ML18005A297
| ML18005A297 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/15/1988 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-595 HO-880013-(O), NUDOCS 8802230111 | |
| Download: ML18005A297 (6) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS>
ACCESSION NBR: 8802230111 DOC. DATE: 88/02/15 NOTARIZED:
NO FACIL: 50-400 Shearon Harris Nuclear Power Planti Unit ii Carolina AUTH. NAME AUTHOR AFFILIATION
~j*TSON> R. *.
Carolina Power 5 Light Co.
REC IP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000400
SUBJECT:
Responds to NRC 871014 itr 5 notice of violation dtd 880119 re 50-400/87-34-01. Corrective actions: table e/footnote for closed sys counting as isolation boundaries reviewed eritten instruction added.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED: LTR ENCL'IZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: Application for permit reneeal filed.
05000400 RECIPIENT ID CODE/NAME PD2-1 PD COP IES REC IP IENT LTTR ENCL ID CODE/MANE 1
BUCKLEYiB COPIES LTTR ENCL 2
2 INTERNAL:
AEOD NRR MORISSEAUi D NRR/DLPQ/GAB NRR/DREP/EPB NRR/DRIS DIR OE MANiJ GN2 FILE 01 1
1 1
1 1
1 1
1 DEDRO NRR/DLPG/PEB NRR/DOEA DIR NRR/DREP/RPB NRR/PMAS/ ILRB OGC/HDS1 RES/DRPS DIR 1
1 1
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1 EXTERNAL:
LPDR NSIC NRC PDR TOTAL NUMBER OF COPIES REQUIRED:
LTTR 22 ENCL 22
Carolina Power 8 Light Company HARRIS NUCLEAR PROJECT P. 0. Box 165 New Hill,'orth Carolina 27562
.FEB
/-5 )9gg File Number '.
SHF/10-13510E Letter Number'HO-880013 (0)
NRC-595 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen:
In reference to your letter of October 14, 1987 and Notice of Violation of January 19,
- 1988, referring to I.E.
Report RII:
50-400/87-34-01, the attached is Carolina Power
& Light Company's reply to the violation identified.
It is considered that the corrective actions taken are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
MGW:ddl Attachment R. A. Watson Vice President Harris Nuclear Project cc'.
Messrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC) 8802230i ii 8802i 5 PDR ADOCK 05000400 G
PDR MEM/HO-8800130/Page 1/OS1
Attachment to CP&L Letter of Response to NRC I.E. Report RII:
50-400/87-34 Re orted Violation.'echnical Specification (TS) 3.6.3 requires that when the plant is operating in Modes 1, 2, 3, or 4, each containment isolation valve must be operable.
The TS ACTION statement specifies that when one of the containment isolation valves is inoperable, the licensee must maintain at least one other penetration isolation valve operable and either restore the inoperable valve to operable status within four hours, or isolate each affected penetration within four hours by use of at least one deactivated automatic valve secured in the isolation position, or isolate each affected penetration within four hours by the use of at least one closed manual valve or blind flange, or the plant should be placed in hot standby (Mode 3) within the next six hours, and in cold shutdown (Mode 5) within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
On August 13, 1987, with the Unit in Mode 1;
containment isolation valve 1BD-11 was declared inoperable and stuck in the open position, and remained in this condition until September 13, 1987.
Contrary to the
- above, during this time the licensee failed to take appropriate action to comply with the ACTION requirements of Technical Specification 3.6.3 in that valve 1BD-11 was not
- repaired, the penetration was not
- isolated, nor was the unit brought to cold shutdown.
This is a Severity Level IV violation (Supplement 1).
Denial or Admission and Reason for The Violation'.
The violation is correct as stated.
The plant was operating in Mode 1, Power Operation, at 100 percent reactor power on August 13, 1987.
Steam Generator lA blowdown containment isolation valve 1BD-ll was declared inoperable at 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br /> after failing an inservice inspection test.
The valve was open and could not be closed locally or by the control switch.
Plant operation continued after the valve was declared inoperable based on the interpretation of a
footnote in the containment isolation valve list.
This interpretation was based on CPSL's understandings extending from the development stages of the Technical Specifications (TS).
In early
- 1986, CPSL personnel working on the development of the Harris TSs suggested to NRR Staff that changes were needed to Standard Technical Specifications (STS) 3.6.3, Containment Isolation Valves.
Our review of this specification showed that it was written with the dual isolation valve lines of GDC 55 and 56 in mind; therefore, it was ambiguous and inconsistent with regard to single valve-closed system type penetrations (GDC-57).
MEM/HO-8800130/Page 2/OS1
When CP&L personnel proposed to clarify STS 3.6.3, NRR Staff indicated that it was very unlikely that changes would be made to STS 3.6.3 itself.
As an alternative, NRR Staff suggested that notes should be added to the containment isolation valve table.
CP&L agreed to this suggestion and proposed the
- change, which became Note 6 to the table.
CP&L's intent for Note 6
was to provide equivalent actions for closed loop, single valve systems (GDC 57) to those already established for dual isolation valve systems (GDC 55 and 56).
NRR Staff concurred with Note 6, and issued Note 6 with the original Shearon Harris TS.
It was CP&L's belief that the issuance of Note 6
indicated that the NRC understood and concurred with this intent although specific detailed discussions did not take place.
The policy of applying Note 6
evolved in internal discussions during late 1986 and early 1987.
From these discussions developed a position that if a valve such as BD-11 were to stick
- open, continued operation would be permissible under certain circumstances.
The logic that was applied is as follows.
- First, credit for the closed system in this manner could only be taken as long as the system was intact.
Then based on the fact that Note 6,
as issued by the NRC> specifies that we may take credit for the closed system as an isolation
The result is a configuration which provides protection for GDC 57 penetrations which is equivalent to GDC 55 and 56 penetrations under the Action statement.
Since the closed loop is an entirely passive boundary, it is not subject to an active single failure.
With the closed system intact, the "open penetration" condition of the opening phrase of the Action statement for TS 3.6.3 is not meaningful for a
In the context of a
containment isolation
- valve, the term "open" was understood to mean open to either the Reactor Coolant System (RCS) or the containment atmosphere.
With the closed system
- intact, the penetration is separated from either of those areas by a barrier that in only subject to a passive failure, and thus, is not "open" from an isolation standpoint.
At the time of the failure of BD-11, the shift's Senior Control Operator and Shift Foreman directed that an Equipment Inoperable Record be initiated to document entry into an Action statement and consulted the Director Regulatory Compliance to obtain confirmation of the correct action.
Based on the position developed for note 6,
the Director Regulatory Compliance concurred with the interpretation taken by the Shift Foreman.
During an internal revie~
of the resulting configuration, questions were raised concerning the identification of unrelated unreviewed potential single failure mechanisms.
Due to these new concerns on satisfying the safety analysis, the plant was shutdown on September ll, 1987.
LER 87-053 discusses the reasons that led to this decision.
During the shutdown, BD-11 was repaired.
The inability for valve 1BD-ll to stroke was caused by binding of the carbon seal rings between the inside diameter of the valve cage and the valve plug.
The valve was determined to have minor steam cuts in the packing gland, a
bad mechanical
- actuator, and damaged seal rings.
The valve
- stem, plug actuator, and carbon rings were replaced and the valve was repacked.
This failure resulted in the valve being physically unable to stroke with steam leaking by the valve stem.
MEM/HO-8800130/Page 3/OS1
Corrective Ste s Taken and Results Achieved:
The plant was operated for twenty-nine days from the time valve 1BD-11 was inoperable until the plant was shut down.
During this
- period, the containment isolation function was met by the closed system.
The capability to isolate blowdown to meet AFW flow requirements was available from valves 1BD-1 and 1BD-7 which isolate on a Safety Injection signal and are designed to the same code class and seismic qualification as the containment isolation valve 1BD-ll.
Isolation of blowdown flow could also have been achieved using the non-nuclear safety control valve for blowdown.
No safety consequences resulted from this event.
Valve 1BD-11 was repaired and returned to operable status.
Corrective Ste s Taken to Avoid Further Noncom liance'.
Upon discovery that the NRC disagreed with CPSL's interpretation action was taken to comply with the NRC interpretation.
Valves in the table containing a
footnote for closed systems counting as isolation boundaries have been reviewed and a written instruction as to the appropriate action to take has been provided to operators.
The action requires the penetration to be isolated within four hours.
In 'addition, other valves, such as 1BD-1 and 1BD-7, not specifically addressed by Technical Specifications are now required to be closed within a specified time interval if they are found inoperable.
In addition, changes have been made to the procedure for Technical Specification interpretations.
The essence of this change is to assure throughout plant management understanding and concurrence in Technical Specification interpretation prior to implementation.
Date When Full Com liance Was Achieved:
The actions as described above were completed on September 24, 1987.
MEM/HO-8800130/Page 4/OS1