ML18016A427
| ML18016A427 | |
| Person / Time | |
|---|---|
| Site: | Harris |
| Issue date: | 05/11/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18016A425 | List: |
| References | |
| 50-400-98-03, 50-400-98-3, NUDOCS 9805190388 | |
| Download: ML18016A427 (39) | |
See also: IR 05000400/1998003
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION II
Docket No:
License
No:
50-400
Report
No:
50-400/98-03
Licensee:
Carolina
Power
8 Light (CP&L)
Facility:
Shearon Harris Nuclear Power Plant, Unit 1
Location:
Dates:
5413 Shearon Harris Road
New Hill, NC 27562
March
1 - April 11.
1998
Inspectors:
Approved'by:
J.
Brady, Senior Resident
Inspector
R. Hagar,
Resident
Inspector-in-Training
J. Blake, Senior Project Manager (Sections
Ml.1,
M2. 1,
E2,
and E8.2)
E.
Brown. Resident
Inspector,
Brunswick (Section 01. 1)
M. Shymlock, Chief, Projects
Branch 4
Division of Reactor Projects
9805f90388
98051'DR
ADOCK 05000400
9
Enclosure
2
EXECUTIVE SUMMARY
Shearon Harris Nuclear Power Plant, Unit
1
NRC Inspection Report 50-400/98-03
This integrated
inspection included aspects
of licensee operations.
engineering.
maintenance.
and plant support.
The report covers
a 6-week
period of resident inspection;
in addition. it includes the results of
announced
inspections
by a senior project manager.
~0e rat i one
~
Operations
performance during the period was acceptable
(Section 01.1).
Response to an electrical
ground and containment fire alarms
on a non-
safety containment air handler
was good (Section 01.2).
~
A violation with two examples
was identified by the inspectors for
failures to properly classify condition reports
as significant in
accordance with required procedures.
The inspectors
also identified a
non-cited violation for a failure to maintain equipment clearances
as
quality assurance
records
(Section 03.1)
Control
Room operators
exhibited
a questioning attitude.
a clear
understanding of Technical Specifications.
and
a determination to
properly implement Technical Specification requirements
in relation to
implementation of Technical Specification Interpretati'on 89-003.
Operator performance during the period was good (Section 04.3).
o
Plant Nuclear Safety Cmmittee discussions
were appropriately focussed
on safety and preventing recurrence of problems.
Identification of
adverse conditions continued to be
a strength
(Section 07.1).
Operator performance
over the last eight months
improved significantly
due to the creation of a better operations
environment.
Administrative
distractions
were removed
from the control
room and an hourly work
scheduling
system
was implemented.
These
improvements
allowed the
operators to focus better
on operating the plant, which significantly
reduced errors (Section 08.3).
Haintenan
~
Haintenance activities were performed adequately.
Minor planning
deficiencies
were noted
on one of four maintenance activities observed
(Section Hl. 1).
~
Surveillance activities were adequately
conducted
(Section H2.1).
~E
~
In general.
engineering activities were being conducted
adequately
and
in accordance
with required procedures
(Section El.l).
A 10
CFR 21 report on the Turbine-Driven Auxiliary Feedwater
Mater
Pump
governor valve stem was being adequately
addressed
(Section
E4. 1).
Nuclear Assessment
Section audits in Engineering were good (Section
E7.2).
~P1 tt
The control of contamination
and dose for the site was good and was
attributable to good teamwork between the various departments
(Section
Rl.l).
Fire protection activities were being adequately
conducted
(Section
Fl. 1) .
The performance of security and safeguards
activities was good (Section
S1.1).
Re ort Details
Sumaar
of Plant Status
Unit 1 began this inspection period at 100 percent
power and remained there
for the entire period.
01
01..1
Conduct of Operations
Gener
1
C
nts
71707
I. 0 erations
01.2
a.
b.
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.
Po ential Fire in Containment
Ins ection Sc
e
3702
The inspectors
reviewed the site response to a suspected fire in
containment
on Parch 28,
1998,
and the related failure of air handler
AH-39B.
Ob erva i ns an
Findin
At 3:40 a.m.
on Harch 28,
1998, with the plant operating at 100 percent
ower, the unit experienced
alarms which indicated that
a ground fault
ad occurred in the motor for containment air handler AH-39B, and that
a
fire had possibly occurred at the same time inside the containment
building.
AH-398 was one of two non-safety-related
air handlers that
provided cooling air to the
Pump
(RCP) motor
cubicle: at the time of this event. the other air handler was out of
service
due to motor problems.
Following the event,
the "C" RCP motor
winding temperature
increased
from its normal operating temperature of
approximately 200'F to approximately 231'F.
Operators
promptly started
the safety-related air handlers
and the emergency service water
(ESW)
system to provide additional cooling to containment,
in accordance
with
Procedure
Pump Abnormal Conditions.
Revision 9.
This procedure
required that the
RCP be tripped when the motor winding
temperature
reached
300'F.
An administrative limit of 265'F was
established
to allow operators
time to prepare,
prior to tripping the
pump.
The
C" RCP motor winding temperatures
remained
between 225'F and
228'F, which was well below the administrative limit.
Later that
morning. maintenance
personnel
made
a containment entry to inspect for
evidence of a fire, particularly around the motor's associated
electrical
cables outside the biological shield.
They did not find any
indications that
a fire had occurred.
The plant remained in stable
steady-state
operation at
100 percent
power.
02
02.1
03
03.1
The inspectors
attended
licensee
meetings related to the event that were
held at 8:00 a.m..
1:00 p.m.,
and 4:00 p.m.
and noted that an "ad-hoc"
site team was formed to diagnose
the event
and to plan and implement
appropriate
responses.
The inspectors
also attended
the maintenance
personnel
pre-briefing prior to the containment entry.
The inspectors
found that the response of the shift crew to the event was timely and
appropriate,
that diagnostic
and troubleshooting efforts were timely and
comprehensive,
and that the focus of the ad-hoc site team shifted
appropriately
from diagnosis to irrmediate response.
and then to long-
term response.
as related information was gathered
and analyzed.
The
inspectors
also observed that both the control-room staff and the ad-hoc
site team had the correct safety focus.
Conclusions
The response to an electrical
ground fault on air handler
AH-39B and
associated fire alarms in containment
was good.
Operational
Status of Facilities and Equipment
n in
red Safet
Feature
S stem Walk
s
71707
The inspectors
performed
a general
walk-down of accessible
portions of
and component cooling water systems.
Equipment
operability, material condition,
and housekeeping
were acceptable
=in all
cases.
The operational
status of;these
systems
was as required-,by-the,-
Technical Specifications
and required procedures.
Operations
Procedures
and Documentation
General
Comments
Ins ection Sco e
71707
The inspectors
conducted
reviews of operations
logs and procedure
usage.
Observations
and Findin s
The inspectors
found that
a change
had been
made to Administrative
Procedure
PLP-202, Verify Working Document
Program,
Section 3.3. in
Revision 9.
This change required operators to verify the correct
revision for controlled documents in the control
room prior to use,
except for emergency operating procedures.
abnormal operating
procedures,
and alarm panel
procedures.
This meant that all other
controlled documents
in the control
room, including drawings.
were to be
verified prior to use.
The change to PLP-202 was
made because
two
aspects
of the document-control
program raise the possibility that
controlled documents in the control
room may not be current:
one aspect
is that
some time may lapse
between
approval of a document
change
and
incorporation of the change into the controlled documents:
the other
aspect is that
some changes
which affect controlled documents
are simply
posted against those
documents until the changes
are incorporated into a
later revision.
The intent of the change to PLP-202 was apparently to
ensure that operators
in the control
room do not unknowingly use
a
controlled document without being aware of pending and/or posted
changes
against that document.
The inspectors
observed that an operator
had written condition report
CR
98-00571 to identify that the PLP-202 change
placed
a significant
administrative
burden
on the plant operators.
The inspectors
reviewed
this issue
and found that
FSAR Section 13.5. 1.3 indicated that the shift
supervisor shall not engage
in administrative functions that detract
from the overall responsibility of safe operation of the unit.
The
inspectors
also reviewed
TMI Action Plan Item I.A.1. Shift Supervisor
Administrative Responsibilities.
and determined
how that item had been
satisfied for the licensing of the Harris Plant.
Safety Evaluation
Report Supplement
4 and
NRC Inspection Report 50-400/86-34 indicated
that
a shift clerk had been assigned
to the control
room, to limit the
administrative responsibilities of the shift superintendent.
which had
previously included maintaining the controlled documents in the control
room.
During initial licensing of the Harris Plant, the
NRC accepted
that method of limiting the administrative functions of the shift
superintendent.
Technical Specification 6.8.1.a
requires that written procedures
be
established.
implemented.
and maintained covering the activities
recermended
in Appendix A of Regulatory Guide 1.33, Revision 2.
1978
which includes administrative procedures.
Administrative Procedure
AP-615, Condition Reporting,
Revision 24. Attachment 2, Criteria for
Significant Adverse Conditions, listed the criteria for identification
of significant adverse conditions.
which included the failure to comply
with regulatory requirements
or explicit commitments to regulatory
agencies
(Item 3.e).
The shifting of the administrative
responsibilities for ensuring that control
room documents
are verified
to be the current revision prior to use from administrative personnel
to
the TS-required on-shift control
room operators
was contrary to the
intent of TMI Action Plan Item I.A.1 and the
FSAR.
Consequently,
CR 98-
00571 should have been classified
as significant.
The failure to follow
Procedure
AP-615 in classifying
CR 98-00571
as significant was
considered
a violation of TS 6.8.l.a
and is designated
violation 50-
400/98-03-01.
example
1: Failure to properly classify condition reports.
After the inspectors identified the procedure verification issue,
the
licensee initiated
CR 98-00967 to address this concern.
(The licensee
classified the
CR as significant.)
Procedure
PLP-202 was subsequently
revised to allow the use of control
room procedures
without
verification.
However,
a review of this issue
by the licensee
revealed
an additional vulnerability where Engineering Service Requests
(ESRs)
had been
implemented with outstanding
changes
against
procedures.
Procedures
that could have
been affected
by implemented
ERSs were
identified and attached to a night order for the operators that was
issued
on January
30.
1998,
and updated
on April 1,
1998.
The
inspectors
pointed out that instructions attached to the night order did
not provide adequate
direction for effectively using the list.
Operations
management
was revising the list and the night order to make
it more useful.
The inspectors verified that Harris Plant was appropriately
responding
to a violation issued at the Brunswick Nuclear
Power Plant in NRC
Inspection Report 50-325,324/97-13.
The violation was associated
with
the retention of equipment clearances
as Quality Assurance
(QA) Records.
The violation was caused
by an inadequate
corporate procedure.
OPS-NGGC-
1301,
Equipment Clearance.
This corporate procedure also controlled
how
Harris's equipment clearances
were retained.
The Harris Plant had
initiated
CR 97-05376 to address this issue.
The Harris Plant had not
retained clearances
as
QA records since approximately
1994,
when
Carolina
Power and Light had begun work on
a corporate clearance
procedure.
Harris Plant conducted the pilot program and changed
from
maintaining clearance
records
as
QA Records
by developing
new
procedures.
As corrective action for CR 97-05376,
the Harris Plant began recovering
the records,
which were stored either in boxes in the work control
center or in the computer system.
In addition, the inspectors
reviewed
the Brunswick Plant's violation response
and determined that the
corporate
procedure would be corrected.
10 CFR 50 Appendix B Criterion
XVIII. Quality Assurance
Records.
requires that sufficient records shall
be maintained to furnish evidence of activities affecting quality.
CP8L
Corporate Quality Assurance
Plan, Revision 18. section
14.2 required
'hat collection. storage.
and maintenance of records shall
be in
accordance with comnitments to Regulatory Guide 1.88 and/or ANSI N45.2.9
and the plant Technical Specifications.
ANSI N45.2.9 requires that
records which would be of significant value in demonstrating capability
for safe operation
or in determining the cause of an accident or
malfunction of an item be maintained for the life of the plant.
Clearance
records
document the positioning of plant equipment.
including
those necessary
for safe operation.
Because
equipment that is
mispositioned during some clearance activities could contribute to an
accident or malfunction. clearance
records should be maintained for the
life of the plant.
The failure to maintain clearance
records
as quality
assurance
records
was
a violation of 10 CFR 50 Appendix B Criterion
XVIII. This issue
was considered
licensee-identified at Harris since it
was found due to feedback
from the Brunswick Plant and was promptly
corrected.
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 designated
NCV 50-
400/98-03-02;
Clearances
as Quality Assurance
Records.
The inspector
reviewed the classification of CR 97-05376
and found that
it was classified 'as non-significant.
Procedure
AP-615, Condition
Reporting.
Revision 24. Attachment 2, section
3e required that the
CR be
classified
as significant since
a regulatory requirement
was violated.
The failure to follow Procedure
AP-615 in classifying
CR 98-05376
as
significant was considered
a violation of TS 6.8. 1.a
and is designated
Violation 50-400/98-03-01.
example
2.
Failure
.to Properly Classify
Condition Reports.
Proper classification of condition reports is important because
significant condition reports are subject to a formal root-cause
investigation.
The licensee initiated significant
CR 98-00876 to
address
the failure to properly classify condition reports.
Iomediate
corrective action included posting
a copy of Attachment
2 of procedure
AP-615 in the room where condition reports are evaluated.
The licensee
responded
iomediately by reviewing similar condition reports
and
identified that several
others were also misclassified.
C~1
A violation with two examples
was identified by the inspectors
for
failures to properly classify condition reports
as significant in
accordance
with required procedures.
A Nog-Cited Violation was also
identified by the inspectors for a failure to maintain equipment
clearances
as
QA records.
Operator
Knowledge and Performance
T
hnical
S
ification Inter retation 89-003
In
e ti n
c
e
7 7 7
The inspectors
examined the circumstances
associated
with the initiation
of CR 98-01026.
which was associated
with a Technical Specification
Interpretation
(TSI) and its conflict with TS.
b
rva i n
an
Fin in
On April 5,
1998, control
room personnel
entered the action statement
associated
with TS 3.4. ll.b, due to both Reactor Coolant System
head
vent valves being inoperable.
In a related discussion,
licensed
personnel
noted that TSI 89-003 gave instructions which were not
consistent with TS requirements.
They raised the issue to the attention
of site management,
who, after considerable
discussion,
agreed.
At the
end of the inspection period. the licensee
was conducting
a review to
identify circumstances
in which TSI 89-003 had been applied in the past.
Com l tion of OST-1119
Ins
ti n
co e
71707
The inspector
observed control
room operators
and an auxil'iary operator
(AO) performing part of the following evolution/activity:
~
OST-1119
Containment
Spray Operability Train 8 Quarterly
Interval.
Modes
1 - 4. Revision
15
Observations
and Findin s
The operators
referred to and followed the applicable procedures
and
gave adequate
answers to the inspector's
questions.
The AO coordinated
07
07.1
6
component manipulations well with the control
room,
and used effective
communication techniques.
During this evolutions
neither the
AO nor the
inspector identified any plant deficiencies.
Conclusions
on 0 erator
Knowled e and Performance
Control
room operators
exhibited
a questioning attitude.
a clear-
understanding of the TSs,
and
a determination to literally implement'S
requirements
in relation to implementation of TSI 89-003.
Operator
performance during the period was good.
Ouality Assurance in Operations
Licensee
Self-Assessment
Activities
Ins ection Sco
e
71707
40500
During the inspection period, the inspectors
reviewed licensee self-
assessment
activities, including Plant Nuclear Safety Conmittee
(PNSC)
meetings
conducted
on March 4,
1998,
March 18,
1998,
and April 7,
1998.
The inspectors
also reviewed the disposition of numerous condition
reports.
bs rv ti
and Findi
- .-The PNSC meeting discussions
were thorough with good questions
from all
members.
Condition Report 97-5320 addressed
the steam generator
blowdown waterharmer
event
and was discussed
at the Harch 4.
1998
meeting.
The initial root-cause
investigation
had been rejected
by the
PNSC previously.
as discussed
in NRC Inspection Report 50-400/98-01.
The revised root-cause
investigation
was
much better
and addressed
those
issues identified by the inspectors
in Inspection Report 50-400/98-01,
with the exception of trending.
The issue of trending was discussed
at
the
PNSC meeting with little agreement
between the members
as to whether
procedural
guidance
on trending and adverse trends
was adequate.
In
addition, the
PNSC could not agree
on whether the steam generator
blowdown waterharaner
data should have
been identified as
an adverse
trend prior to the December
1997 waterharmer
event.
The inspectors
determined that this indecision was caused in part by the limited
procedural
guidance in the trending area
as discussed
in Inspection
Report 50-400/97-13.
The inspectors
reviewed
numerous
CRs.
The threshold for identification
of adverse conditions
was appropriate.
However. Section 03. 1 describes
several
instances
in which conditions were not always classified in
accordance with procedures.
Conclusions
PNSC discussions
were appropriately
focused
on safety
and preventing
recurrence of problems.
Identification of adverse conditions continued
to be
a strength.
0
08.1
08.2
7
Miscellaneous
Operations
Issues
(92700,
92901)
Closed
VIO 50-400/97-10-01:
Failure to establish
and implement
operating procedures:
4 examples.
This violation involved operator
errors associated
with a turbine-driven auxiliary feedwater
pump
(TDAFWP)forced outage
and corresponding
plant startup.
The inspectors
reviewed the licensee's
response
dated
December
16,
1997.
and the root-
, cause investigations for condition reports
97-04109,
97-04112-1.
and 97-
04094.
The licensee comnitted to counsel
the individuals involved.
provide lessons
learned
from the violation to other operators,
revise
procedure
GP-005.
Power Operation
(Mode 2 to Mode 1) to provide
additional guidance
on the operation of the main feed regulating valves
when synchronizing to the grid, revise procedures
associated
with the
runback setpoint,
and revise Engineering
Procedure
EGR-NGGC-0005 to
.clarify that modifications shall not be relied upon for routine
operation unless the turnover process
was completed.
The inspectors
reviewed these corrective actions
and found them acceptable.
During the inspectors'eview
of the turbine runback procedure
issue
identified in example
4 of the violation,
a cormunications
issue
was
identified.
The inspectors
found that the communications
between
engineering.
maintenance.
and operations
was weak in relation to the
first stage
main turbine pressure
switch set point for turbine runback
with only one main feedpump running.
This resulted in engineering
and
operations
assuming that the setpoint
was approximately
10 psig higher
than maintenance
had set it.
The setpoint
was within instrument
accuracy for this nonsafety signal
and did not affect the wording in
~
~
rocedure
GP-005.
However. it was outside the band defined in procedure
PT-093, Turbine 1st Stage
Pressure
Data, which would require the
setpoint to be reset.
Condition report 98-00906
was generated
for this
issue.
This had no safety impact and was being appropriately addressed
by the licensee.
This item is closed.
Cl s d
LER 50-400/97-17-00:
Failure to recognize
inoperable reactor
axial flux difference
(AFD) monitor, resulting in violation of Technical
Specification surveillance
requirements.
This LER was submitted
because
control
room operators failed to satisfy
Technical Specification surveillance 4.2.1.l.b requirements for an
AFD monitor.
The inspectors
reviewed the associated
root-
cause investigation
(CR 97-03092-1)
and the resulting corrective
actions.
The corrective actions included installing features
which
would annunciate
on the main control board whenever the AFD monitor is
disabled
as it was in this event.
and reviewing this event with
operations
crews.
The inspectors
noted
a weakness
in the investigation,
in that the investigators did not reconcile
an apparent contradiction
between
computer records
and statements
prepared
by control
room
ersonnel.
Despite that weakness.
the inspectors
determined that the
icensee
had implemented corrective actions which should effectively
preclude
a recurrence of this violation.
This non-repetitive.
licensee-
identified and corrected violation is being treated
as
a Non-Cited
Violation, consistent with Section VII.B.1 of the
q 1I
P
08.3
and is designated
NCV 50-400/98-03-03,
Hissed Surveillance
on AFO
Monitor.
This item is closed.
Closed
VIO 50-400/97-04-02:
Three examples of failure to effectively
implement corrective actions for previous non-conformances.
The inspectors
reviewed the licensee's
response
dated July 9
~ 1997, the
root-cause investigations,
and the licensee's
corrective actions.
Examples
1 and 2 related to minor dilution events.
The corrective
actions
included
a change in operations
management.
including a
reevaluation of operations
crew assignments.
The new management
focus
was to be on eliminating operations shift crew distractions,
improving
the daily work schedule,
and improving training.
The inspectors
found that operator performance
over the last eight
months
had improved significantly due to the creation of a better
operations
environment.
Administrative distractions
were removed from
the control
room and an hourly work scheduling
system
was implemented.
These
improvements
allowed the operators to better focus
on operating
the plant, which significantly reduced errors.
Thus, the improvements
were effective.
However, the new Operations
Manager that implemented
these
changes
has taken
a leave-of-absence
and whether he will return is
unknown.
In reviewing the root-cause investigations,
the inspectors
noted that
two root-cause
investigations
were performed by individuals=that- were .-
not completely independent of the event (i.e.. shift superintendents).
These investigations
were for (CR 97-01252)
component cooling water TS 3.0.3 entry and
(CR 97-01348) the first dilution event.
The
PNSC
,initiated
CR 97-02137
when the lack of independence
problem was brought
to their attention.
The inspectors
found that operations
subsequently
stopped the practice of having the control
room operators
involved in
performing root-cause
investigations.
The inspectors
reviewed
CR 97-
02692.
Change
and determined that the incident
described in this
CR was not an inadvertent dilution event.
The issues
described in CR 97-02692 were adequately
addressed
by operations
,
initiatives at eliminating administrative distraction.
Example 3 involved inadequate
corrective actions for Violation 50-400/
96-013-01.
The licensee's
corrective actions were not effectively
implemented to prevent the connecting of the non-seismic qualified
component cooling water
chemical addition piping section to both trains
of the component cooling water system.
The inspectors
reviewed the
root-cause
investigation for CR 97-01252
and the associated
corrective
actions.
The inspectors
determined that the licensee
had implemented
appropriate
changes to OP-145 section 6.7.2,
and had completed event-
specific training for the operating crews,
and concluded that those
corrective actions should be effective in preventing recurrence of this
event.
This item is closed.
Ml
Conduct of Maintenance
Ml.1
General
Comments
a.
Ins ection Sco
e
62707
II. Maintenance
The inspectors
observed all or portions of the following work
activities:
WR/JO 96-AHHZI
Boron Recycle System.
Valve 3BR-242 Packing
Leak
WR/JO 97-AKTJI
Replace
Seal for IDLO-E003, ("A" Emergency
Diesel
Generator
Lube Oil Keep Warm Pump)
~
WR/JO 97-AMMHI
HVAC Fan Discharge
Expansion Joint
& Drive Belt
Replacement
WR/JO 98-ABMGI
Support For Spent, Fuel Shipment
b.
Obs rva i ns and Fin in
The observed
maintenance
work activities were properly conducted
and
exhibited professionalism.
In all observations.
the inspectors
noted
that the work package
was present
and in use.
WR/JO 96-AHHZI - This maintenance activity was from the licensee's
backlog list and-had originally,been scheduled
for early 1997.-
During
'the conduct of the job, the inspectors
noted the following minor
problems associated
with the work package:
The work package
indicated that the job had originally been
scheduled
for early 1997,
and even noted that
a clearance
had been
established
at that time; the work package
gave no indication why
the job had not been completed at the time that the first
clearance
was established.
(During the conduct of the job. the
mechanics
were apprehensive
about why the earlier clearance
had
been terminated.)
o
The work package
included
a generic drawing for the valve. but it
did not include
a list of special tools that might be required.
(e.g.,
deep socket for the packing retainer).
Because of the
possibility of contamination
from materials contained in the
associated
piping, the mechanic working on the valve was required
to be in full
anti-C
clothing.
The surrounding
area
was clean
enough that the barrier and associated
step-off pad could be
established
a few feet away from the valve.
This allowed full
coomunication
between the mechanic working on the job and an
associate
outside the barrier.
who had to make three trips to the
tool
room for additional tools as the job progressed.
The minor planning problems
noted during the performance of this job
were not noted during the performance of the other jobs observed.
Conclusions
10
Maintenance activities observed
were adequately
performed.
Minor
planning deficiencies
were noted
on one of four maintenance activities
observed.
Haintenance
and Haterial Condition of Facilities and Equipment
Surveillance Observation
Ins ection Sco
e
61726
The inspectors
observed all or portions of the following surveillance
tests:
MST I0475
Diesel Generator
1A-SA Starting Air Pressure
Calibration,
Revision
6 8 Revision
7
HST I0149
C Narrow'Range
Level Loop (L-0494)
Operational
Test,
Revision 4
OST-1119
Containment
Spray Operability Train
B Quarterly
Interval,
Modes
1 - 4. Revision
15
rv tions
nd Findin
The observed surveillance activities were conducted in a professional
manner.
In all observations.
the-inspectors
noted that the work package
was present
and in constant
use.
During the initiation of the Diesel Generator
1A-SA starting air
pressure calibration (using revision 6 of procedure
HST I0475). the
Instruments
and Controls (I8C) technician noted discrepancies
between
the procedure
and the equipment tags
and stopped the job until the
procedure
could be revised.
The technician noted that the procedure
identified the pressure
switches
as
PS-01EA-9670AISAV and
PS-01EA-
9670A2SAV, and the pressure
control valves
as
PCV-01EA-9670AlSAV and
PCV-01EA-9670A2SAV, while the metal tags attached to the components
did
not contain the
SA" before the final
V".
The procedure
was revised in a few hours
and the calibration was
completed during the scheduled
day.
The quick completion of a procedure
revision was indicative of good working relationships
between
engineering,
operations,
and maintenance
personnel.
The inspectors
informed the licensee that the
I&C technician's
findings and resulting
actions were noteworthy.
but questioned
why this type of mistake was not
found earlier than in the implementation of Revision 6 of the procedure.
Conclusions
Surveillance activities were adequately
conducted.
E1
Conduct of Engineering
11
III. En ineerin
E1.1
E2
E2.1
E4
E4.1
En ineerin
Service
Re uests
Ins 'e tion Sco e
37551
The inspectors
reviewed all or portions of the following Engineering
Service Requests
(ESRs) to determine if procedure
NGR-NGGC-005,
Engineering Service Requests.
Revision 5, was being followed:
o
ESR 9800100 Evaluation of Runout Protection for the TDAFWP.
Revision
0
ESR 9800016 Justification for Continued Operation
- HFIV
Actuators.
Revision
0
Observations
and Findin s
In general,
the
ESRs reviewed were adequate.
ESR 9800100
was associated
with a one-hour report made under
10 CFR 50.72 on Harch 13,
1998. for
inadequate
runout protection of the turbine-driven auxiliary feedwater
pump
(TDAFWP).
ESR 9800016
was associated
with LER 97-002-00
and
'rovided
the engineering evaluation for main feedwater isolation valve
operqbility.
The inspectors
found these
documents to be adequate.
Conclusions
In general,
engineering activities were being adequately
conducted in
accordance
with required procedures.
Engineering Support of Facilities and Equipment
50002
The inspectors
discussed
the current status of the steam generators
with
the responsible
licensee
engineer.
The discussion
included the results
of the latest
eddy current examination,
the licensee's
plans for
continued inspections.
and plans for scheduled
replacement.
The most recent
eddy current examination,
conducted during
.RFO 7 in the Spring of 1997, resulted in the plugging of 46 tubes
(30 of
the 46 were plugged due to top-of-tubesheet
axial
and circumferential
cracking), bringing the total
number of tubes
plugged to 92.
The next
inspections
had been scheduled for RFO 8 in the Fall of
1998.
and the steam generator
replacement
outage
had been scheduled for
RFO 10 in the Fall of 2001.
The inspectors
had no additional questions
concerning the status of the steam generators.
Engineering Staff Knowledge and Performance
Auxi liar
Pum
Turbine Governor Val ve
a.
General
Comaents
37551
12
E7
~
E7.1
E7.2
The inspectors
reviewed
a
10
CFR 21 report'elated
to turbine-driven
pump governor valve stem size problems.
The
inspectors
found that the licensee
was aware of this issue
and was
taking action.
CR 97-04839
had been initiated to address
the use of an
Inconel
718 governor
valve stem which had
a higher coefficient of
thermal
expansion
than the previous
410 stainless
steel
stem.
The
result at one plant was sticking of the governor valve.
The system engineer
had evaluated
the installed Inconel
718 stem and
associated
carbon washers.
The stem was the type described in the 10
CFR 21 report
and was installed in 1995.
The stem was inspected
on May
7,
1997.
and new spacers
were installed at that time.
The pump had been
operated
considerably since then and had run long enough in several
instances
for the stem to reach thermal equilibrium.
Since the issue
involved thermal expansion.
the system engineer
concluded that the stem
to spacer
clearance
issue
was not a problem .for this stem and its
associated
spacers.
However, the inspector'ound that the spare parts
had not been put on hold for evaluation.
The system engineer
imnediately placed
them on hold.
The inspector
found the engineering
actions associated
with this issue adequate.
n l
i
Ouality 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
(FSAR) 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 inspectors
did not find any additional discrepancies
other than those identified by the licensee.
Licensee
Self-Assessment
A tivities
40500
During the inspection period, the inspectors
reviewed licensee self-
assessment
activities, including Nuclear Assessment
Section Audits on
50.59 Safety Evaluations
(HNAS98-015)
and In-Service Inspection
(HNAS98-035).
The inspectors
also reviewed the disposition of numerous
condition reports.
The inspectors
found that the Nuclear Assessment
Section audits
and the condition reports related to engineering
were
good.
GLCJNJM
1
A 10 CFR 21 report on the
TOAFW governor valve stem was being adequately
addressed.
E8
E8.1
E8.2
13
Hiscellaneous
Engineering
Issues
(92700)
(Closed)
Unresolved
Item 50-400/97-13-01:
'C'team Generator
Blowdown
System Waterhanmer.
This item was reviewed in NRC Inspection Report 50-
400/98-01
and was left open pending review of the licensee's
completed
root-cause
investigation.
The licensee's
root-cause
investigation
was
issued after discussion
at the March 5,
1998,
PNSC meeting.
The initial
root cause
had been rejected
by the
PNSC previously.
as discussed
in NRC,
Inspection Report 50-400/98-01.
The revised root-cause investigation
was
much better
and addressed
those issues identified by the inspectors
in
Inspection Report 50-400/98-01 with the exception of trending.
The
'egulatory
Affairs manager
was in the process of developing procedures
to address
the site-wide trending issues.
This item is closed.
0 en
LER 50-400/97-002-00:
Hain Feedwater
Isolation Valves
caused
by cold weather conditions.
This
LER was also discussed
in
Inspection Reports
50-400/97-,03,
and 50-400/97-12.
During a review of
the work schedule for the week of March 9 through 13.
1997. the
inspectors
noted that WR/JO 97-AL201 was scheduled for the completion of
temporary modification ESR-9700785,
"Relocate
TE-01AV-4870AS and
4870BS..."
and attempted to observe
a part of the modification activity..
This modification was intended to relocate the temperature
elements
involved with the control of fans in the steam tunnel area.
On Monday, March 9, 1998,
Temporary Modification ESR-9700785
was sent
back to engineering for -reconsideration after the maintenance
=
supervisor.
the planner.
and the design engineer
performed
a final pre-
job walkdown during which they identified unexpected
conditions in the
newly selected
locations for the temperature
elements.
The elements
were to be located near the steam generator
power-operated relief
valves.
and the steam line atmospheric
dump
valves.
Engineering spent the rest of the week trying to determine
a
better location for the temperature
elements.
By the end of the week.
engineering
had reconsidered
the modification and decided that moving
the temperature
elements
would not solve the problem: they decided that
roviding shielding for the elements in the original locations would
ave the required effect with less effort.
The final pre-job walkdown by maintenance
and engineering
personnel
precluded the implementation of an, unnecessary
modification to the fan
control system.
It was noteworthy that once the engineers
recognized
that the temporary modification to relocate the temperature
elements
was
not the proper approach.
there
was no hesitation to change direction.
However, the inspectors
did question
why months of engineering effort
had not adequately
considered
the atmospheric
conditions in the selected
area
due to the release of steam.
Licensee staff indicated that they
were planning to supplement
the
LER to provide the final corrective
action.
This
LER will remain open pending final resolution of the
problem.
14
IV. Plant
Su
rt
Rl
Radiological Protection
and Chemistry
(RP&C) Controls
Rl. 1
General
Currents
a.
Ins ection Sco
e
71750
The inspectors
observed radiological controls during the conduct of
tours and during observations
of maintenance activities.
b.
bs rv tions and Findin s
The inspectors
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.
C~i
The control of contamination
and dose for the site was good and was
attributable to good teamwork between the various. departments.
Sl
-Conduct of Security and Safeguards Activities
-Sl.l
.
n r
C
n
a.
Ins e tion Sco e
71750
=The inspectors
observed security and safeguards
activities during the
conduct of tours and during observations
of maintenance activities.
b.
Observations
and Findin s
The inspectors
found that the performance of these activities was good.
Compensatory
measures
were posted
when necessary
and properly conducted.
The performance of security and safeguards
activities were good.
S7
Ouality Assurance in Security and Safeguards Activities
S7.1
General
Comnents
40500
The inspectors
reviewed the nuclear
assessment
section audit on security
(HNAS98-029)
and found that it was thorough.
Fl
Control of Fire Protection Activities
Fl.l
General
Comments
1
15
a.
Ins ection Sco
e
71750
The inspectors
observed fire protection equipment
and activities during
the conduct of tours
and during observations
of maintenance activities.
b.
Observations
and Findin s
The inspectors
found the fire protection activities to be acceptable.
c.
Conclusions
Fire protection activities were being adequately
conducted.
X1
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 April 17,
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.
Licensee
16
PARTIAL LIST OF
PERSONS
CONTACTED
D. Batton, Superintendent.
On-Line Scheduling
D. Braund, Superintendent.
Security
8. Clark, General
Manager. Harris Plant
A. Cockeri 11. Superintendent.
IKC 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
W. Gurganious,
Superintendent,
Environmental
and Chemistry
M. Keef, Manager, Training
G. Kline, Manager,
Harris Engineering Support Services
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
S. Flanders.
Harris Project Manager.
M. Shymlock, Chief. Reactor Projects
Branch 4
i
0
17
IP 37551:
IP 40500:
IP 50002:
IP 61726:
IP 62707:
IP 71707:
IP 71750:
IP 92700:
IP 92901:
IP 93702:
INSPECTION
PROCEDURES
USED
Onsite Engineering
Effectiveness of Licensee Controls in .Identifying, Resolving,
and
Preventing
Problems
Surveillance Observations
Haintenance
Observation
Plant Operations
Plant Support Activities
Onsite Followup of Events
Followup - Plant Operations
Onsite
Response
to Events
~0ened
50-400/98-03-01
50-400/98-03-02
50-400/98-03-03
ITEHS OPENED,
CLOSED,
AND DISCUSSED
Failure to properly classify condition reports;
two
examples
(Section 03.1).
Clearances
as quality assurance
records
(Section.
03.1).
Hissed surveillance
on AFD monitor (Section 08.2).
50-400/98-03-02
Clearances
as quality assur ance records
(Section
03.1).
50-400/98-03-03
on AFD monitor (Section 08.2).
50-400/97-10-01
50-'400/97-17-00
LER
50-400/97-04-02
50-400/97-13-01
Failure to establish
and implement operating
procedures;
four examples
(Section 08.1).
~f
Failure to recognize inoperable reactor axial flux
difference
(AFD) monitor, resulting in violation of
Technical
Speci fication surveillance
requirements
(Section 08.2).
Three examples of failure to effectively implement
corrective actions for previous
non-conformances
(Section 08.3).
"C" steam generator
blowdown system waterhaomer
(Section E8.1).
Dis usse
18
50-400/97-002-00
LER
main feedwater isolation valves caused
by'old
weather conditions (Section E8.2).