ML18016A427

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Insp Rept 50-400/98-03 on 980301-0411.Violations Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support
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

NPF-63

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

PDR

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

C" Reactor Coolant

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

AOP-018. Reactor Coolant

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

the auxiliary feedwater

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

inoperable

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

NRC Enforcement Policy

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.

RCS Boron Concentration

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

Steam Generator

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

Steam Generators

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

steam generator

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

steam generator

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

Feedwater

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

auxiliary feedwater

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:

Inoperable

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.

main steam safety 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.

NRR

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

Steam Generators

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

VIO

50-400/98-03-02

NCV

50-400/98-03-03

NCV

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

NCV

Clearances

as quality assur ance records

(Section

03.1).

50-400/98-03-03

NCV

Missed surveillance

on AFD monitor (Section 08.2).

50-400/97-10-01

VIO

50-'400/97-17-00

LER

50-400/97-04-02

VIO

50-400/97-13-01

URI

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

Inoperable

main feedwater isolation valves caused

by'old

weather conditions (Section E8.2).