IR 05000400/1986062

Insp Rept 50-400/86-62 on 860707-25.No Violation or Deviation Noted.Major Areas Inspected:Electrical Separation, Licensee Actions on Previous Enforcement Items & Licensee Identified Items

ML20209A800
Person / Time
Site:	Harris
Issue date:	08/21/1986
From:	Conlon T, Gibbons T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20209A741	List: IR 05000400/1986062 ML20209A736
References
50-400-86-62, NUDOCS 8609080106
Download: ML20209A800 (7)

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UNITE'3 STATES o NUCLEAR REGULATORY COMMISSION

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. REGION 88 101 MARIETTA STREET,N.W.

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Report No.: 50-400/86-62 Licensee: Carolina Power and Light Company P. O. Box 1551

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Raleigh, NC 27602 Docket No.: 50-400 License No.: CPPR-158

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Facility Name: Harris 1 Inspection Conducted: July 7-25, 1986 Inspector: td / bnw

T. D. Gibbons Th/

Date Signed Accompanying Personnel: .D. C. Ford Approved byr 62/t T. E. Conlon, Section Chief

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Engineering Branch Division of Reactor Safety SUMMARY

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Scope: This routine, unannounced inspection was conducted in the areas of

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electrical separation, licensee action on previous enforcement items and licensee identified item Results: No ' violations or deviations were identifie .

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REPORT DETAILS Persons Contacted

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Licensee Employees

• N. J. Chiangi, Manager QA/QC Harris Plant

• J. M. Collins, Manager, Operations

• G. L. Forehand, Director, QA/QC

• J.L. Harness, Assistant Plant General Manger, Operations

• C. S. Hinnant, Manager, Start-up

• L. I. Loflin, Manager, Harris Plant Engineering Support

• C. L. McKenzie, Acting Director, Operations QA/QC

• G. F. Myer, General Manager, Milestone Completion

• M. Thompson, Sr., Manager, Engineering Management

• L. Tibbitts, Director, Regulatory Compliance

• Van Metre, Manager, Harris Plant Maintenance

• V. Hate, Principal QA Engineer

• A. Watson, Vice President, Harris Nuclear Project

• J. L. Willis, Plant General Manger, Operations NRC Resident Inspectors

• G. Maxwell, Senior Resident Inspector S. Burris, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on July 25, 1986, with those persons indicated in the paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received fran the license Unresolved Item 400/86-62-01: Failure of Quality Assurance Program to Identify All Electrical Separation Deficiencies (paragraph 5).

I Unresolved Items 400/86-62-02: Review the Reportability of All NCRs Involv-ing Electrical Cable Separation Deficiencies (paragraph 5).

The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters (Closed) Unresolved Item 400/86-30-01: Verify that Section 7.3.2.1. of the FSAR is revised as described in Westinghouse Letter No. CQL 9308. The licensee and Ebasco requested Westinghouse concur to a proposed FSAR change

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that allows analytical justification as well as physical conformance to the requirements of Appendix B to WCAP-8584/8670. Westinghouse concurred to the change in ' letter CQL 9308 dated April 28, 1986, titled Instrument Impulse Lines - Separation Criteri This change has been incorporated into the FSAR as Revision 27. The inspector has no further question . Unresolved Items Unresolved items are matters about which more information is . required to determine whether they are acceptable or may involve violations or devia-tions. Two new unresolved items identified during this inspection are discussed in paragraph . Electrical Cable Separation During the course of looking into a workers concern the NRC contractor

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inspector.and the Senior Resident Inspector (SRI) conducted interviews with a number of site inspection personnel. Responses obtained during the interviews raised several questions with regard to the adequacy of inspec-tions to assure compliance with Regulatory Guide (RG) 1.75, Physical Inde-pendence of Electric Systems. This RG endorses the IEEE Standard 384-1974 titled, IEEE Trial-Use Standard Criteria for Separation of Class IE Equip-ment and Circuits. This commitment is in FSAR Sections 7.1.2.2.1 and 8.3.1.2.1 Subsequently, the licensee submitted an aniendment to the FSAR identifying exceptions to the separation criteria of RG 1.75. Justification for these exceptions is based upon a test program conducted by Wyle Laboratories. The

test program methodology and test results are documented in Wyle Test Report I number 47879-02. The exceptions were reviewed by NRR and found acceptable as stated in Supplement No. 3 to NUREG-1038 dated May 1986.

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The NRC contractor inspector and the SRI conducted an inspection of eleva-

tion 286'0" of the Fuel Handling Building (FHB). This building was chosen because it had been completely inspected and was turned over to nuclear operations. The NRC contractor inspector examined .the east wall of eleva-

! tion 286'0" using the site inspection procedures which are based on RG 1.75

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and do not include the exceptions allowed by the Wyle Test Report. This i inspection identified 107 points which were discrepant. Of the 107 discrep-ancies identified, the licensee had identified 95 of them in previous

inspection. Therefore,12 of these discrepancies had not been previously

identified. The separation discrepancies observed were of several catego-

! ries; between raceway components of redundant safety divisions, between

< raceway components of a single division and a non-nuclear safety division.

l and between raceway components of one safety division and exposed cable of another safety division or non-nuclear safety division. The results of this

inspection caused the licensee to conduct a 100% reinspection of the FHB to

quantify the problem so that corrective action could be specifie The

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licensee's reinspection identified 774 discrepant points including 243 discrepant points which had not been previously identified by earlier inspection The 774 discrepant points were evaluated by design using the Wyle test report criteri Design evaluation found that 748 discrepant points were acceptable but 26 discrepant points were technically unaccept-able and will require rewor The licensee performed additional reinspections in areas A-110 and A-459 of

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the Reactor Auxiliary Building (RAB) to determine whether the problems identified in the FHB existed in other areas of the plant. The inspection identified 305 discrepant points including 79 points which were not identi-fied during previous inspections. Design evaluation using the Wyle criteria found that 292 points were acceptable and 13 discrepant points,were found to be technically unacceptable and will require rewor '

The NRC inspectors performed an inspection of area A-104 on elevation 261'0" of the RAB in order to independently evaluate the problem. The inspectors identified 58 separation discrepancies. Research on these items is still incomplete; however, the licensee has identified two discrepancies out of the 58 which were not previously identifie Based on the findings of the licensee's reinspection,1079 discrepancies existed with respect to the cable separation requirements of RG 1.75. The initial inspections conducted by QC identified only 757 of the 1079. This amounted to 322 discrepancies that were not identified on the initial inspections. When the 1079 discrepancies were evaluated against the Wyle Test Report,1040 were found to be acceptable. This left 39 discrepancies that were determined to be deficient and would require rework. The initial QC inspections did not identify 26 of the 39 deficiencies. The remaining 13 deficiencies are currently being checked by the licensee to determine if they were overlooked during the initial inspection The licensee was previously cited for two violations that involved cable separations. One of the violations (400/85-04-01) identified inadequate inspection for separation between nonsafety cable trays and a safety related conduit in the RAB. The other violations (400/85-08-01) involved design approval of a Field Change Request (FCR) E-1304 which was in direct conflict with the requirements of RG 1.75 and IEEE 384-1974. As part of the correc-tive action for violation 400/85-08-01 the licensee's design engineering (HPES) issued FCR-E-4563 dated April 25, 1985, which contained new inspec-tion criteri This caused the licensee to revise existing inspection procedures and to reinspect safety-related electrical equipment and raceways that had been previously inspected and accepted prior to May 1985. For those installations that had not been previously inspected the licensee choose to inspect to the new criteria and the discrepancies were documented on Nonconformance Report (NCR) 85-1665 (dated July 9,1985). This NCR documented 1482 discrepancies with cable separation criteri .

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In view,of the current problem, it is clear that the licensee . failed Eto

, recognize the full implication of Violation 400/85-08-01 and as a result of

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that failure, the corrective action specified was inadequate to preclude further deficiencies in cable separatio This is an Unresolved Item which will be identified as 400/86-62-01; Failure

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of the Quality Assurance Program to Identify All Electrical Separation

Deficiencie During the review of the separations issue identified in the above para- '

graph, the inspector noted that there was no construction deficiency report

(CDR) submitted to the NRC documenting the electrical cable separation

! problem An unresolved item 400/85-39-02 titled, Review the Causes of NCR

85-1665 for Reportability was opened in November 1985. At that point in time, the licensee deemed it not reportable because the final QC inspection l (walkdown) had not been reached under the new program. This item was closed on the above basis; however, in light of the new findings in.this area a new

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unresolved item is being opened. This unresolved item will be identified as 4 400/86-62-02, Review of Electrical Cable Separation NCRs with respect to j 50.55(e) requirements.

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+ (Closed) Item 400/CDR 84-1917.5 KVA Inverters - Insulation Breakdown (10CFR50.55(e))

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The final report was submitted on July 9,1986. The report has been reviewed and determined to be acceptable. The inspector held discus-

sions with responsible licensee representatives and reviewed supporting i documentation to verify that the corrective actions identified in the

report have been completed.

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. Westinghouse Electric Corporation (WEC) notified the licensee of a

insulation breakdown on a General Electric Company ferro-resonant >

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! transformers supplied with WEC 7.5 KVA Inverters. The transformer

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'. failures were due to an insulation breakdown between the coil and the ccre of one of the two reactors connected to the secondary of the

- transformer. The failure is caused by. internal vibration which result- .

ed from insufficient securing of laminations which make up the center The operation of the transformer result in a

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leg of the reactor core.

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failure of coil insulation after a period of tim ,

WEC recommended that the site inspect all inverters to identify if any

part number 3485C38-H08 transformers are installed. Six inverters at j the plants were found to have questionable transformers. WEC stated

! that if the transformer operated for six months under load without I degradation it can be concluded that the manufacturing defect does not

exis The licensee performed the six month load test of Channel I, *

II, II, and VI inverters and the SA and SB inverter _

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The licensee identified that Channel VI failed due to a deficient transformer af ter the. end of the test. The transformer was replaced j' and a' new six month load test was completed. The licensee reported that General Electric Company is now manufacturing ferro-resonant

transformers which are not' subject to this failur ;

' (Closed) Item 400/CDR-84-188, Air Operated Diaphragm Valves do not Meet Design Value for Natural Frequency (10 CFR 50.55(e))

The final report was submitted on September 30,^ 1985. The report has

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been reviewed and determined to be acceptable. The inspector held

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discussions with responsible licensee and contractor representatives ,

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and reviewed supporting documentation to verify that the corrective

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actions identified in the report have been completed. Westinghouse Electric Corporation (WEC) notified the licensee that a number of air i operated diaphragm valves supplied by ITT-Grinnell were found to have a natural frequency of less than 33 hertz. The valves were designed to have a natural frequency above 33 hertz,

, When a piping system is analyzed, valves with a natural frequency above 33 hertz are considered to be a rigid segment. . If the natural frequen-cy is below 33 hertz, the valve is considered a flexible segment and i must be analyzed as such.

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The licensee identified the 36 valves which are involved. There are 27 valves suppli,ed by WEC and 9 valves in the balance of plant equipment.

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These are 17 stress calculations which required re-analysis incorpo-rating the flexibility of the valves. The re-analysis identified three

additional restraints which were installe (Closed) Item 400 CDR 85-209 6.9KV Switch Secondary Disconnect Fingers (10 CFR 50.55(gear e)) Circuit Breakers -

The final report was submitted on July 2,1986. The report has been

[ reviewed and determined to be acceptable. The inspector held discus-

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sions with responsible licensee representatives and reviewed supporting documentation to verify that the corrective actions identified in the -

l- report have been completed. The license identified that the secondary-disconnect fingers were found to be shorter than required. The secon-

dary disconnect fingers are contacts on the circuit breaker which

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control use function of the breaker. The improper length could cause i poor contact which could cause the breaker to malfunction. Siemens-Allis(SA), the switchgear manufacturer, stated that a new supplier of fingers was unable to control dimensions with the required tolerance.

, SA has changed suppliers and is inspecting 100% of the fingers supplied to the sit The licensee replaced all 16 fingers on all safety l

breakers as documented on work request and authorization ABAY-1 and NCR 85-0391.

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6 (Closed) Item 400 CDR84-179 In-Core Flux Mapping System-System Interac-tions (10 CFR 50.55(e))

The final report was submitted on December 30, 1985. The ceport has been reviewed and determined to be acceptable. The inspector held discussions with responsible ifcense representativities and reviewed supporting documentation to verify that the corrective actions identi-fied in the report have been complete The non safety in-core flux mapping system is mounted above the in-core instrumentation tubing seal table. The licensee questioned the possi-bility of parts of the flux mapping system falling on the seal table during a seismic event. A design review identified that a design change was required to the movable portion of the flux mapping syste This change is documented by field design request AS-10316 and Design Change Notice 650-954. This work has been complete ,

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