropriate act because

the investigation

was focussed

on marking

only'.

This narrow focussing diluted the significance of the overall

finding of the root cause investigation.

0 en

Violation 50-400/97-13-01:

"C" Steam Generator

Blowdown (SGBD)

System Water Hammer.

This Unresolved

Item (URI) was opened in NRC Inspection

Report 50-400/

97-13 to further review the removal of safety-related

snubber

1BDH-169

adjacent to the containment isolation valve, without entering

a

TS

action statement

and for review of the root cause

and repetitive nature

of water

hammer events

on the

SGBD System,

including their continued

occurrences.

Additionally, the inspectors

reviewed the treatment of

this event

under the maintenance

rule 10 CFR 50.65.

Refer to section

MB. 1 of this report for the discussion of SGBD water

hammer event review

under the maintenance

rule and section

E8. 1 for the discussion of the

review of the root cause evaluation of this event.

The inspectors

reviewed

CR 9705329,

Operator Logs'ngineering

Service

Request

(ESR)

9700949 Revision

0

~

and

TS sections 3.7.8, 3.6.3.

and

TS

Interpretation

(TSI)87-004,

Revision 5.

No Equipment Inoperability

Record

(EIR) was written following removal of the snubber

due to

miscommunication

and misunderstanding

of ESR 9700949.

EIR 97-1352

was

written after questioning

by the

NRC.

The snubber

was restored within

the TS action statement

time requirements.

The inspectors

concluded

that the licensee's

CR evaluation of the condition was adequate.

An

additional

work request

(97AHRZ1) involving snubber

1BDH-169 was

4

reviewed

and the inspectors verified that an EIR was opened for this

work activity and

TS requirements

were met.

The inspectors

concluded

that this was

an isolated event

and that the licensee did not violate TS

requirements.

Hl.l

Conduct of Maintenance

General

Comments

Ins ection Sco

e

62707

II. Maintenance

The inspectors

observed all or portions of the following work

activities:

~

.

WR/JO .98-AACD1

"B" diesel

lube oil changeout

~

WR/JO 98-AA7B-6

"B" sequencer

Agastat relay inspection

~

WR/JO 98-AAQM1

Fuse holder

replacement

in PIC-3

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 thei r 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.

The inspector discussed

with the licensee the circumstances

surrounding

a paper absorbent

wipe that was found in the "B" emergency diesel

generator

lube oil tank on January

29,

1998 during lube oil replacement.

Condition Report 98-00327

was issued to address this condition.

The

inspector

observed that there were two tanks,

one on the suction to the

lube oil pumps

and one on the discharge

from the engine.

The wipe was

in the tank on the suction to the three lube oil pumps.

The wipe was

found during performance of work under

WR/JO 98-AACD1 to change the lube

oil.

While removing the lube oil below a baffle that separates

the

upper

and lower half of the tank, workers noticed the wipe came floating

out from the side of the tank.

The workers concluded that the wipe had

been left in the tank since it was cleaned during the refueling outage

(RF07).

The inspector

reviewed procedure

HMM-011, Cleanliness,

Housekeeping,

(FME), Classification of Work Practices.

Revision 14,

and its predecessor

procedure

AP-619, Foreign Material

Exclusion.

Section 5.3.5 of HMM-11 discusses

FHE zones

and provides the

minimum requirements

for each

zone.

The lube oil sumps

had been

a

Zone 4

FHE area.

As discussed

in the Operability Evaluation,

ESR

9800061,

the licensee

has identified that this area

should have included

\\

C.

M1. 2

logging of material in and out of the tank.

Section 5.3.5 indicates

that supervisors

are responsible'for

setting appropriate

2one

4

FME

controls.

The controls for the lube oil tank were inadequate to ensure

that the wipe was

removed prior to the diesel

generator

being declared

operable..

This is identified as

a violation of TS 6.8. l.a and procedure

MMM-011 for fai ling to follow procedure to establish

adequate

foreign

material exclusion criteria for the diesel

generator

lube oil tank.

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.

This item is designated

NCV 50-400/98-

01-02 'nadequate

Foreign Material Exclusion Controls for Diesel

Generator

Lube Oil Tank.

The operability evaluation

review is contained

in section

E1.1.

The Agastat relay inspection

was prompted

by a

10 CFR 21 notification.

from the vendor

about

a potential

bad solder

connection.

The licensee

found three relays installed that were suspect.

All had performed

without problems during prior. load sequencer

testing.

All three relays

were replaced.

Engineering

performed the inspection of the relays after

they were

removed

by maintenance

personnel

and inadequate

solder

connections

were found.

The inspector considered

the establishment

of

acceptance criteria by Engineering to be good.

Conclusions

h

Maintenance activities observed

were adequately

performed.

A paper

wipe

was found in the "B" diesel

generator

lube oil tank that was apparently

left there during the 1997 refueling outage

(RF07).

This was identified

as

a Non-Cited Violation for failing to establish

adequate

foreign

material exclusion controls.

When inspected

due to a

10 CFR 21'otification,

several

Agastat relays in the load sequencers

were found

with inadequate

solder connections

and were replaced.

Rod Control

Ur ent Failure Alarm

Ins ection Sco

e

62707

The inspector

observed trouble-shooting

and post-maintenance

testing for

a rod control urgent failure alarm received

on February

24.

1998.

The

work was performed under

WR/JO 98-ABMA1.

Observations

and Findin s

The inspector observed that initial trouble-shooting to determine the

cause of the urgent failure alarm adequately

determined the cause of the

alarm.

The trouble-shooting

found that

a multiplexer relay in the

1BD

rod control logic cabinet

had failed.

The failure occurred while the

operators

were trying to insert control

bank "D".

After the relay was replaced

and,the urgent fai lure alarm was cleared,

the post maintenance

testing required

rods to be moved in two steps

and

out two steps.

When the testing. was accomplished,

the wrong group of

J

control

bank. "D" stepped

in first causing the rod sequence

to be

improper (> 2 steps

between groups).

The trouble-shooting

had failed to

recognize that the bank and group counters in the rod control system

had

become misaligned

when the urgent failure occurred.

The inadequacy

in

the trouble-shooting

resulted in inadequate

work order instructions

(WR/JO).

The instructions

should have required the counters to be

checked

and set to the proper settings

comparable to the rod height for

the Bank "D" group I and II rods.

Procedure

ADM-NGGC-0104, Work

Management

Process,

Revision 3, indicated in 9.8.7.9.d that the work

instructions shall contain

a level of'etail appropriate to the

complexity of the task to be accomplished.

The fai lure to have adequate

work instructions for repai r of the rod control system is

a violation of

TS 6.8. 1.a.

and procedure

ADM-NGGC-0104.

This is considered

a second

example of fai lure to follow procedures

and is designated

violation

50-400/98-01-01,

example 2, -Inadequate

Work Instructions for Rod Control

System.

The trouble-shooting of the rod sequencing

problem was initially not

well coordinated.

However,

once the shift superintendent

of operations

was involved the trouble-shooting

process

improved considerably

and

provided favorable results.

The rod control counters

were reset

and the

post-maintenance

test

was conducted successfully.

Conclusions

A violation was identified for inadequate

rod control system work

instructions.

The inadequate

work instructions

were the result of

incomplete initial trouble-shooting.

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:

OST 1036,

Shutdown Margin Calculation

Modes 1-5, Revision

11

MST I0269,

Lo-Lo Tave P-12 Interlock (T-0422) Operational

Test,

Revision

8

MST I0320,

Train

B Solid State Protection

System Actuation Logic

and Master Relay Test,

Revision

18

Observations

and Findin s

The inspector

found that the testing

was adequately

performed.

Conclusions

The surveillance

performances

observed

were adequately

conducted.

M7

Ouality Assurance

in Maintenance Activities

H7.1

Hissed Surveillance

on Shutdown

Mar in

Ins ection Sco

e

40500

The inspector

reviewed the circumstances

surrounding

a January

29.

1998.

missed surveillance

for shutdown margin.

The inspector

reviewed

TS

3. 1.3. 1, 3. 1. 1. 1,

and 4. 1. 1. l.l.a, condition report 98-00340

and

attended

the

PNSC meeting where the root cause investigation

was

discussed

(Section 07. 1).

Observations

and Findin s

The operators

had placed the shutdown

bank

"C" rods

on the hold bus to

facilitate replacement of a power supply.

Placing rods

on the hold bus

will illuminate the rod control urgent failure alarm.

Alarm Response

Procedure

APP-ALB-013 for rod control urgent 'fai lure di rects the

operator

to Procedure

AOP-001. Halfunction of Rod Control

and Indication

Systems.

The operators

declared the rods

on the hold bus inoperable per

TS 3. 1.3. 1.

The oncoming shift identified that

a shutdown margin

evaluation

had not been conducted

as required

by TS 4.,1. 1. 1. l.a when the

rods were declared

inoperable.

Condition report 98-00340

was written to

address

that failure.

The root cause investigation described that operators

did not correctly

interpret the

TS wording and therefore,

failed to perform the shutdown

margin calculation.

TS 4. 1. 1. 1. l.a requires

a shutdown margin be

performed within one hour after

a control rod(s) is determined

inoperable.

After identification by the oncoming shift. the

surveillance

was accomplished

approximately

19 minutes after the TS

surveillance

4. 1. l.l.l.a requi red one hour time limit.

The root cause investigation also noted that condition report 97-04513

was written on October 6,

1997 to identify that there

was inconsistent

wording between

TS 3. 1.3. 1., 3. 1. 1. 1,

and 4. 1. 1. 1. l.a.

The condition

report identified that the surveillance could be missed since there

was

nothing to point an operator to TS 4. 1. 1. 1. l.a when

TS 3. 1.3. 1 was

entered for a rod control urgent fai lure alarm.

The condition report

was written after

a rod control urgent fai lure alarm had been received.

The inspector

noted that

CR 97-04513

was still open

and that action

had

been assigned

to train operators.

However, there

was no interim action

identified to clarify the identified inconsistency.

The inspector

observed that the licensee

was already

aware of the

inconsistency

on January

29,

1998, but had not promptly addressed

the

issue.

There were no interim measures

in place to alert operators to

the identified inconsistency

and operator training had not been

completed.

Consequently,

the occurrence of the January

29 '998,

missed

surveillance

can

be directly attributed to management

not implementing

interim corrective actions for

a previous condition report.

The root

cause investigation identified corrective actions which included

a

10

direct link between the alarm response'rocedure

and the shutdown margin

TS.

The fai lure to conduct

a shutdown margin evaluation within the required

one hour is considered

a violation of TS 4. 1.1. 1. 1.a

and is designated

violation 50-400/98-01-03,

Failure to Conduct

Shutdown Margin

Surveillance Within One Hour.

Conclusions

A fai lure to conduct

a shutdown margin calculation

as required

by

Technical Specification Surveillance

Requirement

4. 1. 1. 1. l.a.'hen

control rods were declared

inoperable

was identified as

a violation.

Miscellaneous

Maintenance

Issues

(92902)

0 en

URI 50-400/97-13-01:

"C" Steam Generator

Blowdown Water

Hammer

,

A significant water

hammer event occurred

on the "C" SGBD system piping

on December

22 '997.

The maintenance

rule data

base for the steam

generator

blowdown system

was reviewed.

The inspectors

observed that

the licensee

was documenting

system

and equipment failures in the

maintenance

rule data

base including water

hammer events.

The

SGBD was

currently in A(l) status

due to valve stroke time issues

unrelated to

the water

hammers;

The licensee

reviewed this event

and the scoping of the

SGBD system at

a

Maintenance

Rule Expert panel

meeting.

The panel thoroughly discussed

the issue

and concluded that the event did not constitute

a maintenance

rule preventable

functional failure as presently

scoped.

The panel

determined that the present

scoping

was adequate

and that the plant

corrective action program was adequately

and appropriately tracking

resolution of the

SGBD system water

hammer problems.

The expert panel

meeting

on the issue

was thorough

and exhibited

a proper safety focus.

Additional reviews of this event are contained in Section

E8. 1.

Conduct of Engineering

III. En ineerin

Diesel Generator

Lube Oil Tank

Pa

er

Wi e

Ins ection Sco

e

37551

The inspectors

reviewed Engineering Service

Request

(ESR) 9800061,

Operability Assessment-

Wipe Found in 1B-SB

LO Tank, Revision

0 to

determine if procedure

EGR-NGGC-005,

Engineering Service Request.

Revision 5,

was being followed.

ESR 9800061 evaluated

the operability

of the diesel with the paper wipe in the lube oil tank.

Observations

and Findin s

11

The

ESR evaluated

the probable location of the wipe in the tank and

concluded that it was most likely crimped between

one of the baffle

plate sections

and its mounting point. which probably held it in place

unti 1 the baffle plate was

removed to allow access

to the tank.

The

wipe had

a crimp in it.

In discussing

the

ESR with the licensee.

the

inspector learned that the licensee

had placed

one of these wipes in a

barrel of oil and after several

days it had sunk to the bottom.

If that

had happened

in the tank the pumps would probably have sucked

up the

wipe.: In addition, the conclusion

was based

on the fact that the engine

had been operated

75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months since the last refueling outage,

which was

the last time the tank was opened

and that the suctions to the three

lube oil pumps should

have picked up

a loose wipe.

The

ESR also

evaluated

what would have happened if the

pumps

had picked up the wipe.

The

ESR concluded that the wipe most likely would have

been shredded

and

captured in the

10 micron duplex strainer

down stream of the pump.

The

shredded

theory was supported

by a statement

from a knowledgeable diesel

engine vendor engineer

who was fami liar with these

pumps

and had seen

a

higher strength cotton rag pass

through similar screw type pumps during

factory testing.

Conclusions

The engineering operability evaluation for a paper wipe found in the

diesel

generator

lube oil suction tank was thorough

and cohcluded that

the wipe would not have affected the diesel.

Containment

Sum

Concerns

Ins ection Sco

e

37551

The inspector

reviewed licensee actions to an investigation of concerns

related to potential

loose parts in the containment

sump that was

identified in CR 98-00295 to determine if the concerns

were properly

addressed.

During initial construction four brackets

and attached

threaded

studs

were weld to the top edge of pipes located in the bottom

of the containment

sump.

The pipes are suction pipes for containment

spray

and residual

heat

removal

pumps.

The brackets

were used during

construction to attach foreign material

exclusion cover over the suction

pipes.

These brackets

were not part of permanent plant design

and were

not being controlled.

The potential existed that

a bracket or part

could come loose

and fall into the pipe,

damaging

one of the pumps.

It

was noted that during the past refueling outage

a part of a bracket

was

found loose.

Observations

and Findin s

The inspector

observed

several

team meetings that were conducted to

determine the short term Justification for Continued Operation.

The

team was composed of several

members

from the Engineering Organization.

In addition,

a regulatory affairs person with root cause

and

human

1.

12

factors training was assigned to assist.

The team's investigation

found

that

a portion of the bracket

had

come loose

and was

removed during the

past refueling outage

(RF07).

The engineer

who removed the bracket

was

on the team.

In addition,

a design control engineer

from a different

organization

was assigned

responsibility to be an independent

assessor

of the information the team gathered.

The independent

assessor

was

assisted

by the regulatory affairs team

member in the

human factors

and

root cause .investigation aspect.

The inspector

found that only one

member of the team had been involved with the containment

sump work in

RF07, the engineer

who removed the portion of the bracket.

The rest of

the team

and the independent

assessor

were.all

independent of the

RF07

containment

sump work.

During RF07, the issue with the brackets

was addressed

as part of the

containment liner and

sump issues.

The liner was discussed

in NRC

Inspection Report'50-400/97-04.

As part of the liner issue the sumps

were regrouted to eliminate leakage of borated water from the

sump to

the gap between the containment

and the liner.

During the regrouting,

one of these brackets

was apparently

found loose

when bumped

by an

individual involved with the work.

Engineering

addressed

the loose

bracket in ESR 9700374,

Sealing of Recirculation

Sumps,

Revision 1, with

a statement

in Section

9, Installation Instruction, that "if feasible,

remove the temporary metal brackets that are welded to the 30" pipe

penetration."

The inspector

found no other statements

concerning the

brackets

in ESR 9700374 through revision 2.

The team conducted

a short term operability evaluation which was

documented

in ESR 9800042,

Revision 0.

The

ESR was based

on interviews

and reviews of documents.

A containment entry was planned but found not

to be necessary

based

on first hand information from engineers,

quality

control inspectors,

and workers who were in the sump

and involved with

the sump regrouting effort.

The licensee

found pictures which showed

large portions of the bracket.

These pictures

agreed with the

descriptions

obtained

from the interviews.

The combination of the

pictures

and interviews,

combined with documentation'ere

considered

sufficient information by the licensee to perform the

ESR.

The inspector

reviewed the

ESR,

observed

the pictures of the bracket.

and discussed

the team's findings with licensee

personnel.

The team was

thorough

and objectively approached

the identified problems.

The team

found that only the portion of the bracket that was loose

had been

removed.

The team considered

what would happen if a bracket broke off.

This included seismic

and hydraulic flow analysis of the broken off part

to determine whether it would be carried into the

sump in an accident

situation.

The basis for the determination that the part would not be

carried into the

sump was:

~

Seismic

and hydraulic (flow) loads

imposed during design basis

events

are low.

E7

E7.1

E7.2

13

~

The one bracket that

came loose was

removed during RF07.

The

remaining brackets

were strength tested during

RF07 by striking

with a one pound

hammer.

No others

were found to have failed.

~

Grouting activities completed during

RF07 provide more than

adequate

support for the brackets.

The licensee

concluded that the recirculation

sumps

and the residual

heat

removal

and containment

spray systems

were operable.

The brackets

are planned to be removed during RF08.

A root cause investigation

was

prepared

and was presented

to the Plant Nuclear Safety Committee

on

February

19, .1998.

The presentation

was observed

by the inspector.

Conclusions

The short term operability determination for containment recirculation

sump brackets

was adequate.

It concluded that foreign material

exclusion

cover brackets installed during construction

could remain in

the

sump and the

sump would still perform its intended function.

The

conclusion

was based

on tack welds having been strength tested

during

the outage

(RF07),

on calculations

which showed that if the brackets

came loose they wouldn't be transferred into the sump,

and that grout

installed during

RF07 would hold the brackets in place.

Quality Assurance in Engineer ing Activities

S ecial

FSAR Review

37551

F

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

per forming the inspections

discussed

in this report, the .inspectors

reviewed the applicable portions of the

FSAR that related to the areas

inspected.

The inspectors

did not find any additional discrepancies

other than those identified by the licensee.

Trendin

of Cor orate Condition

Re orts

Ins ection Sco

e

40500

The inspector

reviewed

NRC violations for the past several

years to

determine if trends existed.

The inspector also discussed

with the

resident

inspectors

at the Brunswick and Robinson Nuclear Plants

any

trends related to common activities such

as corporate

procedures

or

activities.

The inspector also reviewed trending of deficiencies for

the corporate nuclear procedures

used.

b.

Obser vations

and Findin s

-14

The inspector

observed that corporate

personnel

use the Harris

corrective action program to document

adverse conditions.

The licensee

explained that

a separate

subunit of the Harris, corrective action

program was

used for corporate

generated

condition reports.

Trending of

the corporate condition reports

was conducted

by Harris plant personnel,

separate

from the Harris trending program.

However, trend reports

were

not generated

for the corporate subunit like they were for the Harris

plant generated

condition reports.

The inspector

observed that

a number of the new Nuclear Generation

Group

(NGG) procedures

were identified in NRC inspections

as having errors

and

were the subject of NRC enforcement action.

The errors included:

~

allowing configuration changes

to the plant without providing

=appropriate

design verification,

~

not requiring monitoring of occupational

exposure to radiation by

declared

pregnant

wo~en likely to receive

a dose in excess of ten

percent of the applicable .limit of 500 milli rem,

~

not specify'ing time requirements

for the updating of Environmental

Qualification Data

Packages

to maintain them current for installed

plant equipment.

~

not controlling the computer

software design process to ensure

that design activities did not affect software installed at the

sites,

and

~

allowing clearance

records

not to be designated

as Quality

Assurance

Records.

The specific

NRC Inspection

Reports

where these errors were documented

are 50-325.324/97-02,

50-325.324/96-16

50-325,324/97-12

and 50-325,324/

97-13 for the Brunswick facility, and 50-400/97-04

and 50-400/97-12 for

the Harris facility.

- The specific procedures

involved include

Procedures

EGR-NGGC-0005.

DOS-NGGC-0002.

EGR-NGGC-0156,

EGR-NGGC-0007,

CSP-NGGC-2501,

2502,

and 2503.

and OPS-NGGC-1301.

The errors identified above suggest

a trend in corporate procedural

inadequacy

which is of concern for two reasons:

~

Corrective actions

implemented to address

specific procedural

inadequacies

may not adequately

address

program-level* reasons

why

the procedures

are not adequate.

If program-level

reasons

contributed to the inadequacies.

and if corrective actions

do not

address

those

reasons,

then this trend in procedural

inadequacy

could continue.

E8

E8.1

15

~

Licensee staff did not identify and recognize this trend before

the inspectors

did.

This Suggests

that no program currently in

place effectively trends

and corrects

corporate-wide

problems.

In discussing

these

issues with Harris plant corrective action program

personnel,

the inspector

became

aware that corporate

procedure or

process

inadequacies

could be identified at the Brunswick and Robinson

Nuclear plant sites but not be entered into the corporate corrective

action program subunit at Harris.

As

a result,

common problems with

corporate activities would not be trended in the

same data

base.

diluting a potential trend such that it would not be identified.

The

'nspector

also learned that the Harris corrective action program

trending guidance

and requi rements

were limited to approximately three

lines in procedure

AP-615, Condition Reporting.

The guidance is

basically to do quarterly trending.

The licensee

had already identified

this weakness

and was determining

a course of action to address this

issue:

Conclusions

A trend in corporate

procedure

inadequacies

was identified.

Trending of

corporate related

adverse condition reports

were being diluted because

the condition reports

were spread

through all three sites corrective

action data

bases.

The licensee

had identified that trending program

guidance in general

was weak and was determining

a course of action to

address this issue.

Miscellaneous

Engineering

Issues

(92903)

0 en

Unresolved

Item 50-400/97-13-01:

"C" Steam Generator

Blowdown

System

Water

Hammer.

This Unresolved

Item (URI) was opened in NRC Inspection Report 50-400/

97-13 to review the root cause evaluation of the steam generator

blowdown

(SGBD) event of December

22,

1997,

and to review the repetitive

nature of water

hammer events

on the

SGBD System,

including their

continued occurrences.

,The inspectors

reviewed the history of SGBD water

hammer events

as

documented

by the licensee's

corrective action system.

A total of five

CRs were identified which documented

water

hammer events

on the

SGBD

lines from December

21,

1996, to present.

The first documented

event

occurred in April, 1987, which was documented

in LER 87-029-01.

A 1996 Nuclear Assessment

Section

(NAS) audit identified that no formal

process

existed to document evaluations

following water

hammer events

including meeting post water

hammer snubber

requirements.

Procedure

PLP-631,

Water

Hammer Assessment

Program,

was implemented in March 1997,

and established

the current water

hammer

documentation

and evaluation

process.

16

Review of water

hammer data indicated that prior to PLP-631

~

documentation of water

hammer events

was weak and inconsistent.

Following implementation of PLP-631, the sensitivity to water

hammers

has increased

and the licensee

was documenting water

hammers

using the

condition report

(CR) and maintenance

rule processes

and evaluating the

eff'ects of water

hammers

using the

ESR process.

Data indicated that the

process is being followed.

Several

changes

were

made to the

SGBD line valves

and operating

procedures

were changed

but the problems were not resolved.

CR 975320

was

a level

1 CR, which requires

a root cause investigation

(RCI). and was assigned to Engineering.

The

CR concluded that the root

cause

was inadequate original designs

that improper communications of

the issue

between Operations

and Engineering,

and inadequate

post

modification testing following SGBD system modifications were

contributing causes.

The CR/RCI presented

procedural

enhancements

identified by the system engineer

as short term water

hammer solutions

with long term resolution via hardware modifications to the system to

provide slow fill and warmup capability.

The inspectors

concluded that

the CR/RCI did not look at all

SGBD design

documents

and did not

thoroughly review the implementation of previous

SGBD modifications

intended to prevent water

hammers during system initiation.

The inspectors

reviewed

a description of the metallurgical analysis

performed

on the failed section of SGBD piping.

The evalu'ation

was

performed

by the Metallurgy Labs at the Harris Energy and Environmental

Center.

The conclusion

was that the pipe section failed due to an

overload fai lure of the pipe consistent with a significant water

hammer

loading and did not indicate

a fatigue problem or

a problem due to

cumulative effects.

The inspectors

attended

the

PNSC meeting conducted

February

11,

1998,

which reviewed

CR 975320 Root Cause Investigation

(RCI).

The

PNSC

performed

a thorough discussion of the

RCI and requested

an additional

root cause to be added for organizational

acceptance

of water

hammers

and raised several

other questions for the incident investigation

team

to address.

The

PNSC rejected the CR/Root Cause Investigation

and

requested

that it be revised.

The inspector concluded that management,

including the

PNSC,

was appropriately

focussed

on determining the root

cause of the event

and ensuring corrective. actions provide

a permanent

solution.

The inspectors

concluded that the

SGBD water

hammers

during

SGBD

initiation was

a long standing

problem which the licensee's

corrective

action program

had not corrected.

The Root Cause Investigation

concluded that original design

was the root cause

and hardware

modification corrective

action is planned.

The Root Cause Investigation

was reviewed by the

PNSC and will be revised.

'

17

The inspector discussed

trending with the licensee,

particularly in

relation to the steam generator

blowdown water

hammer event,

and in

general.

The licensee

had already identified trending

as

an area that

needed

improvement.

A new Correction Action Program manager

had been

assigned

in the last four months with guidance to review the trending-

area.

The inspector

observed that trending was being conducted in

relation to maintenance

rule, maintenance

work orders,

and condition

reports.

The inspector

concluded that trending continues to be an area of

weakness.

However,

improvement

was being

made.

The inspector

considered

the lack of trending program procedural

guidance

a

.

significant contributor to the weakness.

The integrated site-wide

trending approach

was not adequately

defined to ensure consistent

implementation.

The URI will remain open pending review of the revised

CR/Root Cause Investigation.

Conclusions

Management,

including the Plant Nuclear Safety Committee,

was

appropriately

focussed

on determining the root cause of the event

and

ensuring corrective actions provide

a permanent solution.

Condition

report trending

had not revealed

a trend related to the blowdown events,

which had resulted in a lack of management

attention prior to the event.

IV. Plant

Su

ort

Rl Radiological Protection

and Chemistry

(RP&C) Controls

Rl.l

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.

S1

Sl.l

Fl

F1.1

18

Conduct of Security and Safeguards Activities

General

Comments

Ins ection Sco

e

71750

The inspector

observed security

and safeguards

activities during the

conduct of tours

and observation of maintenance activities.

Observations

and Findin s

The inspector

found the performance of these activities was good.

Compensatory

measures

were posted

when necessary

and properly conducted.

The inspector

noted from review of condition reports

and from discussion

with operations

and security staff that

a gun was discovered during

passage

of an individual's articles through the access

area

X-ray

machine

on January

22,

1998, at 6: 14 a.m.

The individual was

appropriately isolated

from the weapon

by the security staff.

The

security staff interviewed the individual and determined that the

.

individual had accidentally left the gun in their belongings.

The

security staff determined that no malevolence

occurred.

A site-wide

news bulletin was put out that

same

day to review the actions taken

and

remind the plant staff of the prohibition on weapons in the protected

area.

The inspector

observed

work conducted

on the protected

are'a security

fence to add razor wire under contract

XXA7000484.

This wire was being

appropriately installed.

The addition of the wire was in excess of the

requirements

of the security plan.

The licensee

made

a 50.72 report in relation to granting access

to an

individual that should not have

been granted

access.

This issue will be

reviewed in detail after the licensee

submits

a safeguards

event report.

Conclusions

The performance of Security and Safeguards activities were good.

Security staff responded

appropriately to the discovery of a gun during

processing of employee belongings in the access

area

X-ray machine.

Control of Fire Protection Activities

Desi

n Basis of Fire Barrier Penetration

Seals

Ins ection Sco

e

64704

The inspectors

reviewed the fire bar rier penetration

seal

designs

and

testing for compliance with the facility's licensing requirements

identified in FSAR, sections

9.5. 1.2, Barriers

and Access;

9.5. 1.5.4,

Quality Assurance

Program:

17.3,

HNP Quality Assurance

Program

Description;

arid Carolina

Power,and Light's

(CPSL) Corporate Quality

'19

Assurance

Manual, section 15.0. Quality Assurance

Program for Fire

Protection

Systems.

The inspectors

compared selected as-built fire barrier penetration

seals

to fire endurance test configurations to verify that those seals

were

ualified by appropriate fire endurance

tests

and representative

of the

esign

and construction of the fire endurance test specimens.

During

plant walkdowns the inspectors

observed the installation configurations

of selected

accessible fire barrier penetration

seals to confi rm that

the licensee

had established

an acceptable

design basis for those fire

barriers

used to separate

safe

shutdown functions.

b.

Observations

and Findin s

Fire barriers include penetration

seals,

wraps, walls, structural

member

fire resistant

coatings,

doors,

and dampers,

etc.

Fire barriers

are

used to prevent the spread of fire and to protect redundant

safe

shutdown equipment.

Laboratory testing of fire barrier materials is

done only on

a limited range of test assemblies.

In-plant installations

can vary from the tested configurations.

Under the provisions of

Generic Letter (GL) 86-10,

Implementation

of, Fire Protection

Requirements,

licensees

are permitted to develop engineering

evaluations

justifying such deviations.

The inspectors

reviewed the fire barrier penetration

seal

design

records,

Harris construction control system

(CCS) computer database

design records. quality assurance

and quality control

(QA/QC)

installation records,

Information Notice (IN) 88-04,

seal typical detail drawings

and

testing records.

The review included nine mechanical

and electrical

fire barrier penetration

seals.

In the review of penetration

seals,

the inspectors

used

FSAR sections

9.5. 1.2. Barriers

and Access,

9.5. 1.5.4. Quality Assurance

Program

and

17.3,

HNP Quality Assurance

Program Description;

CP&L Corporate Quality

Assurance

Plan, section 15.0, Quality Assurance

Program for Fire

Protection

Systems,

Revision 18; Harris Civil Modification Procedure

No.

CMP-010, Installation of Penetration

Seals,

Revision 8; Harris.

Nuclear Safety Evaluations

Nos.

1288 and 1413,

concerning

NRC

dated

March 17,

1988; Harris'uclear

Safety Evaluation

No.

1406 concerning

NRC IN 88-56,

dated October 25,

1988; Harris Nuclear Safety Evaluation

No.

1209 concerning

NRC

Information, Notice (.IN) 94-28,

dated April 15,

1994; selected

seal typical vendor

(Promatec) detail drawings

1364-93035

through 1364-93072;

selected

composite penetration

location drawings

2167-S-002 through 2167-S-208:

and recognized industry fire penetration

seal testing guidance of American Society for Testing

and Material

(ASTM) Standard

E814-1988,

Standard

Test Method for Fire Tests of

Through-Penetration

Fire Stops

and Institute of'lectrical

and

Electronics

Engineers

(IEEE) Standard

634-1978,

IEEE Standard

Cable

Penetration

Fire Stop Qualification Test.

l

20

Using the

FSAR Fire Hazards Analysis

(FHA) Figures

9.5A-1 through

9.5A-41 to determine the location and description of the plant fire

areas'he

inspectors

conducted

walkdowns

and inspected

seal

installations.

The inspectors'eview

focused

on verifying that the

following design

and installation parameters

for the as-built

configurations

were adequately

bounded

by tests

or justified by

licensee's

engineering

evaluations:

~

type and opening size;

~

seal material type and depth;

~

damming material type and orientation;

~

types

and thermal

mass of penetrating

items;

~

clearances

of penetrating

items;

and

~

fire test results for unexposed

surface temperatures

The following penetration

seals

were visually inspected

and the

QA/QC

engineering

and construction penetration

closure verification package

records for these

seals

were reviewed to determine whether the as-built

plant seal configurations

were representative

of those utilized in fire

seal qualification tests:

v

21

PENETRATION SEAL SUMMARY

SEAL

MATERIAL

DAMMING

MATERIAL

IDENTIFICATION/

NUMBER

LOCATION / SIZE

(INCHES)

DESIGN

DETAIL

DEPTH / TYPE

TYPE / ORIENTATION

FIRE TEST REPORTS /

QUALIFICATION

ELECTRICAL CABLE

TRAY

E 156

ELECTRICAL CABLE

TRAY

E 103

ELECTRICAL CABLE

TRAY

E 2797

ELECTRICAL

CONDUIT

INTERNAL

E 520K

MECHANICALPIPE

P 3624

MECHANICAL

SEISMIC GAP

P 4393

REACTOR AUXILIARY

BUILDING / WALL

BETWEEN FIRE

ZONES 1.A.EPA AND

1.A BALi/78X28

REACTOR AUXILIARY

BUILDING / FLOOR

BETWEEN FIRE

ZONES 1.A.EPA AND

1.A.3.MP / 26 X28

REACTOR AUXILIARY

BUILDING / WALL

BETWEEN FIRE

ZONES 1.A.SWGRA

AND 1.A-SWGRB /

28 X42

REACTOR AUXILIARY

BUILDING /FLOOR

BETWEEN FIRE

ZONES 12.A.CR AND

1.A CSR A /4

DIESEL GENERATOR

BUILDING/WALL

BETWEEN FIRE

ZONES 1.D.DTB AND

1 D.1-DG8.RM / 6

REACTOR AUXILIARY

BUILDING / WALL

BETWEEN FIRE

ZONES 1.A.EPA AND

1-A.46.ST / 2X312

EL-1

ES-3

EL-1

EC-1

MS 5

GS-1

4"- LOW DENSITY

SILICONE

ELASTOMER

10 - SILICONE

FOAM

4"- LOW DENSITY

SILICONE

ELASTOMER

4"- LOW DENSITY

SILICONE

ELASTOMER

6"- SILICONE

FOAM

6"- SILICONE

FOAM

KAOWOOL

BOARD-

1 -TWO SIDES

KAOWOOL

BOARD-

1"- BOTTOM SIDE

KAOWOOL

BOARD-

1 -TWO SIDES

KAOWOOL

CERAMIC FIBER-

1"-TWO SIDES

KAOWOOL

BOARD ~

1 -TWO SIDES

KAOWOOL

CERAMIC FIBER-

1"-TWO SIDES

1063.1

3 HOURS

1001A.

3 HOURS

1063.1 ~

3 HOURS

1063.1 ~

3 HOURS

CTP 1001A.

3 HOURS

1001A-

3

HOURS'ECHANICAL

PIPE

P 3683

MECHANICAL

COPPER TUBE

P 447A

MECHANICALPIPE

WITH TWO PIPE

PENETRANTS

P 3308

DIESEL GENERATOR

BUILDING/WALL

BETWEEN FIRE

ZONES

1 D DTA AND

1-D.1.DGA-RM / 6

REACTOR AUXILIARY

BUILDING /FLOOR

BETWEEN FIRE

ZONES 1 A-BALAND

1.A.3PB /6

REACTOR AUXILIARY

BUILDING / WALL

BETWEEN FIRE

ZONES

1 A.EPA AND

1-A.46.ST / 18X38

MS.S

ML-2

MR.5

6 - SILICONE

FOAM

4"- LOW DENSITY

SILICONE

ELASTOMER

48'- PROMATEC

RADFLEX

KAOWOOL

BOARD-

1"-TWO SIDES

KAOWOOL

BOARD-

1"- BOTTOM SIDE

KAOWOOL

BOARD-

'I" .TWO SIDES

CTP 1001A.

3 HOURS

1063.1

1024.

3 HOURS

1002

CTP 1063.9.

3 HOURS

The inspectors

noted that the licensee's

evaluations of Information

Notices 88-04,

88-56,

and 94-28 did not identify any fire barrier

seal

problems at Harris.

The inspectors'isual

inspections

did not identify any missing seals

and verified that the installed fire

barrier penetration

seals

were continuous with no gaps

~ cracks,

or holes

in the barrier material that would indicate the seals

were inoperable.

22

The inspectors

reviewed the fire barrier penetration

design

documentation for mechanical

penetration fire seals

P 3308 and

P 447A.

Fire barrier seal

P 3308 consisted of an 18-inch by 38-inch block out,

with two non-sleeved

14-inch pipe penetrants

in a concrete wall.

The

entire depth of the block out was filled with Promatec

Radflex silicone

material.

Design drawing 1363-93047,

Flexible Mechanical

Seals-Radflex,

Revision

1

~

and qualifying fire test reports

CTP 1002 and 1063.9 for

this type of,seal

indicated that fire tests

had been conducted only on

single sleeved

pipe penetrations

and not on block out penetration

designs.

Fire barrier seal

P 447A included

a 6-inch diameter sleeve

with a single two and one-half inch copper tube penetrant

in a concrete

floor.

Qualifying fire test report CTP,1001A for this seal

type

indicated that fire tests

had been conducted only on steel

pipe

penetrants.

No copper tube penetrant

had

b'een tested.

Based

on these

reviews, the inspectors

concluded that the licensee

failed to have adequate test documentation to demonstrate

that the as-

built penetration

seal configurations of fire seals

P 3308 and

P 447A

had been qualified by fire tests.

The penetration

seal configurations

, were significantly different from the tested typical seal

types

and

configurations

and were not bounded

by the vendor's

design

and test

documentation.

Also the licensee

had not conducted

engineering

evaluations that followed the guidance of GL 86-10 to justify the

adequacy of these penetration

seal configuration deviations

from the

fire barrier configurations qualified by tests.

The inspectors

also conducted

a review of the fire barrier penetration

design documentation for electrical fire barrier'penetration

seal

E 156.

This penetration

seal

consisted of a 78-inch by 28-inch block out (2184

square

inch seal

area) with six vertical stacked

cable tray and conduit

penetrants

in a concrete wall.

Qualifying fire test report

CTP 1063. 1

for this seal

type indicated that successful fire tests

had been

conducted

on

a maximum block out size of 42-inch by 46-inch which

designated

1932 square

inches

as the maximum seal

area limit.

The

licensee's

field engineering

and construction penetration

closure

verification package for electrical penetration fire seal

E 156, dated

December

15.

1986,

noted

a

QA/QC hold point verification inspection of a

subdivision of the seal.

Penetration installation procedure

CMP-010,

step 7.0. 12, indicated that Engineering shall specify size

and location

of subdividing partitions

and material to be used

on large floor/ceiling

penetrations

requi ring subdividing as specified

on typical detail

drawings.

The licensee's

seal typical detai

1 drawing 1364-

93035.

sheet

3

~ Revision 0. General

Note No. 4 indi'cated that

a

~

enetration

seal

be subdivided

by partitions if the maximum seal

area

imit is exceeded.

The note also required that the penetration

engineers

prepare

sketches/drawings

of the subdividing design

and the

materials

(including structural

support elements)

installed

and that

this subdividing design documentation

become

a permanent part of the

engineering

documentation

package of the seal.

However,

no

sketches/drawings

of the subdividing design

and the materials installed

were identified in the engineering

documentation

package of penetration

fire seal

E 156 provided to the inspectors.

At the request of the

23

inspectors,

the licensee also examined the field design

and construction

documentation for two additional

large floor/ceiling

electrical penetration fire seals

requiring subdividing.

The licensee

was unable to locate the penetration

seal

subdividing design

documentation that demonstrated

the as-built configurations

were bounded

by the vendor's

design

and test documentation.

Also, the licensee

provided no engineering

evaluation documentation that evaluated

the

adequacy of these subdivided penetration

seal configurations.

This does

not follow the guidance of GL 86-10.

The inspectors

concluded that the

licensee

had not implemented

and maintained the design engineering

documentation for large subdivided electrical floor /cei ling penetration

fire seal configurations that demonstrated

the as-built configurations

were bounded

by the vendor's

design'and test documentation.

FSAR sections

9.5. 1.2 and 9.5. 1.5.4 indicated that penetration

seal

designs

are qualified by tests

and that the Fire Protection Quali'ty

Assurance

Program elements

are included in FSAR section 17.3.

FSAR

section 17.3.2,

Performance/Verification

indicates,

in part, that design

and as-

documents

and procedures

are controlled to reflect design

mod f'

-built conditions.

and, that sufficient records

are maintained to

provide documentary

evidence of the quality of items and the

accomplishment of activities affecting quality.

CP8L Corporate Quality

Assurance

Plan.

Revision

18, Section 15.0, Quality Assurance

Program for

Fire Protection

Systems

implements the

FSAR fire protection quality

assur ance requirements

and indicates in paragraph

15.4, that design

activities shall

be accomplished

in accordance

with procedures

that

assure

the applicable design requi rements

are included.

Harris

TS 6.8. l.h indicates that written procedures

shall

be established.

implemented,

and maintained covering the fire protection program

implementation.

Based

on these

reviews, the inspectors

determined that the licensee

failed to adequately

implement

and maintain the applicable design

control documentation

requirements

of the fire protection program

as

described

in the

FSAR to demonstrate

that the as-built configurations of

fire barrier penetration

seals

P 3008.

P 447A,

and

E 156 were bounded

by

the vendor's

design

and test documentation.

This is

a violation of the

facilities'perating license condition 2.C.F.

and is identified as

Violation 50-400/98-01-04,

Failure to Properly

Implement

and Maintain

the Applicable Fire Protection

Program Design Control Documentation

Requirements

for Fire Barrier Penetration

Seals.

In addition, the

licensee did not perform engineering evaluations that followed the

guidance of NRC GL 86-10 for devi ati ons from fire barrier configurations

qualif'ied by tests.

This was considered

an engineering

program

weakness.

c.

Conclusions

A violation was identified for failure to adequately

implement

and

maintain in effect the applicable provisions of the fire protection

program for fire barrier penetration

seals

P 3008,

P 447A,

and

E 156.

In addition. the licensee did not perform engineering evaluations that

P

F2,

F2.1

24

satisf'ied the guidance of NRC GL 86-10 for deviations

from fire barrier

configurations qualif'ied by tests.

This was considered

an engineering

program weakness.

Status of Fire Protection Facilities and Equipment

Surveillance of Fire Protection

Features

and

E ui ment

Ins ection Sco

e

64704

The inspectors

reviewed procedure

FPT-3550,

"Fire Barrier

Seal

Inspection

18 Months Interval," Revision

10,

and the inspection data for

the surveillance

procedures

which were completed

December

2,

1992,

March 15,

1994,

and June 3,

1995.

These were reviewed for compliance

with the requi rements of FSAR Section 9.5. 1.

Observations

and Findin s

Surveillance

procedure

FPT-3550 required

a visual inspection

each

18

months of a random sample of 10 percent of'ach type of fire barrier

enetration seal.

The sample inspections

were requi red to include fire

arrier seals that had not been inspected within the past

15 years.

Each seal

was inspected for any apparent

change in appearance

and signs

of abnormal

degradation.

If any abnormality was found,

an additional

10

percent

was requi red to be inspected.

The inspection

and selection

process

was to continue until an acceptable

sample

was found.

The inspectors

reviewed Procedure

FPT-3550

and concluded that the

procedure

met the frequency requirements

of Procedure

FPP-014.

Fire

Protection Surveillance

Requirements,

Revision 8, Section 5.5. 1.c and

met the commitments

made to the

NRC.

The penetration

seal surveillance inspections

completed

December

2.

1992.

Harch 15,

1994,

and June 3.

1995 were reviewed by the inspectors.

No discrepancies

were noted.

The surveillance inspection

due

January

1998 had not been completed

and was in process

during this

inspection.

The completion of this inspection

was in the grace period.

As previously documented

in NRC Inspection

Report 50-400/97-04,

the

number of fire protection survei llances

being performed in their grace

period was approximately

60 percent for long term (quarterly to 18-

month) survei llances.

This was considered

an excessive

number

and

resulted in the program being considered

not fully effective.

Action

had been taken by the licensee to correct this issue.

As of

December

1997,

47 per cent of the surveillance

procedures

were performed

in the grace period, with 45 percent of these

being performed within

seven

days of the scheduled

date.

Twenty percent of the survei llances

were performed early.

By January

1998 this number

had been further

reduced

such that

41 percent of the survei llances

were performed in the

grace period. with 92 percent of these survei llances

performed within

seven

days of the scheduled

date.

Twenty-eight percent of the

survei llances

were performed early.

Continued

improvements in this area

f

F5

F5.1

25

were anticipated

by the li'censee.

The

NRC will continue to monitor the

licensee's

performance in this area.

Conclusion

The surveillance inspection

procedure for the fire barrier penetration

seals

was adequate.

The three most recent inspections

had been

satisfactorily

implemented.

However,

a large number of fire protection

surveillance

procedures

continued to be implemented within the grace

period of the procedure.

Action had been

implemented

by the licensee to

address this issue

and corrective action was anticipated.

Fire Protection Staff Training and Qualification

Fire Bri ade

Ins ection

Sco

e

64704

The inspectors

reviewed

a fire brigade drill for compliance with the

licensee's

site procedures

and the requirements

of FSAR Section 9.5. 1.

Observations

and Findin s

The inspectors

witnessed

a fire brigade drill conducted

on February 3,

1998, at 9:00 P.N.

This drill involved

a simulated fire on the 1A-SA

steam driven auxiliary feedwater

pump located

on elevation'36 of the

auxiliary building.

The response

by the fire brigade to the simulated

fire included

a fire brigade

leader

and two fire brigade

members

from

operations,

one fire brigade

member from maintenance

and one fire

brigade

member from health physics.

Three security officers, three

auxiliary unit operators

and one health physics

employee also responded

to provide additional assistance

to the brigade,

as required.

The fire

brigade

members

responded to the simulated fire in full turnout gear

and

each

one was equipped with self contained breathing apparatus.

The

response

was timely and the brigade demonstrated

the proper use of fire

fighting equipment

and tactics.

The brigade leader's

direction and

performance

was good.

Following the drill, a critique was conducted to

discuss the brigade's

performance

and recommendations

for future

enhancements.

Conclusions

The fire brigade demonstrated

good response

and fire fighting

performance

during

a simulated fire brigade drill conducted during this

inspection period.

V

F5.2

'26

Fire Barrier Penetration

Seal Installers

and

C Ins ectors

Ins ection Sco

e

64704

The inspectors

reviewed training records for the maintenance

employee

designated

to install

and repair fire barrier penetration

seals

and the

QC inspectors

designated

to inspect the penetration

seals for compliance

with the requirements

of FSAR Section 9.5. 1.

Observations

and Findin s

Only one site employee

was qualified to install

and repai r the

facility's fire barrier penetration

seals.

This employee

had received

,

initial classroom training and practical application in the installation

of the types of fire barrier penetration

seals

used at the Harris

facility.

This training was conducted

by the vendor who supplied the

seal material for the various fire barrier penetration

seals installed

at the facility.

This employee

had received appropriate

annual

retraining

and recertification to maintain

up to date knowledge

and

performance in the installation of these seals.

The inspectors

witnessed the repai rs to a degraded

penetr ation seal

performed by this

individual.

The employee demonstrated

an excellent

knowledge of fire

barrier penetration

seal installation requi rements

and the repai r work

was of a high quality.

The fire barrier penetration

seal installation procedures

'contained

hold

points f'r QC inspections of the principle installation features.

Five

QC inspectors

were performing

QC inspections

and verifications of fire

barrier penetration

seal installations.

The inspectors

reviewed the

training records of two of these

employees

and verified that the

training and certification records for these

employees

were current for

the installation of fire bar rier penetration

seals.

In addition. the

inspectors

witnessed

the performance of a

QC inspector during the

oversight

and verification of repai rs to

a fire barrier penetration

seal.

The

QC inspectors

demonstrated

appropriate oversight

and

verification activities for these repairs.

Conclusion

The fire barrier penetration

seal installer was appropriately trained to

accomplish fire barrier penetration

seal installation work and

QC

inspectors

were qualified to perform the appropriate verification for

installation

and repairs

made to the fire barrier penetration

seals.

, ~ a.')

F7

F7.1

27

guality Assurance in Fire Protection Activities

Fire Protection Audit Re orts

a.

Ins ection

Sco

e

64704

The inspectors

reviewed the Nuclear Assessment

Section

(NAS) Audit

Report

HNAS98-011, Harris Fire Protection Assessment,

dated January

29,

1998, for compliance with the licensee's

site procedures

and commitments

made to the

NRC.

Observations

and Findin s

The licensee's

Nuclear Assessment

Section performed

an assessment

of the

fire protection program on January

5-16,

1998.

The report for this

assessment

was report

No.

HNAS98-011.

The assessment

team determined

that the fire protection program was effective in support of the

operation of the facility.

Findings from the assessment

were

categorized

as strengths.

issues,

or weaknesses.

The assessment

report

identified two strengths,

no issues

and five weaknesses.

The assessment

report also identified eight previously identified 1995-1997 audit

issues

and weaknesses

that remained

open.

The licensee's

corrective

actions for these outstanding audit items were being implemented

and

completion was anticipated in 1998.

Conclusions

The licensee's

1998 Nuclear

Assessment

Section

assessment

of the

facility's fire protection program was of good quality and effective in

identifying fire protection program performance to management.

Corrective actions in response to identified assessment

issues

were

being implemented

and completion

was anticipated in 1998.

XI

Exit Meeting Summary

V.

Mana ement Meetin s

The inspectors

presented

the inspection results to members of licensee

management

at the conclusion of the inspection

on March 4,

1998.

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.

r

28

Licensee

PARTIAL LIST OF

PERSONS

CONTACTED

D. Batton. Superintendent,

On-Line Scheduling

D. Braund; Superintendent,

Security

B. Clarke

General

Manager,

Harris Plant

A. Cockerill, Superintendent,

I&C Electrical

Systems

J. Collins, Manager,

Maintenance

J.

Cook,

Manager,

Outage

and Scheduling

J.

Donahue,

Director Site Operations,

Harris Plant

J.

Eads

~ Supervisor,

Licensing and Regulatory

Programs

R. German,

Manager,

Plant Support

W. Gurganious,

Superintendent,

Environmental

and Chemistry

M. Keef. Manager,

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

S. Flanders.

Harris Project

Manager

~

NRR

M. Shymlock, Chief, Reactor Projects

Branch 4

29

IP 40500

IP 62707

IP 71707

IP 92901

IP 92903

INSPECTION

PROCEDURES

USED

Onsite Engineering

Effectiveness of Licensee Controls in Identifying, Resolving,

and

Preventing

Problems

Surveillance

Observations

Maintenance

Observation

Fire Protection

Program

Plant Operations

Plant Support Activities

Followup - Plant Operations

Followup - Maintenance

Followup - Engineering

~0ened

50-400/98-01-01

ITEMS OPENED,

CLOSED,

AND DISCUSSED

Failure to follow procedures:

1) properly check main

control

room chart recorders,

and;

2) inadequate

work

instructions for rod control system

(Section 08. 1 and

Section M1.2).

50-400/98-01-02

NCY

Inadequate

foreign material exclusion controls for

diesel

generator

lube oil tank (Section Ml.l).

50-400/98-01-03

Failure to conduct shutdown margin surveillance within

one hour (Section M7.1).

50-400/98-01-04

Failure to properly implement

and maintain the

applicable fire protection program. design control

documentation

requirements for fire barrier

seals

(Section Fl. 1).

Closed

50-400/98-01-02

NCV

Discussed

Failure to conduct shutdown margin surveillance within

one hour (Section M7.1).

50-400/97-09-02

50-400/97-13-01