ML18019A264

has

corrected

these

deficiencies

and revised applicable

procedures

to strengthen

inspection

in

these

areas.

Inspection

personnel

have

recei,ved

additional

instruction to prevent recurrence

of this item.

Follow-up inspections

have

been

conducted

in this area

by the

resident

inspector

with

no

deficiencies identified.

This item is closed.

4.

Unresolved

Items

and Inspector

Follow-up Items (92701)

~

~a.

Closed

Ins ecto

ol lo -u

Ite

00

(

)

p

r

F

w

p

m

4

/84 36 01

'Unauthorized

Work or

Tampering with Completed

and

Inspected

Installations".

This

concern

has

been

reviewed

by

CP&L; an audit of this area

was conducted

by the

Quality Assurance

surveillance

group.

It was determined that the root

causes

of the

problems

were

craftsmen

working outside

of procedure

guidelines;

working

in

advance

of written direction,

and

personnel

causing

damage

while working or gaining

access

to nearby

equipment.

CP&L management

has provided written instructions to all site personnel

on the protection of installed

equipment,

and additional training has

been

conducted

in this area.

The resident

inspector will continue to

monitor this area

in future inspections.

This item is closed.

b.

(Closed)

Unresolved

Item 400/84-24-03

"Closure

of FCRs."

CP&L wi 11

close

FCRs in the following manner:

(1)

FCRs classified

as "generic",

wherein

the conflict/condition is

applicable to

a specific item or requirement of an existing design

document,

are closed

by Harris Plant Engineering Staff (HPES)

when

the

approved

change

is incorporated

into the applicable

document

as specified in Administrative Procedure

AP-IX-05.

(2)

FCRs classified

as "generic",

wherein the conflict/condition is

not

applicable

to

a

specific

electrical

item

or requirement

detailed/specified

ir. exi sting

design

document(s),

will remain

open

as

.long

as its design

content (clarification or amplifica-

tion)

is

necessary

for

electrical

installation/inspection

activity.

FCRs

of this

type

are

"voided"

by

HPES following

~

, I

notification of completion of all affected

work by Harris Plant

Construction Staff.

(3)

Some

FCRs/PWs require

no field work/rework and are issued only for

document

changes.

These

FCRs/PWs

are

closed

by

Electrical

Discipline Engineer s when approved for incorporation into affected

documentation

(Procedure

Change Notice ¹1, AP-IX-05, R/31).

(4)

In accordance

with AP-IN-05, Field

Change

Request

(FCR/PW),

FCRs

are

closed

by

Electrical

Discipline

Engineers

when

(a) the

affected

design

documents

are

revised/issued

incorporating

the

specified

change

or (b) by visual field verification that all

affected work/rework has

been

completed

and inspection

accepted

by

Construction

Inspection documentation.

A statement is provided in

the implementation

section of the majority of FCRs to indicate

how

implementation is accomplished.

After reviewing the

above clarification

on this issue,

the inspector

considers this item closed.

c ~

d.

(Closed)

Inspector

Follow-up Item 400/83-24-08

"Disposition of

Embed

Plate

Gouge."

During

an inspection

the inspector

observed

a 1/16" to

1/8" deep

gouge

about

2"

long

on

a ceiling

embed

plate

on

hanger

EA 26148.

The gouge

was parallel to the weld of a gusset

to the

embed

and about 3/4" from the weld.

This deficiency

was

documented

by

on

Deficiency

and

Disposition

Report

(DDR)

1773.

The

gouge

was

repaired

and reinspected

and the

DDR was closed

on October 7,

1983.

Additional

instruction

was

provided

to craft

personnel

to

reduce

recurrence

of problems in this area.

This item is closed.

(Closed)

Inspector

Follow-up

Item

400/83-37-05

"gA Monitoring of

Start-up Activities."

CP&L has

provided

a vigorous

gA surveillance

program of all operations activities.

Support

has

been

provided

by

site construction

inspection or quality control,

as required to assure

that start-up activities are conducted

in accordance

with site require-

ments.

This item is closed.

e.

(Closed)

Inspector

Follow-up Item 400/84-24-04

"Operations

Management

Staffing."

Amendment

17 to the

FSAR revised

Section

13. 1 eliminating

the

position

shown

as

manager

of plant operations.

This

item is

closed.

(Closed)

Inspector

Follow-up Item 400/85-04-03

"Evaluation of Mainten-

ance

Work Requests

and Authorizations for Reportabi lity."

CP&L has

revised

the applicable

operations

procedure

(AP-034) to clarify the

information

needed

on work requests

for evaluating

them as potentially

reportable

items.

This item is closed.

5.

Status of Three Mile Island Action Items (TI2514/01

25401B)

a

0

Item I.A.l.l. "Shift Technical Advisor."

FSAR Section 13.2.1.1.3;

Section

13. 1.2.2;

CP&L Response

to

NRR Licensee Qualification Branch

Question

630.7

dated

July 25,

1983;

CP&L Operations

Procedure

OMM-1

Section 3.2.7;

and Harris Plant Technical Specification Section 6.2.4

address

CP&L's commitments to action required for this TMI item.

This

TMI,Action Item is closed.

b.

C.

Item I.A.1.2 "Shift Supervisor Administrative Duties."

This item is

addressed

in the

SER as

an outstanding

issue.

FSAR Section

13. 1';

Section

13'. 1;

TMI Appendix Page

3; Harris Plant Technical Specifica-

tion Section

6. 1.2

and 6.2,

and

Operations

Procedure

OMM-01 Section

3.2.3 address

CP&L's commitments to TMI Action Item I.A.1.2.

The shift

foreman's administrative responsibilities

have

been clearly delineated

in Procedure

OMM-01.

Section 3.2.3.J

of the procedure

requires

that

his administrative

functions

do not detract

from his primary duties.

However,

the

inspector

could

not

determine

how all of the shift

foreman's administrative duties

can

be accomplished

without detracting

from his primary responsibilities.

This is

an Inspector

Follow-up Item

"I.A.1.2 Shift Supervisor Administrative Duties" 400/85-16-01.

Item I.A.1.3 "Shift Manning."

NUREG 0737 was revised

by Generic Letter 82-02

and

affected

the

action

required

by

TMI Item I.A.1.3.

Technical Specification Section 6.2.2

addressed

Item I.A.1.3

in

FSAR TMI'ppendix

Page

4;

Harris

Plant

and Operations

Procedure

OMM-01

Section 3.3.6.

The inspector previously evaluated this TMI Action Item

and identified an Inspector

Follow-up Item as 400/83-37-03

"Scheduling

Overtime."

The Harris Plant Technical Specification Section 6.2.2

and

Revision

1

of

Procedure

OMM-01,

Section

3.3.6

clearly

delineate

compliance with this

TMI Action Item.

IFI 400/83-37-03

and

TMI Item

I.A.1.3 are closed.

d.

Item I.A.2. 1

"Immediate

Upgrading of

RO and

SRO Training Qualifica-

tion."

TMI Appendix

Page

5;

CP&L response

to

Licensee

Qualification Branch Question

630.4

and

SER Section

13.2. 1.3 conclude

that

CP&L has satisfied

the requirements

of this action

item.

This

item is closed.

e.

Item

I.A.2.3

"Administration

of Training

Programs

for

Licensed

Operator."

FSAR Section

1.8 and 13.2.2;

CP&L response

to

NRR Licensee

Qualification Branch Question

630.5

and

SER Section

13.2. 1.3 conclude

that

CP&L has satisfied

the

requirements

of this action

item.

This

item is closed.

Item I.A.3.1 "Revised

Scope

and Criteria for Licensing Examinations."

FSAR TMI Appendix,

Page

7,

commits

CP&L to utilize

a simulator

as

a

part of the licensing examinations.

This item is closed.

Item

I.B.1.2

"Independent

Safety

Engineering

Group."

Technical Specification Section 6.5.4

Appendix,

Page

8 and Section

13.4;

SER Section

13.4

and Harris Plant

address

CP&L's

commitments

to

have

an

on site independent

safety

engineering

group.

This group

has

been

established

at

the

site

and

is

functioning

as

the

on site

Corporate

Nuclear Safety section.

This item. is closed.

Item I.C. 1 "Guidance for the Evaluation

and Development of Procedures

for Transients

and

Accidents."

TMI Appendix,

Page

9;

response

letter

to

Harold

Denton,

dated

September

18,

1984;

Section

13.5.2. 1;

SER Section 13.5.2.3;

and

NUREG 0730,

Supplement

1

address

steps

which

CP&L will take to comply with this action

item.

CP&L has

submitted the

Emergency Operating

Procedures

(EOPs) generation

package

to

NRR and

has

developed

the plant specific

EOPs.

To satis-

factorilyy

resolve this item requires:

the

NRR staff to review CP&L's

plan and address

their findings in a supplement

to the

SER;

and

an

NRC

follow-up review will be required to resolve

any questions

which

may

result

from evaluating

CP&L's plan.

This is

an

Inspector

Follow-up

Item "I.C. 1 Guidance for the Evaluation

and Development of Procedures

for Transients

and Accidents" 400/85-16-02.

Item I.C.8 "Pilot Monitoring of Selected

Emergency

Procedures

for NTOL

Applicants."

TMI Appendix,

Page

16,

and

SER Section

13.5.2.3

address

this item.

The

SER states

that the

NRC staff does

not plan to

review selected

Emergency

Operating

Procedures

in accordance

with TMI

Action Item I.C.8.

The staff plans to review the

EOPs

based

on

Action Item I.C. l.

This item is closed.

Item I.C.2 "Shift and Relief Turnover Procedures."

FSAR TMI Appendix,

Page

10;

FSAR Section

13.5. 1.3;

SER Section

13.5. 1 and

CP&L Operations

Procedures

OMM-022 address

CP&L's compliance with this action

item.

The inspector evaluated

procedures

OMM-001 and

OMM-002 and

found them

to

be

an

acceptable

method

of assuring

that

operating

shifts

are

properly relieved.

This item is closed.

Item I.C.3 "Shift Supervisor

Responsibilities."

TMI Appendix,

Page

11;

Section

13. 1.2;

Section

13.5. 1;

Harris

Plant

Technical

Specification,

Section

6. 1.2,

and

Operations

Procedure

OMM-001 clearly establish

the

command duties of the shift supervisor

and emphasize

the primary management

responsibility for safe

operation

of the plant.

The inspector

evaluated

procedure

OMM-001 and found it

to clearly define the duties,

responsibilities

and authority of the

shift

supervisor

( shift

foreman)

and

the

control

room operator s.

Harris

Plant

Technical

Specifications,

Section

6. 1.2,

addresses

a

management

directive

signed

by

the

vice-president

Harris

Nuclear

Project to be issued yearly to all plant personnel.

The directive is

required to state

that the shift foreman is responsible

for the safe

operations

of the plant.

This item is closed.

~

Item I.C. 4 "Control

Room Access."

TMI Appendix,

Page

12;

Section 13.5.1;

Section

13.5.1

and

CP&L Operations

Procedure

OMM-001 describe

the control

room access

limitations and the authority,

responsibility

and

succession

in the

control

room.

The

inspector

evaluated

the applicable

sections

of procedure

OMM-001; the procedure

adequately

addresses

the concerns

identified in this TMI Action Item.

However,

the

procedure

has

not yet

been

implemented.

This is

an

Inspector Follow-up Item "I.C.4 Control

Room Access"

400/85-16-03.

Item I.C.5 "Procedures

for Feedback

of Operating

Experience

to Plant

Staff."

Appendix,

Page

13;

Section

13.5. 1;

Section

13.5. 1;

CP&L Qual.ity Assurance

Procedure

CQAD 80-1; Operations

Procedures

ONSI-1

and

D-AP-31

describe

the

guidance

required

to

ascertain

that operating

experience

is fed back to the plant's staff.

The inspector evaluated

the applicable site procedures

(ONSI-l, 0-AP-31

and Enclosure

1 to

CQAD 80-1)

and found them to address

adequately

the

concerns

identified in TMI Action Item I.C.5.

This item is closed.

n.

0.

Item I.C.6 "Verify Correct Performance

of Operating Activities."

TMI Appendix,

Page

14;

SER Section

13.5. 1;

CP&L Operations

Procedures

OMM-001;

Section 5.2,

and

OMM-05 describe

CP&L's current

position

relative

to

TMI Action

Item I.C.6.

The

inspector

evaluated

the

applicable

CP&L operations

procedures

and

discussed

the

content

of

these

procedures

with the responsible

CP&L personnel.

The inspector

was

informed that

CP&L is reevaluating its position

and will provide

additional clarification.

This is

an Inspector

Follow-up Item "I.C.6

Verify Correct Performance

of Operating Activities" 400/85-16-04.

Item I.C.7

"NSSS

Vendor

Review of Procedures."

References:

FSAR TMI

Appendix,

Page

15;

FSAR Section

14.2.3.2;

SER Section

13.5.2.3;

response

to

a draft

Open

Item

Number

194 (letter

dated

July 1,

1983);

and

CP&L letter clari fying company

position

concerning

Action Item I.C.7 (letter dated

February

18,

1985).

The clarification

was provided to inform NRR that

CP&L does

not plan to require Westing-

house (the

NSSS vendor) to review the

Emergency

Operating

Procedures.

CP&L has

committed

to Westinghouse

review of low power

and

power

ascension

procedures

which are related

to

NSSS, prior to fuel load.

The inspector will verify that these

reviews

are accomplished.

These

reviews

are Inspector

Follow-up items "I.C.7. 1

NSSS

Vendor

Review of

Low Power Test Procedures"

400/85-16-05

and "I.C.7.2 NSSS Vendor Review

of Power Ascension

Procedures",

400/85-16-31.

P..

Item I.D. 1 "Control

Room Design

Review."

FSAR TMI Appendix,

Page

17;

SER Section

18;

SER Supplement

1, Section

18;

and

NUREG 0737,

Supple-

ment 1,

summarizes

the

requirements

and outstanding

issues

which must

be

addressed

in order

to close this

TMI Action Item.

The inspector

will track

NRR closeout

action

on this

item.

This is

an

Inspector

Follow-up Item "I.D.1 Control

Room Design

Review" 400/85-16-06.

I

~

~ (L

I.G.1 "Special

Low-power Testing

and Training."

FSAR Section

13.2.-

1.1.2;

FSAR Section

14.2.12.2.26

(Amendment ll) and

Section

14

describe

CP&L's commitments that each

Reactor Operator

(RO) and Senior

Reactor Operator

(SRO)

who performs

RO and

SRO duties shall participate

in the initiation, maintenance

and recovery

from natural circulation.

The inspector inquired about plans which CP&L's training department

may

have

made to resolve this item.

The inspector

was informed that

plans to document

a training program to require the necessary

observa-

tions to

address

satisfactorily

the

TMI Action Item.

The inspector

will observe portions of training during low-power testing.

This is an

Inspector

Follow-up

Item "Special

Low-power Testing

and Training."

400/85"16"07.

II.B.1 "Reactor

Coolant

System

Vents."

FSAR TMI Appendix,

Page

22;

FSAR Section 5.4. 12.5;

SER Section

15.9. 1 and

CP&L Emergency Operating

Procedure

EOP-FRP-I.3

describe

the Harris Plant

Reactor

Coolant

High

Point Vent System.

The design of the vent system

has

been

reviewed by

and

found acceptable,

as

discussed

in the

The

inspector

assessed

the

construction

status

of the

system

and

found it to

be

partially completed.

Those sections yet to be installed include:

the

piping connections

to the reactor

vessel

head

and to the pressurizer;

the electrical

power

supplies

to the

solenoid-operated

valves;

and

control

room indication for flow and valve position.

The inspector

evaluated

EOP-FRP-I.3

and found it to address

only the reactor

vessel

head

vent.

The

procedure,

when addressing

the reactor 'vessel

vent,

does

not identify the

valves

to

be

manipulated.

The Harris

Plant

Technical Specifications

Section 3/4.4. 11 addresses

the operability

and

surveillance

requirements

for

the

vents.

This

is

an

Inspector

Follow-up Item "II.B.1 Reactor

Coolant System Vents" 400/85-16-08.

II.B.2 "Plant Shielding to Provide

Access

to Vital Areas

and Protect

Safety

Equipment for Post-accident

Operation."

TMI Appendix,

Page

25;

Sections

12.2.1.12,

12.3.2.16

and

3.11;

and

'ection

12.2

describe

CP&L's design

review of plant

shielding

and

environmental

qualification of spaces

or systems

which may be used in

post-accident

operations.

This

TMI Action Item

was

evaluated

and

accepted

by

NRR; the results

are

documented

in the Harris Plant

As a result of the applicant's

review,

no modifications were identified

as

being

required.

Region II will review this

area.

This is

an

Inspector

Follow-up Item "II.B.2 Plant Shielding to Provide

Access

to

Vital Areas" 400/85-16-32.

II.B.3

"Post-accident

Sampl ing

Capability."

Appendix,

Page

26;

FSAR Sections 6.2.5

and 9.3.2,

and

SER Section 9.3.2.2 address

CP&L's

post-accident

sampling

system.

CP&L personnel

informed

the

inspector

that

the

sampling

system

is

being

installed

and

the

supportive procedures

are being drafted.

CP&L expects

the system to be

installed

and procedures

to

be

completed

in late

1985.

This is

an

Inspector

Follow-up

Item "II.B.3 Post-accident

Sampling

Capability"

400/85-16-09.

II.B.4 "Training for Mitigating Core

Damage."

TMI Appendix,

Page

27;

FSAR Section

13.2;

SER Section

13.2. 1.3,

and

CP&L response

to

the

NRR Safety Evaluation

Licensee Qualification Branch Question

630.6

address

CP&L's compliance

with this

TMI Action Item.

The inspector

reviewed

the training

records

for the Harris Plant shift technical

advisors

and operating

personnel

from the Plant General

Manager through

the operating chain, including licensed operators.

These

records

show

that

these

personnel

have

been

trained,

as

required

by the

Mitigating Core

Damage Training

Program.

Training for managers

and

technicians

in the

Instrumentation

and Control,

Health Physics,

and

Chemistry Sections

is

an

ongoing

program which will not

be completed

until

fuel

loading.

This

is

an

Inspector

Follow-up

Item "II.B.4

Training for Mitigating Core

Damage" 400/85-16-10.

II.D.1 "Performance

Testing of Boiling Water Reactor

and Pressurized

Water Reactor Relief and Safety Valves."

FSAR TMI Appendix,

Page

28,

SER Section

3.9.3

and

CP&L response

letter to

NRR concerning

Confirmatory

Item

Number

6

dated

June

28,

1984

document

CP&L's

compliance

with this

TMI Action Item.

This

item will remain

open

pending

NRR review

and

approval

of CP&L's plant specific

response

submitted

on

June

28,

1984.

This is

an

Inspector

. Follow-up

Item

"II.D.1 Performance

Testing of Boiling Water Reactor

and Pressurized

Water Reactor

Relief and Safety Valves" 400/85-16-11.

II.D.3 "Relief

and 'Safety

Valve Indication."

TMI Appendix,

Page

29,

and

SER Section 7.5.2 address

CP&L's compliance with this TMI

Action Item,

The installation of the

hardware

has

not yet

been

completed

for the relief

and

safety

valve indicators.

This is

an

Inspector

Follow-up Item "II.D.3 Relief and Safety

Valve Indication"

500/85"16-12.

II.E. 1. 1

"Auxil iary

Feedwater

Re 1 i abi 1 ity

Eval uati on."

Appendix,

Page

30;

Section

10 '.9;

Supplement

1,

Section

10.4.9,

and

FSAR Section

10.4.9 address

CP&L's compliance with this TMI

Action Item.

The inspector

was

informed

by

CP&L that the auxiliary

feedwater

system did not require

any plant modification concerning this

Action Item.

NRR has reviewed

and accepted

the Harris Plant auxiliary

feedwater reliability evaluation.

This item is closed.

II.E. 1.2

Auxiliary Feedwater

System Initiation and

Flow."

FSAR TMI

Appendix,

Page

31;

FSAR Sections

7.2.2,

7.3. 1, 7.3.2,

7.5

and 10.4.9;

and

SER Section 7.3.3. 1 address

CP&L's compliance with this TMI Action

Item.

has

accepted

the

design

of the

Harris

Plant

auxiliary

feedwater

system

controls.

However,

the

indicators

and

control

circuits have not yet been insta'lied.

This TMI Action Item will remain

open until the electrical

hardware

and controls for the auxiliary

feedwater

system

have

been installed

and the installation evaluated

by

Region II.

This is

an

Inspector

Follow-up Item "II.E.1.2 Auxiliary

Feedwater

System Initiation and Flow" 400/85-16-13.

z.

II.E.3 ~ 1 "Emergency

Power for Pressurizer

Heaters."

FSAR Section 8.3.1

and

SER Section

8.4

~ 8 address

CP&L's compliance with this

TMI Action

Item.

The

SER states

that

CP&L will have

procedures

for manually

loading the pressurizer

heaters

onto the class

1E buses

following loss

of off site power.

The inspector selectively evaluated

the procedures

which

CP&L has

in place to require

the

manual

loading of pressurizer

heaters

onto the

lE buses

as

required

by the

TMI Action Item.

This

item is closed.

aa.

II.E.4. 1 "Containment

Dedicated

Penetrations Hydrogen Control."

TMI Appendix,

Page

33;

and

SER Table

1'. clearly indicate that

utilizes redundant

in-containment

thermal

recombiners;

therefore this

TMI item is not applicable to the Harris Plant.

This item is closed.

bb.

II.E.4.2

"Containment

Isolation Dependability."

TMI Appendix,

Page

34;

FSAR Sections

6.2.4,

7.3. 1. 1,

and 7.3. 1.3;

and

SER Section

6.2.4 address

CP&L's position concerning this TMI Action Item.

NRR has

reviewed

the

CP&L design

and

has

addressed it in

the

Section 6.2.4

requires

CP&L to provide

Technical

Specifications

for

containment

isolation

setpoint

pressure.

has

submitted

the

requested

sections

of the Technical

Specifications

by

a letter dated

April 23,

1985.

This

item

remains

open

pending

review

and

acceptance

of the

proposed

technical

specifications.

Region II will

follow

up

on this

item 'to

determine

acceptability

of the

final

installed

hardware.

This is

an

Inspector

Follow-up

Item "II'.'E.4.2

Containment Isolation Dependability" 400/85-16-14.

cc.

II.F. 1

"Additional Accident

Monitoring Instrumentation."

Appendix,

Page

35;

FSAR Sections

11.5.2,

12.3.4,

6.3

and

6.2;

response

letters

to

dated

July 1,

1983,

July 15,

1983,

September

21,

1983,

October 24,

1983,

and

October 26,

1983;

Sections

11.5 and 10.4.2;

SER Open Items

9 and 10;

and

SER Confirmatory

Item 24,

25 and

26 address

CP&L's compliance with this TMI Action Item.

(1)

Subparts

(2.a)

and

(2.b) of the action

item require

noble

gas

effluent

radiological

monitoring,

sampling

and

analysis.

The

design for these monitors

has

been

completed

but their installa-

tions

have

not

been

completed.

NRR has

reviewed

the monitoring

and sampling

system design

and has

provided

comments

in the

These

subparts

have

been identified by

NRR as

SER Open Items

9 and

10,

and

Confirmatory

Items

24,

25,

and

26.

Upon satisfactory

resolution

of the

design

between

and

CP&L,

Region II will

verify that the final design installation

has

been

completed

and

that procedures

are

issued.

This is

an Inspector

Follow-up item.

"II.F.1 Subparts

(1)

and

(2) Effluent Radiological

Monitoring,

Sampling

and Analyses" 400/85-16-15.

(2)

Subpart (2.c) "Containment High-range Radiation Monitor."

NRR has

reviewed

and accepted

the design of the Harris Plant containment

high-range radiation monitors,

as discussed

in SER Section 12.3.4.

The

monitors

have

not yet

been

installed.

Upon

completion

10

Region II will verify installation.

This is an Inspector Follow-

up

Item "II.F.1

Subpart

(3)

Containment

High-range

Radiation

Mon itor" 400/85-16-16.

(3)

Subparts

(Z.d)

and (2.e)

"Containment

Pressure

and Water

Level

Monitors."

NRR has

reviewed

and accepted

the design of the Harris

Plant containment

pressure

and water level monitors,

as discussed

in SER Section 7.5.2.2.

The monitors

have not yet been installed.

Upon completion

Region II will verify installation.

this is

an

Inspector

Follow-up Item "II.F.1 Subparts

(4) and (5) Containment

Pressure

and Water Level Monitors" 400/85-16-17.

(4)

Subpart (2.f) "Containment

Hydrogen

Concentration

Monitor."

has

reviewed

and accepted

the design of the Harris Plant contain-

ment hydrogen concentration

monitoring system,

as discussed

in SER

Section

7.5.2.2.

The

system

has

not yet

been

installed;

upon

completion

Region II will verify installation.

This

is

an

Inspector

Follow-up Item "II.F.1 Subpart (6) Containment

Hydrogen

Concentration

Monitor" 400/85-16-18.

dd.

II.F.2 "Instrumentation

for Detection

of Inadequate

Core

Cooling."

TMI Appendix,

Page

36;

Section 4.4;

CPSL

responses

to

dated April 18,

1984,

December

6,

1983,

and

November 4,

1983;

and

Supplement

1, Section

4 identify this item as

a license condition which

must be resolved prior to operating

above

5% power.

The installation

of the

hardware

associated

with this

TMI Action Item is incomplete.

The procedures

associated

with the reactor

vessel

water level indica-

tion

system

have

been written

and

are available for implementation.

This item remains

open until the hardware is installed

and the instal-

lation

can

be evaluated

by Region II.

This is an Inspector

Follow-up

Item "II.F.2 Instrumentation for Detection of Inadequate

Core Cooling"

400/85-16-19.

ee.

II ~ F.3 "Instrumentation for Monitoring Accident Conditions (Regulatory

Guide 1.97)."

The

NRC staff has

been instructed to use

Supplement

1 to

NUREG 0737

(Generic Letter 82-33)

in the

implementation

of emergency

response

capability

(including

requirements

for

post-accident

monitoring)

~

Therefore,

conformance

to the guidelines

of Regulatory

Guide

1.97 will be

included

in the

evaluation

of designs

for the

emergency

support facilities.

The

implementation

schedule will be

established

in

conformance

with

Supplement

1

of

NUREG 0737.

The

completion of the review of this item will be performed during the post

implementation

review discussed

under

NUREG 0737 III.A.1.2

"Upgrading

Emergency

Support Facilities."

This item is closed.

ff.

II.G. 1 "Emergency

Power for Pressurizer

Equipment."

FSAR TMI Appendix,

Page

37;

FSAR Section

8.3. 1.2

and

Section

8.4.8

address

CPKL's

compliance with this

TMI Action Item.

NRR has

reviewed

and

accepted

the

Harris

Plant

design

as

discussed

in

Section 8.4.8.

The

installation

and testing of the

hardware

has

not yet

been

completed.

11

Upon completion of the

hardware

and testing,

Region II will evaluate

the

configuration.

This

is

an

inspector

Follow-up

Item

"II.G.1

Emergency

Power for Pressurizer

Equipment" 400/85-16-20.

gg.

II.K.1 "IE Bulletins

on

Measures

to Mitigate Small-break

LOCAs and

Loss-of-feedwater Accidents."

FSAR TMI Appendix,

Pages

38,

39

and 40;

FSAR Section 7.3. 1 and

SER Section

15.9 address

CP&L's compliance with

this TMI Action Item.

(1)

Subpart II.K.1.5

"Review of

ESF Valves."

CP&L has

committed to

have

procedures

which address

the positioning of

ESF valves

and

will establish

methods of demonstrating,

on

a regular basis,

that

these

valves

are

in the

proper position.

The

procedures

are

currently being developed.

Region II will evaluate

these

proce-

dures

when

they

have

been

completed.

This

is

an

Inspector

Follow-up Item "II.K.1.5 Review of ESF Valves" 400/85-16-21.

(2)

Subpart

II.K.1. 10

"Operability Status."

CP&L is

developing

procedures

for removing safety-related

systems

from service

(and

restoring to service)

to assure

that the operability status

is

known; Operations

Procedures

OMM-001, OMM-003 and

OMM-005 provide

this assurance.

However, the independent verification sections of

OMM-001 and

OMM-005 are being evaluated

by CP&L for clarification.

Upon resolution of the

independent

verification item, identified

earlier

as

an Inspector

Follow-up Item 400/85-16-04,

the proce-

dures

associated

with Item II.K.1. 10 will be further evaluated.

This is an Inspector

Follow-up Item "II.K.1. 10 Operability Status"

400/85-16-22.

(3)

Subpart

II.K.1. 17 "Trip Per

Low Level Bi-stable."

The Harris

Plant design

does

not include

a low pressurizer

level coincident

with low pressurizer

pressure,

as

discussed

in

Sections

7 2

1

and

7

3

1 1.

Safety

Injection is initiated

by

low

pressurizer

pressure.

The Harris Plant

has incorporated this

Action Item into the plant design;

therefore this item is closed.

hh.

II.K.2.13 "Thermal

Mechanical

Report."

This item is addressed

in the

FSAR TMI Appendix,

Page

41;

and

SER Section 15.9.4,

and Appendix C.

As

discussed

in the

SER, the

NRC staff concludes that the Harris Plant can

be operated

before complete resolution of this issue

and completion of

the proposed

rulemaking without undue risk to the health

and safety of

the public.

This item is closed.

ii.

II.K.2.17 "Potential for Voiding in the

RCS During Transients."

This

item is discussed

in

TMI Appendix,

Page

42;

and

SER Section

15.9.5.

This item is discussed

in the

Section

15.9.5

as

being

reviewed

by

NRR.

If NRR determines

that plant operating

procedures

must

be modified,

CP&L will be required to implement

the

changes

for

the Harris Plant.

This item is not considered

an outstanding

issue in

the

This item is closed.

I

'I

I

II

II.K.2.19 "Sequential

Auxiliary Feedwater

Flow Analysis."

The

SER,

Section 15.9.5,

identifies this

item as

not being applicable

to the

Harris Plant,

as it employes

the inverted

"U" tube

steam

generators.

This item is closed.

kk.

mm.

II.K.3.1 "Installation

and Testing Automatic

PORV Isolation Systems."

TMI Appendix,

Page

44;

and

SER Section 15.9.7

address

CP&L's

position

on this TMI Action Item.

Should

NRR's review of the Westing-

house

Owner's

Group report

(WCAP-9804) determine that modifications are

necessary,

CP&L will be required to address

the concerns.

There is

no

action required

by Region II.

This TMI Action Item is closed.

II.K.3.2 "Report

on Overall

Safety Effect of

PORV Isolation

System."

TMI Appendix,

Page

45;

and

Section

15.9.7

address

CP&L's

position

on this

TMI Action Item.

Westinghouse

Owner's

Group Report

(WCAP-9804)

summari zes

the

col 1 ecti ve

data,

in

conjuncti on

with

industry generic probabilistic data,

and estimates

the probability of a

small-break

LOCA caused

by

a stuck

open

PORV.

Should

NRR review of

WCAP-9804 determine

the

need for changes

or modifications,

CP&L will be

requi red

to

address

these

needs.

There

is

no action

required

by

Region II.

This TMI Action Item is closed.,"

II.K.3.3 "Reporting of S/V and

R/V Failures

and Challenges."

FSAR TMI

Appendix,

Page

46;

Section

15.9.8

and

Harris

Plant

Technical Specifications 6.9. 1.4,

3.4..4

and 3.4.2.2

address

CP&L's compliance

with this item.

CP&L has

committed to document all challenges

to

a

safety or relief valve in the plant annual

report

as discussed

in the

plant technical specification section 6.9. 1.4.

Failure of the valves

are to

be reported

in accordance

with the plant

LER procedure,

which

has not been finalized.

Region II will evaluate this procedure

when it

has

been

completed.

This is

an ,Inspector

Follow-up

Item "II.K.3.3

Reporting of S/V and

R/V Failures

and Challenges"

400/85-16-23.

nn.

II.K.3.5 "Automatic Trip of Reactor

Coolant

Pumps

During LOCA."

TMI'Appendix, Page

47; Generic Letter 83-10C;

CP&L response

to Generic

Letter

83-10C,

dated April 22,

1983;

SER Section 15.9.9;

and

Emergency

Operating

Procedure

Network address

CP&L's compliance

with

this item.

This item is addressed

in the

SER as Confirmatory Item 33.

needs

to

address

CP&L's

response

to Generic

Letter

83-10C

and

supplement

the

as required.

This is

an Inspector

Follow-up Item

"II.K.3.5 Automatic Trip of

Reactor

Coolant

Pumps

during

LOCA"

400/85-16-24.

00.

II.K.3.9 "PID Co'ntroller Modification."

TMI Appendix,

Page

49;

and

SER Section

7.7.2.3

address

CP&L's commitment to this

TMI Action

Item.

CP&L has

committed to adjusting

the derivative action setting

for the

PORV PID controller to zero.

The PID controller for the

PORVs

has

been adjusted to zero

and its adjustment circuit has

been disabled

to prevent inadvertent maladjustment.

This item is closed.

"A

13

pp ~

Ss.

uu.

VV'

I.K.3. 10

"Proposed

Antici patory

Trip

Modificati on."

Appendix,

Page

50;

and

SER Section

15.9. 10 state that

no modification

to the

standard

anticipatory trip has

been

proposed.

Therefore,

as

discussed

in the

SER section, this item is not applicable to the Harris

Plant.

This item is closed.

II.K.3.11 "Justification of Use of Certain

PORYs."

FSAR TMI Appendix,

Page

51;

Table 1.1,

and

Section 15.9.7;

and

NUREG 0611,

Section 3.2.4.4

address

the requirements,

and

CP&L's

commitments,

to

this item.

CP&L states that the "Control Component,

Inc." (CCI)

PORYs

are not utilized

on the Harris Plant pressurizer

and therefore this TMI

Action Item is not applicable.

This item is closed.

II.K.3.12 "Confirm Existence of Anticipatory Reactor Trip Upon Turbine

Trip."

TMI Appendix,

Page

52;

Section

7.2.2.5;

and

Section

7.2. 1. 1.2.f

address

CP&L's compliance

with this

item.

As

stated

in the

SER,

CP&L's design

of this trip feature

was

found

acceptable

by

NRR.

The inspector

evaluated

the Westinghouse

drawing

(108D831,

Sheet

15) which depicts

the anticipatory reactor trip upon

turbine trip

and

the applicable'arris

Plant

proposed

technical

specification

requirements

(Table 3.3-1)..

This item is closed.

II.K.3.17

"Report

on

Outages

of

ECCS;

Licensee

Report

and

Proposed

Technical

Specification

Changes."

FSAR TMI Appendix,

Page

53;

and

Section

15.9. 11

commit

CP&L to

a program for collecting

ECCS

outage

information for

NRC.

As discussed

in

SER Section

15.9. 11,

NRR has

found

CP&L to be in compliance with this TMI Action Item.

This item is

closed.

II.K.3.25 "Effect of

Loss

of

AC

Power

on

Pump

Seals."

Appendix,

Page

54;

and

SER Section

15.9. 12 address

CP&L's evaluation of

the consequences

of loss of

RCP seal cooling.

In the

FSAR CP&L states

that adequate

cooling has

been provided

and that

no modifications are

necessary.

As discussed

in SER Section

15.9. 12,

NRR has

reviewed plant

RCP seal

cooling system design

and has found it to be adequate,

without

the need of plant modifications.

This item is closed.

II.K.3.30 "Revised

Small-break

LOCA Methods to

Show Compliance with

10 CFR 50,

Appendix K."

FSAR TMI Appendix,

Page

55,

and

SER Section

15.9.13

address

CP&L's compliance with this

TMI Action Item.

NRR has

accepted

the

original

small-break

model

as

in

compliance

with

Appendix

K.

This item is closed.

II.K.3.31 "Plant-specific Calculations

to

Show Compliance with 10 CFR 50. 46. "

TMI Appendix

and

Section

15.9. 14

address

CP&L'

position concerning this

TMI Action Item.

Westinghouse's

new small-

break

LOCA

model

(WCAP-10054,

dated

March 26,

1982)

is

presently

undergoing

review by NRR.

CP&L has committed to submit plant specific

calculations

showing

compliance with

10 CFR 50.46,

either

within one

year of NRR's approval of the model, or before fuel load, whichever is

later.

As stated

in the

SER Section

15.9. 14,

NRR has

determined

that

14

CP&L's commitment is acceptable.

No action is required

by Region II.

This item is closed.

XX.

zz.

aaa.

III.A.l. 1

"Upgrade

Emergency

Preparedness."

TMI Appendix,

Page

57;

and

SER Section

13.3.4

address

CP&L's compliance with this

item.

The requirements

of this item were

superseded

with issuance

of

the final rule on emergency

planning

(45FR55402).

As discussed

in the

SER,Section

13.3.4, this item is closed.

I

III.A.1.2

"Upgrade

Emergency

Support Facilities."

TMI Appendix,

Page

58;

and

SER Section

13.3.4 address

CP&L's compliance with this TMI

Action

Item.

NRC

conducted

an

evaluation

of the

Emergency

Planning

Program,

including the support facilities.

The results of the

evaluation

were

documented

in

Region II report

400/85-09.

Further

evaluation

of the

emergency

response

was conducted during the week of

May 13,

1985.

The

results

of this

evaluation

are

addressed

in

Region II inspection

report 400/85-20.

This is an Inspector

Follow-up

Item "III.A.1.2 Upgrade

Emergency

Support Facilities" 400/85-16-25.

III.A.2 "Improving Licensee

Emergency

Preparedness

-

Long Term."

Section

13.3.4;

Harris Plant

Emergency

Plan;

and

NUREG 0737,

Supple-

ment

1

address

CP&L's compliance

with this

TMI Action

Item.

NRC

conducted

an evaluation of the

CP&L Emergency

Plan,

and the results

are

documented

in

Region II report

400/85-09.

The

program

was further

evaluated

during the week of May 13,

1985.

The concerns resulting from

this evaluation

are addressed

in Region II inspection report 400/85-20.

This is

an

Inspector

Follow-up

Item "III.A.2 Improving

Licensee

Emergency

Preparedness

Long Term" 400/85-16-26.

III.D.1.1 "Integrity of Systems

Outside

Containment

Likely to Contain

Radioactive Material."

FSAR TMI Appendix,

Pages

59 and 60;

CP&L letter

of response

to

NRR dated July 11,

1984;

and

SER Section

9.3.5

address

CP&L's

compliance

with this

item.

The

leak

reduction

program,

as

described

in the

FSAR TMI Appendix,

was reviewed

by

NRR with comments.

This

TMI Action Item is listed in the

as

an outstanding

issue.

After the

program

has

been

accepted

by

NRR,

Region II will verify

implementation

of the

leak reduction

program.

This is

an Inspector

Follow-up

Item "III.D.1. 1 Integrity of Systems

Outside

Containment

Likely to Contain Radioactive Material" 400/85-16-27.

III.D.3.3 "Improved

Inplant

Iodine

Instrumentation

Under

Accident

Conditions."

FSAR TMI Appendix,

Page

61;

Section

12.3.4.2;

and

Section

12.3

addr ess

CP&L'

position

on this

TMI Item.

The

equipment to be utilized by CP&L, concerning their position

on this TMI

Item,

has not yet arrived at the Harris Plant.

CP&L has not yet fully

completed

the

implementing

procedure

for

using

this

equipment.

Region II will verify installation

of

equipment

and

evaluate

the

equipment

operating

procedures.

This is

an

Inspector

Follow-up Item

"III .D.3. 3

Improved

Inp1 ant

Iodine

Instrumentati on

Under

Accident

Conditions" 400/85-16-28.

15

bbb.

CCC.

III.D.3.4 "Control

Room Habitability Requirements."

FSAR TMI Appendix,

Page

62;

FSAR Section 6.4 and 9.4. 1; and

SER Section 6.4 address

CP&L's

compliance

with this

TMI Action Item.

CP&L has

proposed

a technical

specification

section

(3.7.6)

as

required

by the Action Item.

As

discussed

in

Section 6.4,

NRR reviewed

and

accepted

the

Harris

Plant design

concerning this TMI Action Item.

No action is required

by

Region II in closing this item.

This item is closed.

Item I.D.2 "Plant Safety

Parameter

Display Console".

This TMI Action

Item has

not

been

addressed

in the

FSAR or the

The

NRC require-

ments concerning this item, are addressed

in Supplement

1 to

NUREG 0737

(Generic Letter 82-33).

A detailed description of the Harris Plant

safety parameter

display

system is discussed

in

a

CP&L letter to

dated

December

2,

1983.

This letter

contains

the safety analysis

of

the Harris

system.

Representatives

from the

NRC

Human

Factors

Group

have

conducted

an onsite audit of the safety parameter

display system

and their

review is still

ongoing.

The

system

installation

is

incomplete

and the procedures

and training program are being developed.

This

TMI Action Item will remain

open

pending

NRR'

acceptance

of

CP&L's .safety parameter display system.

This is an Inspector

Follow-up

Item "I.D..2 Plant Safety Parameter

Display Console"

400/85-16-.29.

6.

Electrical

(51053C,

51063C,

92706B)

~

a.

The ins ector

observed

the

wo

p

rk and inspection activities associated

with completion

of FCR-I-1886

on the

secondary

control

board.

This

work involved modifications of internal wiring for indicating lights on

the control

switches.

This work was

being performed

under the di rec-

tion of the switch vendor,

Reliance Electric Company, with CP&L and the

vendor

QA personnel

conducting

the

inspection activities.

All work

activities

were

being

performed

under

work

procedure

"Assembly,

Disassembly,

Modification or Repair of "Q" Equipment"

(WP-137).

b.

The inspector

accompanied

CI inspection

personnel

on

an inspection of

conduits

10191E,

10191F and

16215E-SA in the containment building.

The

inspection

rejected

the

installation

because

all

required

conduit

supports

had

not

been

installed.

A review of the

status

of these

required

supports

by the inspector indicated that for many field routed

conduit,

the

design

and

installation

of

supports

was

not

being

completed prior to conduit installation.

Further

review

on this also

indicated that in many

cases

these

supports

were

being

designed

and

erected

under

the electrical field modification program.

This program

is described

in

CP&L construction

work procedure

"Installation

of

Seismically

Supported

Electrical

Cable Trays,

Conduits,

Boxes

and

Bus

Ducts" (WP-203).

This procedure

is designed

to allow field modifica-

tions to existing components.

This procedure basically allows for work

to "proceed-at-risk"

until the modification is

approved

by design.

Item 3. 15.6 requires

that these

modifications

be incorporated

into

a

Field Change

Request/Permanent

Waiver (FCR/PW) within five working days

or all

work

on this modification

must

be

stopped.

Item 3. 18 addi-

tionally requires that the modification will not be presented

for final

16

inspection

unless

the

modification

has

been

incorporated

into

an

approved

FCR/PW.

A review of the Electrical

Field Modification (EFM)

log

showed that neither of the above procedurally-required

controls is

being followed.

The log shows

EFM No.

118 was initiated

on March 25,

1985,

and

had

not

been

incorporated

into

an

FCR/PW to date.

EFM

No. 121, initiated on March 26,

1985,

has the

same status

and this- item

had also

been

presented

for acceptance

inspection.

A review of this

log,shows

many other instances

of the

same deficiencies.

The failure

to follow procedural

requirements

is contrary to the requirements

of

10

CFR

Appendix B,

Criterion V,

PSAR

Section 1.8.5.5

and

the