ML20203B927

Insp Rept 50-400/86-46 on 860520-0620.Violation Noted: Failure to Follow Administrative Procedure AP-X-02 & Housekeeping Procedures Re Trash & Debris.Deviation Noted: Failure to Review Shift Notes

ML20203B927
Person / Time
Site:	Harris
Issue date:	07/08/1986
From:	Burris S, Fredrickson R, Humphrey P, Maxwell G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20203B896	List: ML20203B893 ML20203B903 ML20203B914 ML20203B927
References
50-400-86-46, NUDOCS 8607180320
Download: ML20203B927 (17)

See also: IR 05000400/1986046

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• UNITED STATES

, [kO Qfe o NUCLEAR REGULATORY COMMISSION

REGloN 11

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101 MARIETTA STREET, N.W.

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• r ATLANTA, GEORGI A 30323

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Report No.: 50-400/86-46 -

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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

Facility Name: Harris Unit 1

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Inspection Conducted: Mh20-June 20,1986

Inspectors: . - ~ 7!e!K

Date Signed

F. Maxwel 3'

W(Gf) S %tb 7/r/a

Date Signed

eRS9P. Burris i; i

fSTl\Lh~

k P.VG. Humphre'

7ls/p

Date Signed

Approved by:( i 7 b

Q PJ E. Fredrickson, Section Chief Date Signed

Division of Reactor Projects

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SUMMARY

Scope: This routine, announced inspection involved inspection in the areas of

Licensee Action on Previous Enforcement Matters and Inspector Follow-up Items;

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Plant Procedures; Safety Committee Activity; Comparison of As-Built Plant to FSAR

Description; Preoperational Test Program Implementation Verification; Testing of

Pipe Support and Restraint Systems; and Other Activities.

Results: One violation was identified " Housekeeping Procedures" paragraph 7.

i One deviation was identified " Failure to Review Shift Notes" paragraph 4. '

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8607180320 860709

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REPORT DETAILS-

1. Licensee Employees Contacted

J. M. 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

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

G. A. Myer, General Manager, Milestone Completion

M. Thompson, Jr. , Manager, Engineering Management '

D. L. Tibbitts, Director, Regulatory Compliance

B. Van Metre, Manager, Harris Plant Maintenance

C. C. Wagoner, Project General Manager, Construction

R. A. Watson, Vice President, Harris Nuclear Project-

J. L. Willis, Plant Genertl Manager, Operations

Other licensee employees contacted included construction craftsmen,

technicians, operators, mechanics, security force members, engineering

personnel and office personnel.

2. Exit Interview

The inspection scope and findings were summarized on June 24, 1986, with the

Plant General Manager, Operations. 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 violation

identified in this report has been discussed -in detail with the licensee.

The licensee provided no dissenting information at the exit meeting.

3. Licensee Action on Previous Enforcement Matters and Inspector Follow-up

Items (92701 and 92702)

a. (Closed) Violation 400/83-29-01, " Failure to Control Fastening

Material". The inspectors reviewed CP&L's corrective actions to the

problem of safety-related items which were found to not be verified

as "Q", and those fasteners which could not be confirmed .to be the

specified material type and grade. CP&L issued procedure AP-XII-04,

" Purchasing Bolting Materials", which provided a mechanism by which

the licensee's receipt inspection personnel could identi fy all

safety-related fasteners as to "Q" versus "Non-Q" material type and

grade, and provided a basis for accepting or rejecting these items.

Additionally, the licensee instituted a fastener review program which

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required all disciplines to perform an investigation for acceptability

of.all previously installed fasteners and corrective action, and if

necessary, correct and document any identified problems. The

inspectors reviewed all pertinent documentation and discussed these

findings with the original identifying NRC inspector. The originator

of this item concurred that the licensee has taken the proper

corrective action and satisfactorily resolved his concerns. This item

is closed.

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b. (Closed) Inspector Follow-up Item 400/84-24-05 " Certifications for

Plant General Manager". The inspectors reviewed the qualification and

training records for the Plant General Manager. As a result, the

inspectors determined that the Plant General Manager has been certified

at the Harris Plant simulator. This certification, along with previous

experience and training, provides sufficient proof that he satisfies

the requirements of ANS-3.1 draft copy, dated September 1979 revision,

Section 4.2.1. This item is closed.

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c. (Closed) Inspector Follow-up Item 400/85-16-12, TMI Action Item II.D.3

" Relief and Safety Valve Indication". This item was opened, and

the status was addressed, in IE Report 400/85-16. At that time,

installation of the hardware had not been completed for the

pressure-operated relief and safety valve indicators. The licensee

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informed the inspectors that work had been completed and that the item

is ready for inspection. The inspectors reviewed the FSAR, page 29 of

the TMI Appendix; Section 7.5.2.2 of the the Safety Evaluation Report;

and NUREG 0737,Section II.D.3. The inspectors then conducted a field

i inspection and verified the following:

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The primary system code safety relief valves (SRV) had limit

switches installed which provided safety grade position indication

that was displayed on the emergency response facility information

system CRT located on the main control board.

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The primary system code safety relief valves had resistance

temperature detectors (RTD) installed upstream of the SRVs as a

backup indication for valve seat leakage.

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Both methods of detection for the SRVs provided an alarm signal

input to an annunciator on the main control board.

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The power operated relief valves (PORV) had valve stem limit

switches installed which were powered from a high-reliability

power source with battery backup and provided position indication

at the control switch on the main control board.

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The PORVs also had an RTD installed downstream in a common header

as a backup to irdicate seat leakage. This method of detection

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was also an alarm signal input to an annunciator on the main

control board.

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All valve position devices were seismically and environmentally

qualified. ~

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Output from the valve position devices was provided to the safety

parameter display system (SPDS).

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Operator response associated with these displays was integrated

into procedure and was consistent with emergency operating

instructions.

Based on the review of the preceding areas, the inspectors consider

that all actions necessary to close this item are complete. This item

is closed.

d. (Closed) Inspector Follow up Item 400/85-16-13, TMI Action Item

II.E.1.2, " Auxiliary Feedwater System Initiation and Flow". The

subject item was identified and status provided in IE Report 400/85-16.

At that time the indicators and control circuits had not been

installed. The licensee informed the inspectors that work to close

this item had been completed. The inspectors reviewed the FSAR TMI

Appendix, page 31; FSAR Sections 7.2.2, 7.3.1, 7.3.2, 7.5, and 10.4.9;

Section 7.3.3.1 of the SER; and NUREG 0737,Section II.E.1.2. The

inspectors then conducted a review of applicable logic and flow

diagrams and determined that:

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The design provides for the automatic initiation of the AFWS.

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The automatic initiation signals and circuits are designed so that

a single failure will not result in the loss of AFWS function.

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Testability of the initiating signals and circuits were included

in the design.

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The initiating signals and circuits are powered from the emergency

buses.

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Manual capability to initiate the AFWS from the control room is

retained and is implemented so that a single failure in the manual

circuits will not result in the loss of system function.

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The ac motor-driven pumps and valves in the AFWS are included in

the automatic actuation (simultaneous and/or sequential) of the

loads onto the emergency buses,

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The automatic initiating signals and circuits are designed so that

their failure will not result in the. loss of manual capability to

' initiate the AFWS from the control room.

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Safety grade flow indication from one auxiliary feedwater flowrate

indicator and safety-grade level indication from one wide range

i steam generator level indicator for each steam generator is

provided.

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The inspectors then conducted a field inspection and verified that:

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Instrumentation as required above is installed and the displays in

, the control room are safety grade.

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Flow and level instrumentation provide input to SPDS which is

! available for display on demand.

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Operator response associated with these displays were integrated

into procedure and are consistent with emergency operating

instructions.

Based on the review of the preceding areas, the inspectors consider

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that all actions necessary to close this. item are complete. This item

j is closed.

e. (Closed) Unresolved Item 400/85-37-03 " Plant Organization Chart for

Operations". This item involved the identification and responsibili-

i ties of the Assistant Plant General Manager. The inspectors obtained

and reviewed CP&L's response to this item, which included changes to

l the Final Safety Analysis Report, Plant Administrative Procedures, and

proposed Technical Specifications, in order to verify that the

Assistant Plant General Manager's duties and responsibilities have been

clearly addressed and identified. This item is closed.

} f. (Closed) Inspector Follow-up Item 400/86-16-01 " Teflon Tape-in the RHR

l System". An inspection of the residual heat removal system (RHR) to

j compare the as-built plant to the FSAR description identified Teflon

j Tape on two vent plugs on flow transmitter FT-605A. The use of Teflon

i Tape is forbidden for in plant use at the Harris Plant, per Adminis-

trative Procedure AP-501. The following steps were taken by CP&L to

remove the tape and prohibit its use in the future on in plant systems:

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Surveillance Report 86-018-01 was issued by the Quality Assurance

Department to document the condition. Surveillance reports remain

j open and are carried on an open items listing until all conditions

have been satisfied.

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Walkdown inspections were performed by the QA Department to

identify any other in plant areas where Teflon was used. This

inspection revealed 13 additional areas. Work requests were

issued for its removal.

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A revision of Section 5.9 of AP-501 was scheduled to require that

all new equipment purchased for in plant use will be free of

Teflon Tape.

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A control program has been initiated to discover and remove Teflon

Tape from in plant systems.

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Teflon Tape was removed from the supply stock issue counter.

This item is closed.

g. (Closed) Inspector Follow-up Item 400/86-22-01 " Motor Driven Valve

Operators Procedure 1/2-9000-E-06". The inspectors reviewed the

licensee's corrective actions to resolve concerns identified in Region

II report 400/86-22. The inspectors obtained copies of the test

procedures and data sheets to verify that the nonapplicable references

have been removed and that the completed data sheets did not contain

any blank signature or data spaces. This item is closed.

h. (Closed) Violation 400/86-24-01 " Failure to Follow Maintenance

Procedural Requirements". The inspectors reviewed CP&L's corrective

steps taken, and action to preclude recurrence of this item. The

licensee repacked the identified valve under Work Request and

Authorization 86-ABDZ1 and returned it to service. The licensee

changed procedure MMM-012, Maintenance Work Control Procedure, to

provide more specific guidance for documenting the "as left" conditions

and any other known discrepancies. The maintenance manager held

discussions with his supervisors and foremen to clarify the need for

documenting equipment status, and the maintenance manager issued a

memorandum summarizing this problem and resolutions necessary to

correct all identified deficiencies. In addition, all supervisors and

foremen were required to review this item with their subordinates.

Start-up personnel also have been reminded of all applicable require-

ments. This item is closed,

i. (Closed) Violation 400/86-24-02 " Failure to Follow Clearance Procedure".

The inspectors reviewed the licensee's response and corrective actions

to a violation of Administrative Procedure AP-020, Clearance Procedure.

This review included interviews with start-up, operations and maintenance

personnel to verify the following:

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Working engineers were aware of reemphasized importance of

restoration of equipment or systems after a clearance is

cancelled;

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Personnel had reviewed Plant Incident Report 86-20 and Shift

Note OP-011-86, as required; l

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Personnel were knowledgeable in the area of clearance procedures;

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Activities working in confined spaces were authorized to be in

, those spaces.

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! The inspectors documented that the corrective actions as identified in

CP&L response letter H0-860304(0) were complete as stated for this

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violation. This item is closed.

j 4. Plant Procedures (424008)

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j An inspection was conducted to determine if the scope of management controls

involved with the plant procedure system is adequate to control operations I

within ANSI 18.7-1976. Technical specifications had not been issued at the

, time of the inspection. The inspection included verification of assignment

of responsibilities and adequacy of controls and implementation for issuing

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new and revised procedures, disposing of outdated procedures, controlling

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temporary changes, preparing and correcting logs, distributing procedures,

, preparing standing and special orders and providing for periodic review of '

i procedures. The conduct of operation procedures was inspected to insure

, incorperation of the following:

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Operators' authority for shutting down the reactor when necessary;

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Responsibility to determine cause and authority to restore operation

j after a scram or other unplanned power upset;

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Requirement to comply with Technical Specifications;

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Operator instructions to believe instrument indications until proven

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Standard of conduct for licensed operators;

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Assignment of supervisory personnel to on-call availability.

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i The inspection also included verification of the requirement to-perform a

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safety review (50.59) of new and revised procedures. A deviation from

commitments was identified in the implementation of shift notes. The

inspectors verified that administrative controls were established for the

! issuance of Shift Notes, implementing the requirements of ANSI N.18.7-1976,

i Section 5.2.4. The inspector reviewed OMM-009, Rev. 1, Shift Notes, which

implements ANSI N.18.7, Section 5.2.4. CP&L has assigned responsibilities

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and methods for issuance, distribution, review, and updating of shift notes.

The inspector, on May 25, 1986, also reviewed the implementation of OMM-009

through a detailed examination of the Shif t Note book in the control room.

j Several problems were identified:

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A "for information only" copy of OMM-009, Rev. O was in the front of

! the Shift Note book. Revision 1 was the current revision.

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Shift Note OP-16-86 required a monthly check of the ACP locker contents

with no mechanism to insure performance of the check.

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Several shift notes had no shift foreman initials.

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Shift Note OP-010-86, HHSI Flow Test and Cavity Seal Ring Test, had .two

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yellow " Post It Notes" attached to the note that read: (1) " Caution:

insure all cavity drains are closed before filling cavity", and (2)

" Prior to admitting flow through any valves in steps 2 and 6 insure

LSIP suction is lined up to RWST". The use of a stick-on note to

update the shif t note is contrary to 0MM-009, Section 5.3.7, which

requires that updates shall require cancellation of the previous note

and issuing a new note. This is a failure to follow procedure.

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Shift Note OP-006-86, Start-up Instructions for NSW, had steps 4 and 8

deleted and step 13 changed through a pen and ink change, an additional

example of an incorrect update of a shift note.

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OMM-009, Section 5.2, requires the operations supervisor to initiate

reviews of all active shift notes once per 30 days and to document the

review by initialing and dating the top page of each note. The shift

notes were not reviewed once per 30 days. No operations supervisor

review had been documented for shift notes since January 25, 1986.

The last three problems identified above are examples of failure to follow

procedure OMM-009, which is required by the FSAR-committed operations QA

program 90 days prior to fuel load. This is a deviation from the FSAR

commitment, " Failure to Review Shift Notes" 400/86-46-01.

Results of the other implementation audits are summarized below:

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Forty-three procedures in each of the service, administrative and

training libraries were compared to the master procedure in document

control. No discrepancies were found in the service library. The

administrative library had two procedures with six expired temporary

changes (#1522, 829,1178, 826, 827 and 856) still attached and one

procedure missing. The training library had two procedures with three

expired temporary changes (#858, 854 and 739). All these temporary

changes had expired at least three months earlier. All of the

procedure revisions were current.

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Eight procedures in the control room were verified to be the correct

revision and had changes incorporated correctly.

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One individual was interviewed to determine if he had been notified of

advanced changes issued to three procedures (LP-P-2001A, B and C) which

had been temporarily distributed to him when Revision 2 was the latest

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revision. He was unaware of the changes. Notification of those

possessing temporary controlled copies when a change is made to them is

required per procedure RMP-002, paragraph 7.3.2. The advance change

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was issued May 5, 1986. The inspectors made this observation on

May 22, 1986.

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Plant Emergency Procedure (PEP) Form Files were audited in the

administrative library, the technical support library and emergency

preparedness storage cabinet (the latter is not a controlled copy).

Form PEP-341-1-2, Manual Dose Projection Record Sheet, in procedure

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PEP-341 was later than the one in the administrative library. Form

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PEP-362-1-4, Isotope Release Worksheet, and Form PEP-302-1-2, Plant

Parameter Information Form, in the technical support library were later

than that contained in the associated procedures.

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The list of approved safety reviewers for procedure review was verified

to be updated when new people are authorized and deletions are made

1 when reviewers have not been requalified at the interval specified in

AP-014, Criteria for Qualified Safety Reviews. No discrepancies were

noted. '

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The list of temporary changes was audited to verify that they receive a

safety review and final approval within proposed technical specifica-

tion time frame, e.g. two weeks. This is incorporated into AP-07,

i Temporary and Advance Changes to Plant Procedures. Seven (#s 2970,

2830,2829,2824,2823,2964,2951) were found with times exceeding two

weeks. All seven were associated with the maintenance department. On

March 5, 1986, nonconformance report NCR OP-86-0003 was issued against

maintenance for a similar finding. The NCR was closed on March 25,

1986 with engineering resolution in progress to determine correct

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action. The above temporary changes were issued on or after April 15,

1986. The inspection was conducted on May 22, 1986. The reviews were

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8, 5, 5, 3, 5, 17 and 23 days overdue. At the end of this reporting

period, the licensee informed the inspectors that corrective action has

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been taken and they are in full compliance with this procedural

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requirement.

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Twenty-five final temporary changes and advanced changes were reviewed

to verify safety reviews were performed and filed in document control.

No discrepancies were noted.

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Document control reviews were verified to be performed as specified in

RMP-002, Document Distribution and Control. The reviews verify

availability of latest revision and correct. incorporation of changes.

The inspectors reviewed results of reviews conducted since October

i 1985. In November 1985 the training library was found to have a high

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discrepancy rate. Document control personnel provided special training

to the affected personnel to prevent future problems.

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Conclusions

associated with the above procedure controls implementation audits 'j

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! The above items indicate an occasional oversight in controlling procedures.

The procedure reviews conducted by the licensee appear to be effective such

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that a major breakdown in controls would be detected in a timely manner, if

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reviews are conducted at the frequency performed in the recent past. This

frequency .is not defined in a procedure. The expired temporary changes

should not cause a problem if the user reads the change carefully since the

expiration condition or date is marked on the change. Two areas of concern

need to be addressed by the licensee. There are a large number of

( procedures currently signed-out on controlled temporary distribution. The

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inspectors estimate that 10 to 20 percent of all procedures may be involved.

The inspectors consider the method currently in effect for notifying users

of a change is not capable of being timely or reliable. For example, there

is no mechanism for document control to know if the user actually is

notified of the change. Timeliness is a problem in that, for the user to be

i notified, the change must be sent to document control, then document control

sends the change to the controlled libraries and then the controlled library

which issued the temporary distrfoution copy must identify the user and mail

him a notification form. The primary means to insure the latest revision of

, a procedure is used appears to be the quirement that the user verify that

j he has the most up-to-date copy. T s is accomplished by checking the

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computer data base. Performance of this is not required to be documented on

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the procedure.

I Reduction of the number of procedures on temporary distribution may be

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, accomplished when the licensee implements " working" file copies as described

later in this report. The licensee committed to review the use of, and

timeliness of controlled temporary distributed procedures. The other

i concern involves the practice of the PEP procedure writers revising a form

without revising its associated procedure. By doing this, the ability to

< verify the availability of the latest revision in the normal method is not

possible, i.e. the computer data base has only the procedure listed in it,

not the form. Also, this results in document control not being properly

notified, such that copies can be properly distributed. The licensee

committed to issue the currently ~ changed forms and future changed forms as

. advanced changes. Conclusions and observations associated with procedure

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program inspection are listed below:

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No provisions for establishing " working" files of frequently used

procedures currently exist. The concept has been approved by

management but not yet implemented.

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A computerized procedure distribution list is being developed to

replace the informal manual system.

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A computer system for scheduling and tracking compliance with the

two year procedure review requirement per ANSI 18.7 is being developed.

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Prior to fuel load the licensee intends to have all procedures reviewed

or revised within the last two years.

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A procedure cross reference to ANSI 18.7 requirements is being

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Field walkdown of procedures are required per Plant Special Order

85-10, dated March 12, 1986. These are in progress. The licensee

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intends to have these walkdowns performed prior to fuel load. However,

this is a one-time requirement. Procedures do not require or recommend

new procedures or major revisions to procedures to be field verified,

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simulated or walked down. The licensee does not believe such guidance

is necessary.

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FSAR commitment to procedure cross reference has not been updated since

Amendment 19. The current amendment is 26. AP-006, Procedure and

Approval, contains a note which states the preparer (of a revision

' request) must consider other sources of information such as...FSAR

Commitment List". The licensee committed to clarify its intention with

regard to maintaining this document as a viable part of its procedure

system.

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Procedures do not address a method for correcting an error in an

individual copy when one is discovered. The licensee is revising

RMP-002 to incorporate this item.

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AP-007, Temporary and Advanced Changes to Plant Procedures, defines a

procedure change as "A change (either temporary or advance) to a

procedure which does not change the purpose of the procedure". The

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proposed technical specifications as well as ANSI 18.7-1976, paragraph

5.2.2 address temporary changes as not changing the intent of an

approved procedure. The licensee committed to change AP-007 to reflect

the wording " intent" instead of " purpose".

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AP-007 provides examples of items which are not to be covered by a

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change. Several of these examples allow the change to be made provided

the change is " supported by approved documentation". Though examples

are provided of that the phrase means, it also includes "etc.". The

inspector believes that the phrase needs to be better defined. The

j licensee is considering a more exacting definition.

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AP-007 does not attempt to distinguish between what items can receive a

, temporary change and which can receive an advance change. Review of

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some temporary changes (TC) revealed that (1) TC 1174 (February 5,

i 1986) changed the setpoint on the auxiliary feedwater punp speed

i controller while in standby mode, 100 percent changed to 20 percent;

(2) TC 1527 (February 13, 1986) added provisions for adding resin to

the boron thermal regeneration system; (3) TC 1183 (January 6,1986)

, deleted independent verification from procedure OP-108, Boron Thermal  ;

j Regeneration System; and (4) TC 89 (November 8,1984, still in effect) l

l provided steps for handling incorrect materials in PMC-002, Material

i Control Receiving. Items 1-4 are outside the scope of what is normally

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allowed for non-intent changes. The licensee committed to provide

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additional guidance of proper use of temporary changes and. provide

j training to appropriate personnel.

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The above items which contain the phrase "the licensee committed to" were

acknowledged by the licensee and resolution of these will be tracked by the

licensee's " CAP" program. These items will be reviewed in a future

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inspection.

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The inspectors performed a review of the electrical lineup of OP-155, Diesel

Generator Emergency Power System. Revision 1 was issued on December 19,  ;

1985 and includes three subsequent temporary changes, 1210 issued January 1,

4 1986, 1214 issued January 3, 1986, and 1524 issued January 30, 1986. Power

panel DP 1A11 circuit #8 was not included in the lineup for diesel generator ,

1A-SA. The circuit powers the local annunciator panel associated with the

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i engine. The inspector also observed that some apparently obvious items such

as starting air compressors being numbered differently from that in the

field, 480V breakers listed as part of 125V power panels and sign offs with

i verification were required for steps that required no action had not been

identified, even though the procedure had already been performed to support

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start up testing. The inspectors discussed this apparent lack of attention,

i by operations personnel, with CP&L management.

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Except as noted, no violations or deviations were identified.

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j 5. Safety Committee Activity (40301B)

The inspectors evaluated the documented program for CP&L's off-site nuclear

review group. The group has been designated as the CP&L Corporate Nuclear

Safety and Research Department (CNS). The department is broken down further

i to include an "On-Site Nuclear Safety sub-unit-(ONS) and an Off-Site Nuclear

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Safety Review sub-unit (NSR). The ONS units are located at each of the CP&L

f nuclear sites to evaluate and review plant activities first hand. Each ONS

unit has a director who reports to the manager of CNS; the NSR sub-unit is

i also headed by a director reporting to the manager of CNS.

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l The CP&L Corporate Nuclear Safety Instructions and Procedures,. CNSI-1 and

j CNSP-1, define the off-site unit's responsibility for independent review and

feedback of company internal events. The inspectors evaluated procedure

CNSP-4 and found it to sufficiently address the following:

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The independence of the group members;

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The group does not use the committee concept, thus eliminating the need

for designating alternate members;

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The requirements for maintaining and distributing records of the group

activities;

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The lines of communications and interface between the on-site and the

off-site units; ,

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The provisions for follow-up action to resolve identified deficiencies. 1

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i The inspectors evaluated procedure CNSP-3. The procedure was found to

i contain requirements to assure that those subjects identified in Section 6

i

of the Technical Specifications will be reviewed and accessed by the

off-site review group. -

! The inspectors reviewed the documented results of six recent instances where

{ the ONS and the NSR personnel conducted evaluations of site events. The

'

evaluations were made to determine the significance of the events,

corrective actions needed, and recommendations for corrective actions to

prevent recurrence,

j No violations or deviations were identified.

1

1 6. Comparison of As-Built Plent to FSAR Description (37301)

a. The inspectors selected 14 safety-related systems and evaluated the  !

up-to-date status of drawings and documentation utilized in the control.

!

room for each. The systems selected were those that had previously

been walked down by the inspectors to compare the ' ' a s-bu i l t system

i status to the latest drawing revision.

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t The latest revision and Field Change Notices were reviewed for the

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specified control room drawings and applicable Field Change Requests

and compared to the latest revision and Field Changes listed in the i

. drawing control log and the the document control center. This review

j consisted of 52 drawings and applicable Field Change Requests

! associated with these systems. Only nine of the 52 drawings had open >

l FCRs. Three of the nine drawings had two open FCRs on each and the

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remaining six had only one open FCR.

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i b. During this inspection period the inspectors, accompanied by the

i applicable start-up engineer, performed a walkdown of the main

j feedwater system on June 5, 1986. The purpose of the walkdown was to

! evaluate system completion and comparison to system flow diagram

, drawing CP&L 2165-S-0544. The following items were evaluated:

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Proper location, configuration, identification, and damage, if

any;

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Installation in accordance with approved drawings, procedures, and

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Attachments properly installed;

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Fastening aterial type, identification, and torquing;

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Interferences identified; ,

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Inspection personnel qualifications;

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Inspection results and nonconformances properly documented.

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Results of this inspection ' include the identification of several minor

discrepancies which are being tracked and corrected by the licensee.

The inspectors will continue to monitor the licensee's completion of

these activities during future inspections. No violations or

deviations were identified.

7. Preoperational Test Piogram Implementation Verification (71302)

a. The inspectors conducted routine tours of the facility to make an

independent assessment of equipment conditions, plant conditions,

security, and adherence to regulatory requirements. The tours included

a general observation of plant areas to determine if fire hazards

existed; observation of activities in progress (e.g., maintenance,

preoperational testing, etc.) to determine if they were being conducted

in accordance with approved procedures; and observation of activities

which could damage installed equipment or instrumentation. The tours

also included evaluation of system cleanness controls and a review of

logs maintained by test groups to identify problems that may be

appropriate for additional follow-up.

b. During the week of May 26, 1986 the inspectors witnessed the in process

heat treatment of the two inside rows of steam generator tubes in an

effort to relieve potential stress points created when forning the "U"

bends. The inspectors reviewed the process procedures ar.d the data

collected.

Westinghouse representatives made a presentation to the inspectors

during the previous week on the heat treatment proposed for the

generator tubes in rows one and two of each of the three steam

generators. The treatment was believed to be necessary for only the

first two rows, resulting from their radius bends .being greater and

yielding a potential stress point on the inside of the bend. At this

stress point, an outward indication had been identified in other "0"

type steam generator tubes. This indication is located in the

downstream portion of the bend and was referred to as "the Blairsville

bump".

The Harris facility was the first of a series of plants to implement

this stress relieving process for the 228 tubes in each of the three

generators. Data for the process was obtained from laboratory

experience.

The process involved inserting electrical heater rods through the tubes

and heating to a temperature of 1340 degrees F for approximately ten

minutes with a specified tolerance of plus or minus 100 degrees F. All

work was performed by the Westinghouse Company and to the Westinghouse

Quality Assurance Program. This stress relieving effort was completed

on May 29, 1986.

Eddy current testing was performed by CP&L to evaluate the effect of

the heat treatment process on the subject tubes. Test results did show

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some difference between the before and after heat treatment process.

4 Evaluation of these results is in progress.

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i c. The inspectors performed a follow-up on the "B" diesel engine trip

i problems encountered during the one hour test run at full load capacity

i associated with preoperational test 1-5095-P02. The engine trips

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resulted from a signal received from the vibration sensor mounted on

the left side of the turbo charger and occurred within a 20 minute time

period after applying the 6.5 megawatt load to the unit.

The cause was initially diagnosed as being a bad sensor. The sensor

I was replaced and the problem continued. The problem was again

evaluated in more detail and the following areas were identified:

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The replacement vibration switch was determined to be defective.

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The turbo charger was not properly aligned with the air inlet

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piping.

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Some rust was found on the mounting surface at the point where the

turbo charger fastens to the engine, and the engine mating surface

i did not meet the required flatness.

The three areas identified above were corrected and the one hour run

with 6.5 MW power load was completed without further interruptions on

June 7, 1986. Preoperational test 1-5095-P02 further required that the

engine be started 35 consecutive times without failure and run at

greater than 50 percent load for a period of one hour each. This

section of the test was successfully completed on June 10, 1986. An

uninterrupted 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> endurance run at full load must be performed per

i preoperational test 1-5095-P04, prior to meeting the full compliment of

the testing requirement.

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d. During a routine review of selected Nonconformance Reports (NCRs)

generated by the on-site Operations Quality Assurance organization, the

j inspectors obtained copies of these documents and reviewed them to

insure that:

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The NCRs were generated in accordance with the approved procedure

(QAP-104);

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Required responses from the NCR subject organization were received

! in the required time constraints;

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QA personnel reviewed and signed the document upon completion of -l

all acceptable corrective actions; l

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QA personnel were trained and knowledgeable in the use procedure

j QAP-104,

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This review identified several minor concerns which the licensee

immediately corrected to the satisfaction of the inspectors.

j Additionally, the inspectors questioned QA management as to the status

j of the Operations Quality Assurance Procedure (0QA-104) which will

replace QAP-104.in the near future. QA management agreed to review

OQA-104 to insure it was written in a reliable and usable fashion. The

inspectors will evaluate the new 0QA-104 during future inspections.

i ,

] e. During this inspection period the inspectors conducted tours of.the

! fuel handling building to observe work in progress. The inspectors

witnessed operations personnel, operations quality control, operations

j quality assurance, technical support, and fuel vendor personnel during

the performance of fuel movement. This inspection was performed to

j verify that:

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An approved procedure, used for receipt inspection, fuel movement

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and fuel storage, was available and in use;

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A qualified operator was in control of all fuel movement;

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An approved load path was used for all fuel movement;

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Changes to the approved procedure were documented and all

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necessary approvals were obtained prior to implementation of the

new procedure;

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Building security was implemented as required by established

i procedures;

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Health physics personnel controlled access to and from all

identified radiation control areas, in accordance with established

procedures.

The inspectors did not identify any discrepancies which had not been

j identified and documented previously by the licensee. The inspectors

l will continue their inspection effort in this area in future report

j periods.

f. During tours of the control room, reactor auxiliary building, turbine

building, diesel generator building, fuel handling building and other

selected site areas, the inspectors identified several problem areas

j with respect to general plant housekeeping. These areas were identi-

i fled as level IV construction control areas and areas under control of

j the operations group. This inspection identified the following

j discrepancies: *

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A soft drink can was discarded in the spent fuel pool (level IV);

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Main control board back panels were littered with cigarette butts,

paper, peanut shells, and miscellaneous work debris, i.e. tape,

plastic wrappers, and tags. -

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Rooms 387A and 384 (level IV) contained' numerous cigarette butts,

paper trash, and miscellaneous work debris;

- Process instrumentation cabinets contained foreign debris in the

bottom of the observed open cabinets, such as nuts, bolts and

plastic tie wraps.

Administrative Procedure AP-X-02, Project Housekeeping, requires that

personnel restrict activities which would create hazardous conditions

for material and equipment protection or for health and fire hazards.

Contrary to this requirements, the inspectors have identified numerous

discrepancies which are identified as a violation, " Housekeeping

Procedures," 400/86-46-02.

Except as noted, no violations or deviations were identified.

8. Testing of Pipe Support and Restraint Systems (703708)

The inspectors toured areas of the reactor auxiliary and containment

buildings. Seven struts, eight spring can supports and eight mechanical

snubbers were observed. Visual examinations weis conducted to check for

deterioration and physical damage of the mechanical snubbers. Visual

examinations were also conducted to check proper installation of base

support plates, fasteners, locknuts, brackets and clamps for fixed pipe

supports.

No violations or deviations were identified.

9. Other Activities (943008)

On May 22, 1986, the Region II Acting Director for the Division of Reactor

Projects and the Harris Site Region II Reactor Projects Section Chief

visited the Harris Plant. Their agenda included a briefing by CP&L

concerning the status of the project overview, construction, start-up

(status of systems, buildings, preoperational testing and procedures), and

readiness for plant operations (staffing, training, and procedures).

Following the briefing a tour was made throughout the plant site, concluded

by a meeting with the resident inspectors.