ML18004B923
| ML18004B923 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/03/1987 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-578 HO-870489-(O), NUDOCS 8709090664 | |
| Download: ML18004B923 (6) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:870'2090664 DOC. DATE: 87/OV/04 NOTARIZED:
NO
.rACIL:50-400 Shearon Harris Nuclear Power Planti Unit ii Carolina AUTH. NAME AUTHOR AFFILIATION WATSON'. A.
Carolina Poeer 8c Light Co.
REC IP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000400
SUBJECT:
Responds to NRC 870804 itr re violations noted in Insp Rept 50-400/87-26. Corrective actions: General Operating Procedure GP-007'ormal plant cooldoen (Mode 3 to Mode 5),
revised to include caution note prior to depressurization.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED: LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: Application for permit renewal filed.
05000400 RECIPIENT ID CODE/NAME PD2-1 PD COPIES LTTR ENCL 1
1 REC IP IENT ID CODE/NAME BUCKLEY'S B COPIES LTTR ENCL 2
2 INTERNAL:
AEOD NRR MOR ISSEAUi D NRR/DREP/EPB NRR/DR IS DIR OE LIEBERMANiJ
<<RFWMg5 RGB FlLE 01 DEDRO NRR/DOEA DIR NRR/DREP/RPB NRR/PMAS/ILRB OGC/HDSi RES DEPY GI-1 1
1 2
2 1
1 1
1 1
1 XTERNAL:
1 TOTAL NUMBER'F COPIES REQUIRED:
LTTR 20 ENCL 20
0
Carolina Power & Light Company HARRIS NUCLEAR PROJECT P.
O.
Box 165 New Hill, North Carolina 27562 SEp O 5 1987 File Number.'HF/10"1351OE Letter Number:
HO-870489 (0)
NRC-578 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 Gentlemen'.
In reference to your letter of August 4, 1987, referring to I.E.
Report RII:
50-400/87-26, the attached is Carolina Power
& Light Company's reply to violation "A" identified in Enclosure l.
It is considered that the corrective actions taken are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Very truly yours, Em~/
R. A. Watson Vice President Harris Nuclear Project RAW:dj Attachment cc:
Messrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
DR. J. Nelson Grace (NRC) 8709090664 8709M PDR ADQCK 05000400 6
PDR MEM/HO-8704890/Page 1/OS1
.~l gP
Attachment to CP&L Letter of Response to NRC I.E. Report RII:
50-400/87-26 Violation "A" Re orted Violation A.
Technical Specification 6.8.1.a requires that written procedures be implemented covering the procedures recommended in Appendix "A" of Regulatory Guide 1.33, Rev.
2.,
February 1978.
General Plant Operating Procedures are identified in Appendix "A" of the Regulatory Guide.
General Procedure GP-007. "Normal Plant Cooldown from Mode 3 to Mode 5" (Rev. 2), requires in section 5.29 the safety injection cold leg accumulator system to be isolated prior to decreasing primary plant pressure below 900 pounds.
Contrary to the above, on July 16, 1987, while performing a
plant cooldown, GP-007 was not implemented in that Operations personnel failed to isolate the safety injection cold leg accumulator system before reducing primary plant pressure to less than 900 pounds, resulting in the passive portion of the safety injection system injecting approximately 200 gallons of borated water into the primary plant system.
This is a Severity Level IV violation (Supplement I).
Denial or Admission and Reason for The Violation.'he violation is correct as stated.
The plant was at 0
percent reactor power in Mode 3,
Hot
- Standby, on July 16, 1987.
The plant was in the process of a normal cooldown and depressurization to 350 degrees F and 365 psig.
Once this condition was reached the Residual Heat Removal (RHR) system (EIIS:AB) would be put into service.
A cooldown rate of approximately 90'F/hr was being maintained.
General Operating Procedure (GP)-007, Normal Plant Cooldown (Mode 3
to Mode 5) requires the isolation of Cold Leg Accumulators (EIIS:BP) prior to decreasing the Reactor Coolant System (RCS)
(EIIS:AB) pressure below that of the Accumu3.ators.
The Accumulators are required to be maintained between 585 and 665 psig per Technical Specification 3.5.1.
Accumulators are required to be operable only when the RCS pressure is greater than 1,000 psig.
At 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />, the reactor operator was instructed to review Operating Procedure (OP)-ill, Residual Heat Removal
- System, in anticipation of placing the RHR system into service.
At 1250 hours0.0145 days <br />0.347 hours <br />0.00207 weeks <br />4.75625e-4 months <br />, while the operator was reviewing OP-ill, the "A" Accumulator low pressure alarm was received followed immediat'ely by the "B" Accumulator low pressure alarm.
These alarms indicated that-an injection of the Safety Injection Accumulators was initiated:
MEM/H0-8704890/Page 2/OS1
The operator observed RCS pressure at 600 psig and Cold Leg Accumulator pressures were at 640 psig.
The operator had neglected to isolate the Cold Leg Accumulators prior to decreasing RCS pressure below that of the accumulators as required by GP"007 and caused the injection of the Accumulators.
The requirement to isolate the Accumulators during plant depressurization is clearly within the knowledge and training of licensed operators and is required by Procedure GP-007.
Therefore, personnel error on the part of the reactor operator is the primary cause of the.event.
Additionally, there were several factors which contributed to the
- event, any of which may have prevented the personnel error'.
l.
A pre-evolution briefing was not held to review the cooldown evolution and the key operator actions that would be required.
2.
The procedure (GP-007) did not include a specific caution at the commencement of the depressurization phase to alert the operator to the subsequent requirement to isolate the accumulators prior to decreasing pressure below 900 psig.
3 ~
The Senior Control Operator was reviewing the results of completed surveillance tests and thus was distracted from direct supervision of this phase of the cooldown.
Corrective Ste s Taken and Results Achieved:
The operator secured the Pressurizer spray valves and energized all Pressurizer heaters to increase RCS pressure above that of the Accumulators.
RCS pressure increased above that of the Accumulators in approximately sixty seconds and the injection was terminated.
During this
- time, approximately 8 percent indicated level, or a total of 170 gallons, was injected.
The Accumulators were subsequently isolated and the cooldown and depressurization to RHR cut in conditions was resumed.
No safety consequences resulted from this
- event, as the reactor was subcritical and depressurized at the time.
The event did not result in a challenge to the integrity of the RCS or require the actuation of other engineered safeguards.
MEM/H0-8704890/Page 3/OSl
Corrective Ste s Taken to Avoid Further Noncom liance:
1.
General Operating Procedure (GP)-007, Normal Plant
'Cooldown (Mode 3 to Mode 5),
has been revised to include a caution note prior to depressurization.
2.
Procedure No.
OMM-001, Conduct of Operations, section on Shift/EvoLution briefings for off normal evolutions was re-emphasized'y the Operations Manager to the Operations Supervisor.
3.
Operating shifts have been retrained on items 1 and 2
above with emphasis on anticipating plant operations and use of pre-evolution briefings before performing significant evolutions.
4.
Senior Control Operators (SRO's) have
'been instructed on the requirement to maintain constant awareness of plant status during off normal.,
evolutions.
ST Appropriate disciplinary action was taken with. the operating shift involved.
Date When Full Com liance Mill Be Achieved:
Full compliance was achieved on August 3,
1987 with completion of the actions stated above.
V MEM/HO-8704890/Page 4/OS1