ML18019A543

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Insp Rept 50-400/85-49 on 851120-1220.Violation Noted: Failure to Incorporate Changes to RCS Drawings
ML18019A543
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 01/09/1986
From: Burris S, Fredrickson P, Maxwell G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18019A540 List:
References
50-400-85-49, NUDOCS 8601270455
Download: ML18019A543 (9)


See also: IR 05000400/1985049

Text

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report No.:

50-400/85-49

Licensee:

Carolina

Power

and Light Company

P. 0.

Box 1551

Raleigh,

NC

27602

Docket No.:

50-400

License No.:

CPPR-158

Facility Name:

Harris Unit

1

Inspection

Co

ed:

4e

ember

20 - Dece ber 20,

1985

Inspectors:~G..

Maxw

Date Signed

~ S.

. Burri

Approved by:

P.

E. Fredrickson,

Section Chief

Di.vision of Reactor Projects

at

Signed

at

Signed

SUMMARY

Scope:

This routine,

announced

inspection

involved 126 resident

inspector-hours

on site in the areas

of Fire Prevention/Protection,

Preoperational

Test Program,

Comparison of As-Built to

FSAR Description,

and Other Activities.

Results:

Of the

four

areas

inspected,

no violations

or deviations

were

identified in three

areas;

one violation

was

found in one

area

("Failure to

Incorporate

Changes

to System Drawings", paragraph 5.c.)

8gPg270455

860>o9

8

REPORT DETAILS

Persons

Contacted

Licensee

Employees

N. J. Chiangi,

Manager,

QA/QC Harris Plant

J.

N. Collins, Manager,

Operations

G.

L. Forehand,

Director,

QA/QC

J.

L. Harness,

Assistant Plant General

Manager,

Operations

C.

S. Hinnant,

Manager,

Start-Up

L. I. Loflin, Manager,

Harris Plant Engineering

Support

D. A. McGaw, Superintendent

QA

C.

L. McKenzie, Acting Director, Operations

QA/QC

G. A. Myer, General

Manager,

Milestone Completion

R.

N. Parsons,

Project General

Manager,

Construction Confirmation

Completion

N. Thompson, Jr.,

Manager,

Engineering

Management

D.

L. Tibbitts, Director, Regulatory

Compliance

B.

Van Metre,

Manager,

Harris Plant Maintenance

M.

D. Vernon, Superintendent

QC

E. J.

Wagner,

Manager,

Engineering

C.

C. Wagoner,

Project. General

Manager,

Construction

R. A. Watson,

Vice President,

Harris Nuclear Project

J.

L. Willis, Plant General

Manager,

Operations

Other licensee

employees

contacted

included

12 construction

craftsmen,

eight

technicians,

ten operators,

and ten engineering

personnel.

Exit Interview

The inspection

scope

and findings were

summarized

on December

20,

1985, with

the Plant General

Manager.

No written material

was provided to the licensee

by the resident

inspectors

during this reporting period.

The licensee

did

not identify as proprietary

any of the materials

provided to or reviewed

by

the

resident

inspectors

during this

inspection.

The

licensee

provided

dissenting

comments

concerning

the identified violation during

the exit

meeting.

Fire Prevention/Protection

(42051C,

71302)

The inspectors

observed

the fire prevention

and protection activities

related to containing combustible materials

where the ignition of these

materials

could

damage

safety-related

structures.

The inspectors

also

observed

the ongoing site training activities for the construction fire

brigade.

b.

Some

of the

specific

areas

observed

by the

inspectors

during this

period were:

( 1)

Nonflammable

protective

cover'ings

were

observed

over

various

safety-related

pumps

and components

located throughout the plant.

(2)

During the various tours of the reactor auxiliary building and the

containment

building,

the

inspectors

observed

that

the

accumulation

of combustible

materials

in these

areas

was

being

minimized.

(3)

Flammable

materials

were

stored

to

prevent

or

reduce

the

likelihood of combustion.

(4)

Welding activities

were

observed

in at

least

seven

separate

locations throughout the site

and in each

instance it was observed

that appropriate fire extinguishing

equipment

was available within

close proximity of the welding activities. It was also noted that

the

portable

fire

extinguishers

contained

sufficient

fire

extinguishing

medium,

as

evidenced

by

displaying

current

inspection stickers

and having unbroken

seals.

(5)

The inspectors

observed that at the various elevations

throughout

the reactor auxiliary building and the containment building, fire

suppression

devices

were

strategically

located

and

readily

available for use.

No violations or deviations

were identified in the areas

inspected.

Preoperational

Test

Program

(71302,

424008,

37301)

a.

The

inspectors

conducted

tours

of

the

various

plant

areas.

The

following items

were

observed

and

assessed

during the tours to assure

compliance with requirements:

(1)

The

inspectors

observed

electrical

personnel

placing

cables

in

their respective

cable trays

and conduits.

Sufficient care

was

being taken

to prevent

damage

to the cables

being

placed

and to

cables

which already

had

been installed.

(2)

The

inspectors

looked for uncontrolled

openings

in previously

cleaned

or flushed

systems

or components.

Where

system

openings

were

identified,

cleanness

controls

were

established

during

flushing.

(3)

The

inspectors

observed

three

instances

in which construction

personnel

were working on equipment which had already

been turned

over to the start-up

group.

The work was being accomplished

under

the

proper

administrative

controls

provided

in

the

Start-up

Manual.

b.

The

inspectors

evaluated

the activities

being

conducted

by

CP5L

operations

QA Surveillance

personnel.

QA Surveillance

personnel

were

present

to

observe

the

preoperational

tests

conducted

during thi s

reporting

period.

The results

of their observations

were

promptly

documented

and distributed

to

those

responsible

for the activities

which were observed.

The

inspectors

reviewed

log

books

maintained

by the test

group

to

identify problems

or plant activities that

may

be

appropriate

for

additional

follow-up.

The

inspectors

observed

operations

personnel

deenergizing electrical

components

as required

by the clearance

program

when equipment is being placed out of commission for repairs,

tests

or

rework.

During the

week of

November

25,

1985,

the

inspectors

observed

the

testing of the "B" emergency

diesel

generator

sequencer

circuits.

The

test

was

conducted

to determine if the

sequencer

would function to

allow the correct

sequence

of electrical

loading.

During the

week of December

2,

1985, the inspector participated

in an

inspection

which was

conducted

by regional

inspection

personnel.

The

inspection

included continued observation

of the preoperational

testing

of

"B"

emergency

diesel

generator

sequencer

circuits

(Start-up

Procedure

5095-P08);

testing

the auxiliary feedwater

system

(Start-up

Procedure

3065-P01);

and testing

the reactor

coolant

pump

seal

water

system (Start-up

Procedure

2060-P04).

(1)

Prior to. starting

the test,

the start-up

and test personnel

made

sure

that

they

were

authorized

to

conduct

the test

and that

current drawings

and procedures

were available for use.

(2)

The inspectors

interviewed the test personnel

and found them to be

knowledgeable

of the applicable test procedure

(Start-up

Procedure

5095-P08).

(3)

The test

personnel

were

aware of the procedures

which allow them

to make

changes

to

a test procedure

during the conduct of testing.

(4)

The test

was

conducted

in accordance

with the

applicable test

procedure

(Start-up

Procedure

5095-P08).

The inspectors

witnessed

selected

portions of section

6, step 6.4.52 of

test

procedure

1-5095-0-03,

Initial

Engine

Run.

The

inspectors

observed

the collection of data

base vibration information from the "B"

emergency

diesel

generator

during partial

load and full,load conditions

in order to verify the following:

(1)

Overall personnel

performance

during the test

was adequate.

(2)

An approved

procedure

was available

and in use.

(3)

Test equipment

being

used

was properly installed

and calibrated

(4)

Personnel

performing

the

test

were

qualified

to

perform

the

evolution.

During the

week of

December

8,

1985,

the

licensee

conducted

test

procedure

1-5145-P-01,

Start-up,

Unit Auxiliary, and

Main Transformer

Preoperational

Test

(SAT and

UAT).

While performing section

6,

steps

6.3. 17. 17.6

and 6.4.5,

the

CP&L Cape

Fear Facility noted significant

line current increases

and voltage drops.

This was determined

to be

an

effect

of trying to

charge

and

pick

up

the

Shearon

Harris unit

auxiliary

and

main

transformers,

creating

a

reverse

current

flow

condition, which causes

large current increase

and voltage drops.

This

would only cause

an offsite problem with the nearest grid supply system

(Cape

Fear)

when

CP&L tried to maintain

their

system

in automatic

control at its lowest setting.

CP&L management

has

committed to change

their operations

procedures

to include

a precautionary

note to alert

the dispatcher

of this potential

problem prior to performing this

evolution.

In addition,

the

licensee

has

committed to include this

possible

problem

in their trai ning

program.

This

item will

be

identified

as

an

Inspector

Follow-up Item,

"Transformer Operability

Problems",

400/85-49-05.

1

The

inspectors

witnessed

the

reassembly

of

1A-SA emergency

diesel

generator

intake

and

exhaust

valves

which

were

removed

for the

inspection

program in accordance

with the

Westinghouse

Owners

Group

recommendations.

This

activity

was

performed

in

accordance

with

Corrective Maintenance

Procedure

CM-M0150, "Emergency

Diesel

Generator

Cylinder

Head

Removal,

Disassembly

and

Reassembly",

Rev.

0,

section

7.5. 1,

steps

1

through

7.

The

inspectors

questioned

the

craft

personnel

performing this activity and reviewed the procedure

to verify

that personnel

were

trained

and

knowledgeable

on

reassembly

of the

valves.

An approved

copy of the

maintenance

procedure

was available

and in use

by the personnel

and hold points were identified, witnessed

and signed

as required

by the procedure.

No violations or deviations

were identified in the areas

inspected.

Comparison of As-Built Plant to

FSAR Description

(37301)

The inspectors

evaluated

the installed condition of Loop "B" of the

Safety Injection System (SI).

The evaluation

was to determine if the

as-built plant

conforms

to the

commitments

contained

in the

FSAR.

Specifically, the inspectors verified that the physical installation is

in

agreement

with simplified

flow diagrams

(SFD)

and

with the

applicable

FSAR figures.

The following

SFD

and

FSAR figures

were

compared

to the most recent

EBASCO design drawings.

SFD:

CPL-2165-S-1309

Sheet

2 (Rev

~ 7)

EBASCO Design Drawing:

CAR-2165-G-809

(Rev.

10)

EBASCO Design Drawing:

CAR-2165-G-810

(Rev.

14)

FSAR:

Figure 6.3.2-2

The

FSAR figure 6.3.2-2

was found not to be the most current revision

of the

EBASCO Site Design Drawing (CAR-2165-G-809).

The

FSAR Revision

is

shown

as

Rev.

7 whereas

the site document control center

shows

Rev.

10 as being the most current revision for CAR-2165-G-809.

The inspector

also

found that there

are

two outstanding

Design Field

Change

Requests

( FCRs)

which

may

have

an

impact

on

the as-built

condition of the nitrogen

accumulators

for this

system.

These

design

changes will affect drawing CAR-2165-G-809

and will require tracking to

determine

adequacy

of the

system

for operation.

The

FCRs

were

identified as

FCR-SI-711

and

FCR-J-2691.

The above condition will be identified as

an Inspector

Follow-up Item,

"As-Built Condition of SI System",

400/85-49-02.

While conducting

a walkdown of the SI System,

the inspector

observed

the

following items:

(1)

Valve 2SI-V554SB-1

The valve position

scale

was missing.

CPCL

documented this condition

on Deficiency Report tag

number 06329.

(2)

Valves

4SI-V332-1

and 4SI-V210-1

Handwheels

cannot

be operated

due to interference

with adjacent

pipe

hangers.

CPAL start-up

personnel

notified

construction

about

this

concern.

Field

modifications will be required to allow the proper

operation

of

these

valves.

(3)

The

instrumentation

air valve for valve

2SI-V530SB-1

cannot

be

operated

due to interference with an adjacent

structural

support.

CP5L

documented

this condition

on Deficiency Report

tag

number

06330.

The

above

three

items will be collectively identified as

an Inspector

Follow-up Item, "Operability of SI Valves", 400/85-49-03.

b.

The

inspectors

performed

a

walkdown

and

review

of

the

auxiliary

feedwater

system

(AF) loops "A", "B", and

"C" to

determine if the

as-built plant configuration

conforms to the

commitments outlined in

the

FSAR.

The inspection

was

performed

to verify that the

physical

conditions

agree with those identified on the simplified flow diagrams

(SFD)

and applicable

FSAR requirements.

The identified

SFD

and

FSAR

figures were compared to the most current

EBASCO design drawings.

SFD:

CPL-2165-S-0544

SFD:

CPL-2165-S-0545

FSAR:

Figure

10. 1.0-3

FSAR:

Figure 10. 1. 0-4

EBASCO Design Drawing:

CAR-2165-G-044

EBASCO Design Drawing:

CAR-2165-G-045

The inspectors

informed the licensee that the

FSAR figures 10.1.0-3

and

10. 1.0-4

were

not the

most current

revisions

of the

EBASCO design

drawings

(CAR-2165-G-044

and

CAR-2165-G-045).

The

FSAR revisions

are

e;

shown

as

Rev.

10,

whereas

the site document control center

shows

Rev.

14 as being the most current revision for CAR-2165-G-044,

and

Rev.

13

as the most current revision for CAR-2165-G-045.

During the walkdown the inspector

noted the following items:

(1)

Va1 ves

lAF-146

and

1AF-113

were

mi ssing

any

type

of

identification,

and therefore

were not clearly identifiable.

(2)

Valve

1AF-19 motor leads

were tied back with metal

wire due to

what appeared

to

be

an interference

problem with the mechanical

operator.

(3)

Pipe

strap

temperature

sensors'ocations

need

to

be correctly

identified on drawings.

All of these

concerns will be identified

as

an Inspector

Follow-up

Item, "As-Built Condition

and Operability of the Auxiliary Feedwater

System",

400/85-49-04.

c.

The inspectors

evaluated

the installed configuration of Loop

1 of the

reactor coolant

system

(RCS).

The following SFD

and

FSAR figure were

compared to the most current

EBASCO design drawing.

SFD:

CPL-2165-S-1300

(Rev.

3)

EBASCO Design Drawing:

CAR-2165-G-800

(Rev.

11)

FSAR:

5.1.2-1

(Rev.

7)

The

FSAR figure 5. 1.2-1

(Rev.

7) was found not to be the most current

revision of the

EBASCO design

drawing,

CAR-2165-G-800

(Rev.

11).

In

addition, the inspectors

identified the following discrepancies:

(1)

Three

(one

on each

loop) 3/4" capped

and valved (2) lines .tapping

off of the reactor

coolant

system

RTD lines.

These

lines

are

identified

on

EBASCO

design

drawing

CAR-2165-G-800

as

2RC

3/4-200SN-1,

2RC

3/4-201SN-1

and

2RC

3/4-202SN-1,

but

are

not

included

on

FSAR figure 5. 1.2-1

(Rev. 7).

(2)

Pressure

transmitter

¹1-PT-441

was

. identified

on

EBASCO design

drawing CAR-2165-G-800,

and is physically installed in the plant,

but is not identified on the most current revision of FSAR figure

5.1.2-1

(Rev. 7).

(3)

The inspectors

noted that the

high point vent lines

and valves

were not identified on any of the identified drawings.

(4)

There are three outstanding

Field Change

Requests

(FCRs) which may

have

an

impact

on the as-built condition of the reactor

coolant

system,

and these

changes will require modifying the

EBASCO design

drawing to reflect the actual plant conditions.

The above identified items will be identified as

an Inspector

Follow-up

Item, "As-Built Condition of the Reactor Coolant System",

400/85-49-06.

Additionally,

the

inspectors

identified

to

licensee

personnel

a

discrepancy

between

the

EBASCO design

drawing

CAR-2165-G-800

and the

actual

as-found

condition

of

the

plant

as

follows:

during

a

hand-over-hand

inspection

of the

RCS

piping

using this

EBASCO site

design

drawing,

the inspector identified

a 3/4" pipe

tapped

from the

RCS hot leg.

This line was traced

to

a valve,

1-8016A/2RC-U296SN-1

which

was identified

as

the isolation valve for the reactor

vessel

level instrumentation

system

(RVLIS).

The inspector obtained

a current

copy of the

RVLIS drawing,

EBASCO design drawing CAR-2165-G-844

(Rev.

1) which

shows

the

cross

connection

from the

RVLIS to the

reactor

coolant

system.

The

RVLIS was installed

using

FCR

M-873

and

DCN

530-1199.

Neither of these

documents

referenced

CAR-2165-G-800

as

requiring

updating

due to the

RVLIS addition.

This drawing is pre-

sently used

by the control

room operators

for

RCS reference

and will

be

used

in the control

room as

a controlled copy reference after unit

startup.

Discussions

with licensee

management

identified that

the

RVLIS (TMI Action Item II.f.2) was

added

to the plant to allow for

vessel

level indication during

an

inadequate

core cooling event.

The

Harris Plant Engineering

and Systems

(HPES) organization

has generated

a

new

FCR

$3P-4854 to correct the missing drawing details.

The

inspectors

informed

CPRL

management

that failure to revise

the

currently

approved

copy of CAR-2165-G-800

to reflect

the as-built

condition of the plant is contrary to

10 CFR 50, Appendix B, Criterion

III and

PSAR

Section

1.8.5.3.

This

is

a violation "Failure

to

Incorporate

Changes

to System Drawings" 400/85-49-01.

Other Activities

(71302)

During

the

week of

December

2,

1985,

personnel

from the office of

Nuclear

Reactor

Regulation

(NRR) visited the site.

The visit was

a

part of

an

evaluation

which is

being

conducted

by

NRR concerning

seismic qualifications

and operability of pumps

and valves.

On

December

9,

1985

the

Region II Director of the

Reactor

Projects

Division and the Harris Site Region II Reactor

Projects

Section

Chief

visited

the

Harris Site.

Their

agenda

included

a briefing by

CPAL

concerning

the status

of the project overview, construction,

start-up

(status of systems,

procedures

and tests),

and readiness

for operations

(staffing, training,

INPO evaluations

and

key milestones).

Following

the briefing

a tour was

made throughout the plant site,

concluding with

a visit to the

CP5L off-site training facilities.