ML18010A619
| ML18010A619 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/10/1992 |
| From: | Christensen H, Shannon M, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18010A617 | List: |
| References | |
| 50-400-92-04, 50-400-92-4, NUDOCS 9205050111 | |
| Download: ML18010A619 (25) | |
See also: IR 05000400/1992004
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report No.:
50-400/92-04
Licensee:
Carolina
Power
and Light Company
P. 0.
Box 1551
Raleigh,
NC 27602
Docket No.:
50-400
Facility Name:
Harris
1
Inspection
Conducted:
February
15 - March 20,
1992
Inspectors:
edrow, Senior
esi ent
nspector
n
.
Shannon
Resident
Inspector
Approved by:
H. Christensen,
Section Chief
Division of Reactor Projects
License
No.:
't lo eW
a
e
igne
la
Date Signed
g /u y~.
ate Signed
Scope:
SUMMARY
This routine inspection
was
conducted
by two resident
inspectors
in the areas
of plant
operations,
radiological
controls,
security,
fire protection,
surveillance
observation,
maintenance
observation,
safety
system
walkdown,
review of
PNSC activities,
review of spent
fuel handling activities,
design
changes
and modifications
and
review of licensee
event reports.
Numerous
facility tours
were conducted
and facility operations
observed.
Some of these
tours
and observations
were conducted
on backshifts.
Results:
,t
Two violations
were identified:
Failure to properly identify and correct
deficiencies
as
requi red
by
10 CFR 50, Appendix B, Criterion XVI, paragraphs
2.a.(1)
and 9.b;
Failure to use
a qualified person for the
performance
of
independent verifications,
paragraph
3.a.
Housekeeping
improvement
was
needed
in several
plant areas,
paragraph
2.b.(3).
ALARA planning for the outage
work and Reactor
Coolant
Pump
(RCP) oil addition
was considered
to be
a strength,
paragraph
2.b.(4).
The
RAB area
radiation levels
have
increased
significantly due to Residual
Heat
Removal
(RHR) shutdown cooling operation,
paragraph 2.b.(4).
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Detailed planning
and
use of mockups for maintenance activities
was considered
to be
a strength,
paragraph
4.a.
Personnel
training regarding
the
use of freeze
plugs
was considered
thorough,
paragraph
4.c.
Licensee
management
has reevaluated
spent fuel crud cleanup efforts and decided
to leave the crud
on the bottom of the pools,
paragraph
7.
The conservative
decision to shutdown
the plant
and repair boric acid leakage
reflected
management's
support
for the control
of boric acid corrosion,
paragraph
8.
REPORT
DETAILS
Persons
Contacted
Licensee
Empl oyees
J. Collins, Manager,
Operations
- C. Gibson,
Manager,
Programs
and Procedures
- C. Hinnant,
General
Manager,
Harris Plant
- B. Meyer, Manager,
Environmental
and Radiation Monitoring
T. Morton, Manager,
Maintenance
- J. Hevill, Manager,
Technical
Support
C. Olexi k, Manager,
Regulatory Compliance
A. Powell, Manager, Harris Training Unit
R. Richey, Vice President,
Harris Nuclear Project
- H. Smith, Manager,
Radwaste
Operation
E. Willett, Manager,
Outages
and Modifications
- W. Wilson, Manager,
Spent Nuclear
Fuel
Other
licensee
employees
contacted
included
office,
operations,
engineering,
maintenance,
chemistry/radiation
and corporate
personnel.
- Attended exit interview
NRC Personnel
- D. Roberts,
Resident
Inspector,
Intern
and initialisms
used
throughout this report are listed in the
last paragraph.
Review of Plant Operations
(71707)
The plant
began this inspection
period in power operation
(Mode 1).
On
March
7
a power reduction
was
commenced
and oil was
added to the
A and
8
reactor
coolant
pumps.
The unit was then
taken off-line at 4: 18 a.m. to
perform repairs
to valve
AD bypass manifold isolation valve (see
paragraph
8 for more details
on the plant outage).
The
271
days of
continuous
plant operation
on line set
a
new plant record.
Following
completion of valve repairs,
a plant heatup
was
commenced
and the plant
was
taken to hot standby
(Node 3) at 7:38 a.m.
on March 11.
A reactor
startup
was
performed
on March
12
and the reactor
was
taken critical at
12:20
p.m.
The plant
was returned
to power operation
at 7:24
p.m.
on
March
12 where it remained for the duration of this inspection period.
a.
Shift Logs
and Facility Records
The inspector
reviewed
records
and
discussed
various entries
with
operations
personnel
to verify compliance
with the
Technical
Specifications
(TS)
and the licensee's
administrative
procedures.
The following records
were reviewed:
Shift Supervisor's
Log; Control
Operator's
Log;
Outage
Shift Manager's
Log;
Night Order
Book;
Equipment
Record;
Active Clearance
Log;
Jumper
and Wire
Removal
Log; Temporary Modification Log; Chemistry Daily Reports;
Shift Turnover Checklist;
and selected
Radwaste
Logs.
In addition,
the inspector
independently verified clearance
order tagouts.
The inspectors
found the
logs to
be readable,
well organized,
and
generally provided sufficient information on plant status
and events.
Clearance
tagouts
were found to be properly implemented.
(I)
During control
room observations
on
February
20,
1992,
the
inspectors
noticed that the control
room
HVAC system
was aligned
for emergency
recirculation.
This situation
occurred
as
a
result
of
a control
room isolation
signal
from
a failed
radiation monitor.
The inspectors
noticed,
however, that alarms
were lit on
the control
board
indicating that
the required
positive pressure
in the control
room was not being maintained
by this system.
requires
a 1/8 inch water gauge of
positive
pressure.
This matter
was
reported
to operating
personnel
who indicated that efforts were currently in progress
to investigate
the cause for the inadequate
positive pressure.
The following day the inspectors
were informed of the results of
the
investigation.
An
access
door
to
the
ventilation
recirculation
fan unit
R-2B
was
found partially
open
which
allowed
enough air leakage
from the unit to prevent
adequate
pressurization
of the control
room.
The inspectors
were further
informed that it was
a routine practice for auxiliary operators
to open
these
access
doors during rounds to check the condition
inside
the ventilation unit.
Apparently
the
door
was
not
properly closed following the last inspection.
The inspectors
determined
that
no control
room log entries
or
ACRs
had
been
generated.
Procedure
PLP-002,
Corrective
Action
Program,
section
5.2, requires
an
ACR or other sub-program
document
be
initiated for identified deficiencies.
The inspector considered
the
documentation
of
the
problem
to
be
inadequate
for
determining
appropriate
operability
and potential
corrective
actions.
Upon notification of this finding, licensee
personnel
initiated
an
ACR to document
the ventilation problem.
On March
2 the door for control
room ventilation unit R-2A was also found
to be inadequately
shut.
The door was resecured
and
a log entry
made in the shift foreman's
log.
In
NRC Inspection
Report 50-400/92-02,
the failure of operators
to properly identify deficiencies
for appropriate
corrective
action
was identified and
a non-cited violation
(NCV 400/92-02-
01)
was
issued.
The occurrence
of the inadequate
operation of
the control
room ventilation
system deficiency indicates
that
additional
licensee
management
attention is needed
in this area.
The fai lure to properly document
the deficiency in the control
Ci
room
emergency
ventilation
system
is
contrary
to
the
requirements
of
Appendix
B, Criterion
XVI and is
considered
to be
a violation.
Violation (400/92-04-01):
Failure to properly identify and
correct
deficiencies
as
required
by
Appendix
B,
Criterion XVI.
b.
Facility Tours
and Observations
Throughout
the inspection
period, facility tours
were conducted
to
observe
operations,
surveillance,
and
maintenance
activities
in
progress.
Some
of
these
observations
were
conducted
during
backshifts.
Also, during this inspection period,
licensee
meetings
were attended
by the inspectors
to observe
planning
and
management
activities.
The facility tours
and
observations
encompassed
the
following areas:
security perimeter fence;
control
room;
emergency
diesel
generator
building;
reactor
auxiliary building; reactor
containment
building; waste
processing
building; turbine building;
fuel
handling building;
emergency
service
water building; battery
rooms; electrical
switchgear
rooms;
and the technical
support center.
During these tours,
the following observations
were made:
( 1)
Monitoring Instrumentation
- Equipment operating
status,
area
atmospheric
and liquid radiation monitors, electrical
system
lineup,
reactor
operating
parameters,
and auxiliary equipment
operating
parameters
were
observed
to verify that indicated
parameters
were
in accordance
with the
TS for the current
operational
mode.
(2)
Shift Staffing - The inspectors
verified that operating shift
staffing was in accordance
with TS requirements
and that control
room
operations
were
being
conducted
in
an
orderly
and
professional
manner.
In addition,
the inspector
observed shift
turnovers
on various occasions
to verify the continuity of plant
status,
operational
problems,
and
other
pertinent
plant
information during these
turnovers.
(3)
Plant
Housekeeping
Conditions
-
Storage
of material
and
components,
and
cleanliness
conditions
of various
areas
throughout
the facility were
observed
to determine
whether
safety and/or fire hazards
existed.
The inspectors
found plant housekeeping
and
component material
condition to
be satisfactory.
However,
the inspectors
noted
that
cleanliness
in certain
plant
areas
had
deteriorated.
Specifically,
the charging/safety
injection
pumps
continuously
exhibit oil leakage
even after repeated
maintenance.
Two motor
operated
valves
and
also exhibited oil leakage
from the
valve actuator.
Fittings
on
two sodium hydroxide
addition tank level transmitters
(LT-1CT-7150A and LT-1CT-7166B)
also
showed
signs of leakage.
The containment
spray
pump
and
(4)
pump
rooms
have
ground water intrusion problems
and water
has
been
observed
to collect at
low points
on
the floor.
Although these
problems
were identified by licensee
personnel,
and
appropriate
work tickets
were written to correct
these
problems,
corrective maintenance
has not yet been performed.
Radiological
Protection
Program - Radiation protection control
activities
were
observed
routinely to verify that
these
activities
were in conformance
with the facility policies
and
procedures,
and in compliance with regulatory requirements.
The
inspectors
also
reviewed
selected
radiation
work permits
to
verify that controls were adequate.
The inspector
attended
the pre-job
ALARA briefing for the
A and
B reactor
coolant
pump motor oil addition job and reviewed the
and
previous
radiation
surveys
for the
areas
inside the
containment
building where the work was to be performed.
This
was
the
second
time
a containment
entry
had to be
made to add
oil to
pump.
Previously in October
1991,
an
entry was
made to add oil to the "B" reactor coolant
pump motor.
Again licensee
management
utilized mockup training
on
a spare
motor stored in the spare parts
warehouse.
Lessons
learned
from
the previous
entry were utilized to refine the techniques
for
the
current oil addition
plan.
These
efforts
were
very
successful
in limiting personnel
exposure
received
by plant
personnel.
P
During the forced
outage,
the
licensee
faced
a challenge
in
keeping radiation
exposure
to
a minimum while repairing valves
and
These
valves
were located
near
the
"C"
reactor
coolant
loop where
the radiation
exposure
rates
were
high.
However,
through
a
combination
of effective pre-job
planning, optimization of worker stay-time,
and coordination of
work efforts
between different organizations,
the licensee
kept
exposure
levels to
a minimum.
The biggest contributor to the
reduced
exposure
levels
was the pre-job planning which included
the
use of lessons
learned
from a similar outage in May 1990.
The licensee
also
made
use of a videotape of the work area which
allowed
the licensee
to plan the job without having to make
repeated
entries
into the
hazardous
area.
This effective
use
of ALARA planning
was considered
a strength.
The plant
was
faced with another radiological
challenge
as
a
result of operations
during the outage.
Initially, the licensee
planned
to repair valves
and
1RC-953 while in Mode 5.
based
on this the licensee
planned
a chemical
cleaning
process
designed
to loosen corrosion
products
in the
RCS.
This process
would normally be followed by
a flushing process
(while in Node
5) to remove these
products
from the primary system.
During the
outage,
licensee
management
decided
that the valves
could
be
repaired while in Node 4.
Since the flushing could not occur in
Mode 4, the
RHR system
(while in shutdown cooling) retained
a
significant amount of the highly radioactive corrosion products.
As
a
result,
radioactivity
in
the
system
increased
significantly when corrosion
products settled
out in the system
following its return to a normal
standby status.
This condition
presents
a
new challenge
to the plant because
several
areas
of
the
RAB have
been
upgraded
to high radiation
areas.
The
licensee
took
steps
to conspicuously
identify/post affected
areas.
The licensee
has
no definite
plans
to
reduce
the
radioactivity in the
RHR system
before
the fall
1992 outage.
The
inspectors
will continue
to
monitor
the
licensee's
activities in this area.
(5)
Security Control -
The performance
of various shifts of the
security force was
observed
in the conduct of daily activities
which included:
protected
and vital
area
access
controls;
searching
of personnel,
packages,
and vehicles;
badge
issuance
and retrieval; escorting of visitors; patrols;
and compensatory
posts.
In addition,
the inspector
observed
the operational
status
of closed circuit television monitors,
the Intrusion
Detection
system
in the central
and
secondary
alarm stations,
protected
area
lighting,
protected
and vital
area
barrier
integrity,
and
the
security
organization
interface
with
operations
and maintenance.
(6)
Fire Protection
- Fire protection activities,
staffing
and
equipment
were observed
to verify that fire brigade staffing was
appropriate
and
that fire alarms,
extinguishing
equipment,
actuating
controls,
fire
fighting
equipment,
emergency
equipment,
and fire barriers
were operable.
/
The licensee's
adherence
to radiological controls, security controls,
fire protection requirements,
and
TS requirements
in these
areas
were
satisfactory.
c.
Review of Nonconformance
Reports
Adverse
Condition
Reports
(ACRs)
were
reviewed
to verify the
following:
TS were complied with, corrective actions
as identified
in the
reports
were
accomplished
or being
pursued for completion,
generic
items were identified and reported,
and
items were reported
as required
by the TS.
No violations or deviations
were identified.
3.
Surveillance
Observation
(61726)
Surveillance
tests
were observed
to verify that approved
procedures
were
being
used;
qualified personnel
were
conducting
the tests;
tests
were
adequate
to verify equipment
operability;
calibrated
equipment
was
utilized; and
TS requirements
were followed.
The following tests
were observed
and/or data reviewed:
OST-1506
Reactor Coolant System Isolation Valve Leak Test
Flow Loop
1 Operational
Test
NST-I0145 Steam Generator
A Narrow Range
Level Operational
Test
NST-I0146 Steam Generator
B Harrow Range Level'Loop Operational
Test
EPT-159
EPT-183
ASNE Section XI, Article IWB-5000 102 Percent Hydrostatic
Test
SI Alternate Niniflow Relief Valve Relief Pressure
Test
EPT-184
SI Alternate Miniflow Relief Valve Relief Pressure
Test
In general,
the
performance
of these
procedures
was
found to
be
satisfactory
with proper
use of test
equipment,
necessary
communications
established,
proper
pre-test
briefings
performed,
and
knowledgeable
personnel
performed the tasks.
a ~
The inspector
observed
the
system restoration
and verification for
the
charging
alternate
miniflow relief valve test
performed
in
accordance
with section
7.2 of procedures
EPT-183
and
EPT-184.
This
section
verified that
several
system
drain
valves
and
test
connections
(ICS-745,
and
were returned to
the
normal
system lineup.
The initial positioning of these
valves
was
performed
by plant
operating
personnel.
The
independent
verification of valve position
was
performed
by the
system test
engineer.
The inspector
also
observed
that
the
valves
had
been
positioned to the proper positions.
Since
system
engineers
were not routinely utilized for independent
verification functions, the inspector questioned
the test engineer to
ascertain
his qualifications.
He stated
that it was
a
common
practice for system
engineers
to perform this task
and that
he
had
received
appropriate
training.
Licensee
management
stated
that
although
system
engineers
receive
some training,
they
were
not
qualified to perform independent verification of components
returned
to service
but were allowed to check valve positions inside the test
boundaries
during
the
test.
In contrast,
licensee
operating
personnel
receive
specialized
training in various
techniques
of
checking
valve
positions
and
the
special
requirements
regarding
independent
verification.
The licensee
considered
the
performance
of
independent
verification
by
the
system
engineer
to
be
inappropriate.
The
licensee's
administrative
controls
regarding
performance
of
independent
verifications
are
specified
in
procedure
PLP-702,
Independent Verification.
Section 5.3.3 of this procedure lists the
guidelines
to be applied in determining which individuals may perform
independent
verifications.
These
guidelines
are
very general
in
nature
and
simply require
that
only qualified
personnel,
as
designated
by their
foreman,
be
allowed to perform
independent
verification.
The utilization of a test engineer for the performance
of the independent verifications in section 7.2 of procedures
EPT-183
and
EPT-184 is contrary to the requirements
of procedure
PLP-702
and
is considered
to be
a violation of TS 6.8. l.a.
Violation (400/92-04-02):
Failure to use
a qualified person for the
performance of independent verifications.
4.
Maintenance
Observation
(62703)
The
inspector
observed/reviewed
maintenance
activities to verify that
correct
equipment
clearances
were
in effect;
work requests
and fire
prevention
work permits,
as
required,
were
issued
and
being followed;
quality control
personnel
were available for inspection activities
as
required;
and,
TS requirements
were being followed.
Maintenance
was observed
and work packages
were reviewed for the following
maintenance
(WR/JO) activities:
Disable
the
"B" digital
rod position indication cabinet
detector
encoder
card for control
rod
H-14 in accordance
with temporary
modification PCR-6264,
DRPI
Rod H-14 Half Accuracy.
Troubleshoot
failure of electrical
distribution
breaker
1A-3 to
properly close.
Addition of oil to the "A" and "B" reactor coolant
pump motors.
Replace
regulator
on air operated auxiliary feedwater
valve
in
accordance
with procedure
MPT-I0002,
Ralph
A. Hiller Model
12SA-A029 Valve Actuator,
and post-maintenance
testing in accordance
with procedure
OST-1077, Auxiliary Feedwater
Valves Operability Test
quarterly Interval.
Replace
"C" phase
main transformer oil coolant
pump.
Replace
rotating
element
for the
"A" main
pump
in
accordance
with procedure
CN-N0132,
Main
Feed
Pump
Disassembly
Inspection
and Reassembly.
Rebuild hydraulic operator for main steam
power operated relief valve
1NS-58 in accordance
with procedures
CM-M0186, Paul
Monroe Main Steam
Power Operated
Relief Valve Operator Fill and
Bleed Procedure,.
and
CM-M0188,
Main
Steam
Power
Operated
Relief
Valve
Operator
Disassembly,
Maintenance
and Reassembly.
In
general,
the
ma intenance
obser ved
was
performed
sati s factory.
Appropriate
procedures
were utilized
and
proper return to service
of
affected
components
was independently verified by the craft.
a.
The inspector
attended
the pre-job briefing for the main transformer
work.
This work was critical because it was performed with the plant
on-line
and with the transformer
remaining energized.
The work was
performed
by the licensee's
transmission
department.
The licensee's
pre-planning for this work was
thorough
and included the following
attributes:
The
work activity
and
outline of steps
was
discussed
and
approved
by the
PNSC.
Several
critical
steps
in the
process
were specified
to
be
independently verified.
Plant auxiliary loads
were placed
on the start-up
transformers
in the event of a possible turbine trip.
The fault pressure
relay associated
with the transformer coolant
pressure
was
disabled
during
maintenance
thereby
avoiding
spurious
switchyard breaker
and generator
output breaker trips.
A fire truck and fire watch
were positioned
nearby to combat
potential electrical fires.
An operator
was
assigned
to
be in constant
contact with the
control
room via radio if a problem should develop.
Practice
dry-runs were performed
on the spare transformer prior
to performing work on the
"C" main transformer.
The
licensee's
detailed
planning
and
use of mockups
were
very
effective in accomplishing
the reactor coolant
pump oil addition
and
transformer repairs without mishap
and are considered
to be strengths
in the maintenance
functional area.
b.
Circuit breaker
lA-3 (breaker
108)
experienced
reoccurring closing
problems
during this inspection period.
The breaker
supplies
power
from the unit auxiliary transformer to station unit auxiliary bus
1A.
Non-safety related
plant
loads
are
supplied
from this
bus.
On
a
loss of the main turbine/generator,
breaker
108 is required to open
and
auxiliary
bus
1A
will
automatically
switch
to
the startup
transformer
as
a
power
source
via breaker
107.
The
licensee's
troubleshooting
of this problem identified
a structural
problem in the breaker
cubicle which allows the breaker
secondary
disconnects
to disengage
and
prevent
breaker
closure.
A plant
modification
(PCR-6282,
Cubicle
lA-3 Breaker
Closing
Problem)
has
been initiated to correct
the
problem.
The inspectors
considered
this action to be appropriate.
c ~
In conjunction
with
the
observation
of the
CCW modification,
PCR-5748,
the licensee's
administrative controls regarding
the use of
freeze
plugs
was
also
performed.
The inspectors
reviewed
the
licensee's
procedures
for installing freeze
plugs in piping, training
records of personnel
trained
on the
use of freeze
plugs,
the freeze
plug training lesson
plan,
and visited the hands-on training facility
for freeze
plug installation.
Guidance
provided in
NRC Inspection
Manual, Part
9900 was utilized during this inspection.
Freeze
plugs
were
usually
installed
by
the
plant
services
organization.
For the
CCW modification, several
good pre-evolution
planning
practices
were
observed,
as
discussed
in
NRC Inspection
Report 50-400/92-02.
However,
the procedure utilized for installing
the
freeze
plugs,
MMP-012, Hydrostatic
and
Pneumatic
Testing of
Piping
Systems,
lacked
several
important features
including freeze
plug temperature
monitoring specifics,
source
requirements,
and contingency planning.
The good pre-planning for this work offset
the shortcomings of the procedure.
The licensee's
maintenance
organization also
had
a separate
procedure
for installing
freeze
plugs.
Recently,
these
procedures
were
combined
into
a single
procedure for all work groups
to use
when
installing freeze
plugs.
The
new procedure
incorporated
industry
lessons
learned
from
events
at
other
nuclear
stations.
The
inspectors
found that the recently revised
procedure
CM-M0169, Freeze
Seal
Procedure,
specified
appropriate
steps,
precautions,
and
limitations for installing
freeze
plugs.
The
procedure
also
incorporated
most of the guidance
provided in
NRC Inspection
Manual
Part
9900.
The inspectors
noticed that the
new procedure
did not
specifically address
communications
requirements
between
the control
room
and
the
personnel
performing
the
work.
The
extent
of
communication
was left up to the desires
of the operating shift to
specify.
The inspector
considered
a more formal requirement
to be
appropriate.
The
new procedure
also lacked specific provisions for
moni toring nitrogen flow.
The licensee
considered
observation of the
gaseous
plume
and
a level
indicated
in the jacket
to
be
sufficient.
The inspector
informed the licensee that this might not
be sufficient to positively verify nitrogen flow which is necessary
to maintain
freeze
plug integrity.
The
new procedure
specified
contingency
actions if the
seal
failed.
Thi's action
would
be
specified
for
each
individual
seal
and
would
reference
the
appropriate
emergency
procedure for the loss of the affected
system.
The
inspector
discussed
these
observations
with the licensee
who
stated that appropriate
procedure
revisions
would be considered.
The licensee
has trained
one
crew of plant services
and three plant
maintenance
crews
on the
use
and installation of freeze
seals
using
the
new
procedure.
The
inspectors
found this training to
be
thorough.
No violations or deviations
were identified.
10
Safety
Systems
Walkdown (71710)
The inspector
conducted
a walkdown of the
emergency
service water system
to verify that the lineup was in accordance
with license requirements for
system operability
and that the
system
drawing
and
procedure
correctly
reflected "as-built" plant conditions.
The general
material
condition of the system
was found to be satisfactory
except for some general
corrosion found
on the yokes of several
instrument
root
and drain valves.
Additionally, the inspector
noted
a discrepancy
between
the
system
drawing
and the as-built plant conditions in that the
drawing reflected only one of two valves in series
on a drain line.
These
findings
were
referred
to the
system
engineer
for corrections.
The
deficiencies
did not affect system operability.
No violations or deviations
were identified.
Review of Plant Nuclear Safety Committee Activities (40500)
The
inspectors
attended
selected
PNSC
meetings
to
observe
committee
activities
and
verify
TS
requirements
with respect
to
committee
composition,
duties,
and responsibilities.
Minutes from these
meetings
were
also
reviewed
to verify accurate
documentation.
The inspector
considered
the
conduct
and
documentation
of these
meetings
to
be
satisfactory.
During the
PNSC
meeting
on
February
18,
maintenance
activities to repair
a coolant
pump for the
"C" phase
were discussed.
Specific guidelines
were presented
which described
the
replacement
effort
and
potential
independent
verification steps
were
identified.
The
committee
decided
that this work could
be
performed
safely
with the
plant
online.
No violations
or deviations
were
identified.
Review of Spent
Fuel Handling Activities (71707)
As previously mentioned
in
NRC Inspection
Report 50-400/91-22
and 50-400/
91-01, the licensee
was in the process
of cleaning
up the spent fuel pools
and transfer
canals
utilizing an
underwater filter and
vacuum unit.
During this reporting period,
licensee
management
met with the inspectors
to discuss
future plans
on fuel shipments
and cleanup of the crud located
on the bottom of the spent fuel pools.
Due to significant area
radiation levels
associated
with the underwater
filters
and potentially high personnel
exposures
when handling/changing
out the filters, licensee
management
has reevaluated
the potential nuclear
safety
and
radiological
concerns
between
the
crud
cleanup
and
the
alternative
consequences
of leaving the crud
on the bottom of the pools,
and
has
decided to leave
the crud in the pools.
Based
on the tendency of
the
crud
to
remain
on
the
bottom of the
pools
unless
agitated
significantly,
and little intersystem
communication
between
the spent fuel
and
RC systems
during refueling operations,
the licensee
believes
the crud
hazard
can
be administratively controlled until plant decommissioning.
This action would allow time for the natural
decay of radioactive
isotopes
before
any
cleanup effort which would significantly reduce
personnel
exposure.
Licensee
personnel
have performed
an accident analysis
assuming
a
maximum crud loading in the spent fuel pools.
The licensee
plans to
maintain the crud concentration
within this analysis
and
does not plan to
process
spent
fuel
system
water
with the
radwaste
system
thereby
minimizing the effect
on other plant systems.
Furthermore,
most work
activities which generated
the radiological
problems in the past for pool
draindown,
rack installation,
and weld repairs,
have
been completed.
Only
minor reracking activities are planned in the future.
Although licensee
management
philosophy
addressed
previous
NRC concerns,
specific procedural
precautions
have not
been
implemented.
Nore formal
administrative controls for minimizing the spread of the crud hazard
were
recommended.
Short
Duration
Outage
to Repair
Bypass
Manifold Isolation
Valve
(71707)
On February
29,
1992,
a
power reduction
was
performed to secure
the "A"
main feedwater
pump.
Operating
personnel
noticed
excessive
vibrations
on the
pump balancing flow line.
While the plant was at
a reduced
power
level,
licensee
management
decided
to initiate repairs
to the
"C" main
transformer
and to add oil to "A" and "B" reactor coolant
pump motors.
During the oil addition to the reactor
coolant
pumps,
plant personnel
noticed
evidence
of boric
acid
leakage
from valve
inside
containment.
Licensee
management
conservatively
decided
to shutdown
the
plant
and effect repairs
even
though
the
leakage
was well within TS
limits.
An additional
valve
(1RC-953)
adjacent
to
was
also
leaking.
The plant was
taken to hot shutdown
(Node 4) to effect repairs.
Both valves
were repaired
by installing
a valve cap over the valve stem.
Following this maintenance
work,
a plant heatup
and startup
were performed
and
the plant
resumed
power operation
on
March
12.
The inspectors
witnessed
the shutdown,
cooldown,
heatup,
and startup activities
and also
were present
when the reactor
was taken critical.
Implementation of the
following plant procedures
was observed:
GP-002
Normal Plant Heatup from Cold Solid to Hot Subcritical
Node
5 to Node 3.
GP-004
Reactor Startup
(Node
3 to Mode 2).
GP-006
Normal Plant Shutdown from Power Operation to Hot Standby
1
to Mode 3;
GP-007
Normal Plant Cooldown
(Node
3 to Mode 5).
12
This
shutdown indicated
licensee
management's
support for the control of
boric acid corrosion.
Prompt repair of the leaking valves,
instead of
waiting
to
the
next refueling
outage,
was
prudent
and
prevented
unnecessary
repairs
which could have arisen
from the effects of boric acid
corrosion.
Outage
planning
was
detailed
and
properly
implemented.
Operation of the plant to achieve
the necessary
status
was satisfactory.
However,
a
rod position indication
problem which occurred
during both
shutdown
and startup operations
caused
a slight delay in reactor startup
activities
on March 12.
The problem,
which affected position indication
for control
rod B-10 at the 24-step elevation,
had originally caused
the
"RPI Urgent Alarm" to annunciate
on March
7 during plant shutdown.
At
that time, operators
did not troubleshoot
the occurrence
or initiate
a
work request
but continued
on with the plant shutdown.
When the event
reoccurred
during the plant startup,
a work request
was
generated
as
required
by Annunciator
Panel
Procedure,
APP-ALB-013, Main Control Board.
Such actions
on March
7 would have eliminated the delay
when the problem
recurred
during startup.
No violations or deviations
were identified.
Design
Changes
and Modifications (37828)
Installation of new or modified systems
were reviewed to verify that the
changes
were reviewed
and
approved
in accordance
with 10 CFR 50.59, that
the
changes
were
performed
in
accordance
with technically
adequate
approved
procedures,
that
subsequent
testing
and test
results
met
acceptance
criteria or deviations
were resolved
in an acceptable
manner,
and that appropriate
drawings
and facility procedures
were revised
as
necessary.
This review included
selected
observations
of modifications
and/or testing
in progress.
The following modifications/design
changes
were reviewed:
PCR-6265
Leak Repair of 1RC-22
PCR-6273
Leak Repair of 1RC-953
PCR-5748
CCW Thermal Relief Valve Deletion
PCR-5741
Low Flow Alarm, Excess
Letdown Design
Pressure
Uprate.
Modifications
PCR-6265
and
PCR-6273 installed valve caps
over the valve
stems
and
removed the associated
valve operating
handles.
The valves were
verified to be
open
and
then the
caps
were welded
on to prevent leakage.
The performance of these modifications
was found to be satisfactory.
a.
Modification
PCR-5741
raised
the relief setpoint for the
excess
letdown
heat
exchanger
relief valve to allow higher
CCW system
operating
pressure.
This modification, in conjunction with PCR-5748,
was
performed
to allow normal
CCW operation
at higher
pressures
Ci
13
without lifting system relief valves
as
described
in
LER 90-18.
Subsequent
modeling of the
CCW system
by licensee
design
engineers
revealed
that the completed modifications would still not suffice to
allow
normal
system
operations
and
that
additional
plant
modifications
would
be
necessary.
The
licensee
is presently
evaluating
design
change alternatives.
Although these modifications
removed
several
system relief valves
which will minimize potential
inventory loss
from the
CCW system during pressure
spike transients,
the
inspectors
considered
the
scope
of the modifications
to
be
insufficient to achieve
the desired
goal
which was to return the
system to
a normal configuration.
During
a review of control
room drawings
on February
28,
1992,
the
inspector
noticed that drawings
2165-S-1320
and
2165-S-1322
did not
depict the modifications
which
had
been
performed
on the component
cooling water
system
to replace
heat
exchanger relief valves with
small
flow orifices
(PCR-5748).
Due to the large extent of this
modification,
the
various
CCW heat
exchangers
were
modified in
stages.
The two
RHR and
BRS heat
exchanger
CCW modifications were
field completed
and
the
system
turned
over
as functional to plant
operations
on November 20,
December
4,
and January
16, respectively.
Usually plant drawings
are updated with modification status
by use of
red-lines until final drawing revisions
are
produced.
A review of
the clearance
center
drawings revealed similar discrepancies.
The discrepancies
were
discussed
with plant operations
management
personnel.
Their investigation
revealed
that the drawings
had
been
annotated
with the correct modification information but subsequent
drawing revisions
had
been
produced
which replaced
the red-lined
drawings.
Although the replacement
drawings included previous plant
modifications
to
the
system,
the relief
valve
replacement
modification had not yet been
included.
This detail
was overlooked
by the operations
production assistants
when replacing the drawings
and
the red-line information
was
not included
on the
new drawing
revisions.
Licensee
personnel
previously recognized
the potential
for this
problem to occur
and
prepared
a
procedure
revision to
require
a comparison
between old red-lined drawings
and
new revisions
to verify that all red-line information is included
on new drawings.
As of February
28, the procedure revision
had not been
implemented.
A previous
problem with failure to update plant drawings for modified
systems
was identified in
NRC Inspection
Report
50-400/91-09
in May
1991,
which resulted
in
a violation (400/91-09-01).
The licensee's
corrective
action for this violation included detailed
procedural
guidance
for the
operations
production
assistants
and
an audit
process
to
review
the
red-lined
drawings
quarterly
and at
the
completion of major outages.
The inspector
requested
the last audit
performed
but was
informed
by the licensee
that the audits
had not
been
performed
as required.
The licensee's
corrective actions
were
considered
incomplete
and
inadequate.
Failure
to
perform
comprehensive
and
complete
corrective
action is contrary to the
'
14
requirements
of
Appendix
B, Criterion
XVI, and is
considered
to
be
an additional
example of the violation discussed
in paragraph
2.a.( 1) of this report.
When informed of this finding, licensee
personnel
completed
an audit
of the drawings
and found numerous additional errors.
10.
Review of Licensee
Event Reports
(92700)
The following LERs were reviewed for potential
generic
impact, to detect
trends,
and to determine
whether corrective actions
appeared
appropriate.
Events that were reported
immediately
were reviewed
as they occurred to
determine if the
TS were satisfied.
LERs were reviewed in accordance
with
the current
a
~
b.
(Open)
LER 92-02:
This
LER reported
the undetected
failure of the
plant computer which resulted in a violation of the TS.
The licensee
has corrected
the specific problem with the operation of the computer
program
and is planning
computer
upgrades
to increase reliability.
Also, operating
procedures
will be
enhanced
to provide additional
details
on computer
TS related functions.
The
LER will remain
open
pending
completion
of
the
computer
upgrade
and
procedure
enhancements.
(Closed)
LER 92-03:
This
LER reported that the hot leg recirculation
switchover time specified
in plant emergency
procedures
and the
was
incorrect.
This matter
was identified
by the
nuclear
steam
system
supplier during the review process
for a proposed
technical
specification
change.
The
licensee
has
revised
the
emergency
procedures
and
has
approved
a revision to the
FSAR to reflect the
correct time.
11.
Exit Interview (30703)
The inspectors
met with licensee
representatives
(denoted
in paragraph
1)
at the
conclusion
of the inspection
on
Harch
20,
1992.
During this
meeting,
the
inspectors
summarized
the
scope
and
findings of the
inspection
as they are detailed in this report, with particular
emphasis
on
the
violations.
The
licensee
representatives
acknowledged
the
inspector's
comments
and
did not identify as
proprietary
any of the
materials
provided
to
or
reviewed
by
the
inspectors
during this
inspection.
Item Number
400/92-04-01
Descri tion and Reference
Violation -
Failure
to
proper ly identi fy
and
correct
deficiencies
a
required
by
Appendix
B,
Criterion XVI, paragraph
2.a. (1) and 9.b.
15
400/92-04-02
Acronyms and
Violati on -
Failure
to
use
a
qual ified
person
for
performance of independent verifications,
paragraph
3.a.
Initial i sms
ACR
BRS
CFR
DRPI
EPT
LER
MPT
NRC
OST
PLP
PNSC
RCS/RC
TS
WR/JO
Adverse Condition Report
As Low As Reasonably
Achievable
American Society of Mechanical
Boron Recovery
System
Component
Cooling Water
Code of Federal
Regulations
Digital Rod Position Indication
Engineering
Performance
Test
Final Safety Analysis Report
Heating, Ventilation and Air Co
Licensee
Event Report
Maintenance
Performance
Test
Maintenance
Surveillance Test
Non-Cited Violation
Nuclear Regulatory
Commission
Operations
Surveillance Test
Plant
Change
Request
Plant Program Procedure
Plant Nuclear Safety Committee
Reactor Auxiliary Building
Reactor
Coolant
Pump
Residual
Heat
Removal
Resistance
Temperature
Detector
Radiation
Work Permit
Spent
Fuel
Pool
Safety Injection
Technical Specification
Work Reque8st/Job
Order
Engineers
nditioning