ML18005A307
| ML18005A307 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/24/1988 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-609 HO-880068-(O), NUDOCS 8802290379 | |
| Download: ML18005A307 (8) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR: 88022'F0379 DOC. DATE: 88/02/24 NOTARIZED:
NQ i ACIL:50-400 Shearon Harris Nuclear Power Planti Unit 1> Carolina AUTH. NAME AUTHOR AFFILIATION WATSONi R. A.
Carolina Power 5 Light Co.
RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 0 05000400
SUBJECT:
Responds to 880129 ltr re violations noted in Insp Rept 50-400/87-40. Corrective actions: General Operating Procedures GP-005 h OP-12b changed to ensure that steam dump sos (SDS) placed in manual Zc SDB valves closed prior to opening MBIVs.
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for. permit renewal filed.
05000400 RECIPIENT ID CODE/NAME PD2-1 PD REB/
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REC IP IENT ID CODE/NAME BUCKLEY'S B AEOD NRR MORISBE*Ui D NRR/DLPG/GAB10A NRR/DREP/EPB10D NRR/DRIS DIRPA2 OE LIEBERMANiJ
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CHAL Carolina Power & Light Company HARRIS NUCLEAR PROJECT P. 0.
Box 165 New Hill, North Carolina 27562
.FF.B 24 1988 File Number'.
SHF/10-13510E Letter Number'.
HO-880068 (0)
NRC-609 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 January 29, 1988 referring to I.E.
Report RII:
50-400/87-40, the attached is Carolina Power 6 Light Company's reply to violation "D" identified in Enclosure 1.
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, MGW:dj Attachment R. A. Watson Vice President Harris Nuclear Project cc.'Messrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
Dr. J, Nelson Grace (NRC) 8802290379 880224 PDR ADOCK 05000400 P
PDR MEM/HO-8800680/1/OSl
Attachment to CPGL Letter of
Response
to NRC I.E.
Report RII:
50-400/87-40 Violation "D" Re orted Violation.
Technical Specification 6.8.la requires that written procedures be established and implemented covering the procedures outlined in Appendix A of Regulatory Guide 1.33, Rev.
2, February 1978.
Operations procedures are identified in Appendix A
of the Regulatory Guide.
a ~
Contrary to the above, procedures were not implemented, in that, on November 7,
- 1987, Operations personnel failed to properly set the Steam Dump Control system as required by site Operating Procedure OP-126, Rev., 2, Main
- Steam, Extraction Steam and Steam Dump
- System, subsequently resulting in a
reactor trip and safety inJection
~
b.
Contrary to the
- above, procedures were inadequately established in that OP-134, Rev.
2, Condensate
- System, did not stipulate that condenser recirculation isolation valve 1CE"293 be returned to its normal position, which
- resulted, on November 8,
- 1987, in Operations personnel failing to reposition valve 1CE-293 to the proper position for power operations, thus subsequently requiring a manual trip of the reactor.
This is a Severity Level IV violation (Supplement I).
Denial or Admission and Reason for The Violation'.
Since the violation pertained to two separate
- events, our response will address each event separately.
a.
The violation is correct as stated.
On November 7, 1987, at 0533, the plant was operating in Mode 2 at approximately 4.5X power.
The steam lines were being warmed with the Hain Steam Isolation bypass valves
- open, and all three MSIVs were closed.
The Steam Dump System was set in the pressure control mode with the steam header pressure controller erroneously set at 74X, instead of the required 84X.
MEM/HO-8800680/2/OS1
Attachment to CP&L Letter of
Response
to NRC I.E.
Report RII:
50-400/87-40 Violation "D" (continued)
The event began when the operators began opening the "A" MSIV-As "A" MSIV began to open, the steam header pressure increased beyond the setpoint of the pressure controller, and the steam dump valves opened to control steam pressure.
As described in LER-87-62, the steam header pressure cycled based on the interaction of the P-12 interlock and the steam header pressure controller.
This cycling caused automatic actuation of the Safety Injection
- System, an automatic reactor trip, and Main Steam Line Isolation.
Other specific details of the transient is presented in LER-87-062-00, dated December 7,
1987.
The cause of the event was both procedural deficiency and personnel error.
With the Steam Dump System set in automatic and the pressure control setpoint incorrectly set too low, opening an MSIV initiated a transient cycling of the steam dump valves.
General Operating Procedure GP-002, "Normal Plant Heatup From Cold Solid to Hot Subcritical," requires the Steam Dump System to be in manual mode with the steam dump valves closed prior to opening the MSIVs.
However, this procedure also allowed the MSIVs to remain closed during the heatup phase and be opened later in accordance with GP-005, "Power Operation Mode 2 to Mode 1."
The operators were utilizing GP-005, which references OP-126, which allowed the steam dump controller to remain in the automatic mode of operation while opening MSIVs.
GP-005 also contained a
step to check the setting of the steam dump controller at 1092 psig, although the controller is marked in percent demand.
The operator was required to look up in the curve book the setting (in percent) that corresponded to 1092 psig, and assure that the controller was adjusted to the proper value (84X).
The operator made an error when checking the controller setting which allowed the controller to remain at a setting of 74X, which is equivalent to 963 psig.
Had the controller been set at the proper value, the event would not have occurred.
Corrective Ste s Taken and Results Achieved:
The operators implemented the emergency operating procedures for a Safety Injection.
The isolation of the Main Steam System allowed the steam generators to repressurize to a
value equivalent to Tave.
The subsequent addition of Safety Injection water cooled the RCS to 535 degrees F.
At 0547, Safety Injection was secured, and the plant was stabilized at normal no load conditions (557 degrees F and 2235 psig).
The event resulted in declaration of an "Unusual Event" at 0546 due to injection of ECCS water into the reactor.
The Unusual Event was terminated at 0630.
MEM/H0-8800680/3/Osl
Attachment to CPSL Letter of
Response
to NRC I.E.
Report RII:
50-400/87-40 Violation "D" (continued)
Corrective Ste s Taken to Avoid Further Noncom liance:
The event has been discussed with the reactor operator
- involved, the results of his actions have been clearly identified, and he understands the results of his actions.
Training on the event has been performed with licensed operators.
The training emphasized that after a
step is performed, the operator must confirm a
correct response prior to proceeding',
and if necessary, reverse the action just performed.
In particular, it was stressed that the MSIV should have been closed on the first indication of a
problem.
The training covered procedure
- changes, operator
- actions, and personnel errors.
General Operating Procedure GP-005 and OP-126 have been changed to ensure that the Steam Dump System is placed in manual mode and the steam dump valves closed prior to opening the MSIVs.
In addition, GP-005 now requires independent verification when setting the steam dump controller setpoint, and the procedure also indicates the percent of scale as well as the steam pressure setting.
OP-126 has also been changed to show both percent of scale and steam pressure setting.
GP-002 has been changed to delete the steps for opening the MSIVs.
The steam dump controller scale has been marked with a red marker at the normal value (1092 psig and 84X).
Date When Full Com liance Was Achieved:
Full compliance was achieved on December 7, 1987.
Denial or Admission and Reason for the Violation.'.
The violation is correct as stated.
On November 8,
- 1987, the plant was operating in Mode 1 at 22X power.
The plant was in the process of increasing power from 100 MWe to 150 MWe.
The "lA" Main Feedwater
- Pump, Condensate Booster
- Pump, and Condensate Pump were in service.
MEM/H0-8800680/4/Osl
Attachment to CP&L Letter of
Response
to NRC I.E.
Report RII:
50-400/87-40 Violation "D" (continued)
As the load increase was started, the operator noticed that the "lA" Condensate Booster Pump (CBP) Controller was in the maximum demand position.
"1A" Main Feedwater Pump (MFP) suction pressure and "lA" CBP discharge pressure were approximately 430 psig, and "1A" Condensate Pump (CP) discharge pressure was approximately 200 psig.
It was noted that the Condensate Recirculation
- valve, 1CE-293, was in the "OPEN" position rather than the "MODULATE" position as required by normal plant operation.
Valve 1CE-293 diverts condensate flow to the condenser between the Condensate Booster Pump discharge and the first feedwater heater.
- Normally, the valve would have been closed prior to reaching 22K power.
In
The Shift Foreman determined that the safest way to avoid a flow disturbance, which would cause a
- trip, would be to slowly close the manual recirculation path isolation valve, 1CE-294.
An operator was dispatched to do this',
- however, there was no attempt to halt the turbine power increase process.
As turbine power approached 105 MWe, before any operator action on the manual recirculation path isolation valve could be made, "1A" CP discharge pressure fell below the trip setpoint of 195 psig.
The "1A" CP tripped and caused the trip of "1A" CBP and "1A" MFP resulting in a total loss of main feedwater.
The root cause of the event was personnel error as plant operators were not fully aware of all plant conditions (i.e.,
the recirculation valve being in the open position).
Shift turnover notes did indicate that valve 1CE-293 was in an abnormal position due to secondary cleanup operations conducted earlier in the week.
This operation involved increased flow through the condensate polishing demineralizers prior to plant startup in accordance with OP-134, Condensate System.
Val've 1CE-293 was in the open position to increase flow.
The procedure did not specifically address returning the valve to the modulate position.
Corrective Ste s Taken and Results Achieved:
Since feedwater flow could not be immediately
- restored, the reactor and turbine were manually tripped.
Steam Generator water levels were restored with the automatic actuation of the Auxiliary Feedwater System (AFM).
All plant systems responded as required, and the plant was stabilized in Mode 3.
MEM/HO-8800680/5/OS1
Attachment to CP&L Letter of
Response
to NRC I.E.
Report RII:
50-400/87-40 Violation "D" (continued)
Corrective Ste s Taken to Avoid Further Noncom liance:
In response to this event, the shift turnover process has been enhanced.
Previously, the turnover process included a briefing by the off going Shift Foreman and a
one-on-one turnover of each position.
By management direction, the turnover process has been supplemented with a
post-turnover briefing by the Balance of
- Plant, Reactor
- Operator, Senior Control Operator, each Auxiliary
- Operator, and the Shift Foreman.
The purpose of this is to ensure the operating crew has a full understanding of plant conditions.
The Operations Management
- Manual, OMM-001, has been revised to incorporate this action.
Operating Procedure, OP-134, - Condensate
- System, has been revised to require the condensate recirculation
- valve, 1CE-293 to be placed in the "modulate" position after completion of condensate/feedwater recirculation cleanup operations and prior to starting a Condensate Booster Pump.
Following the
- event, operating shifts were briefed on the causes and consequences of this event.
Date When Full Com liance Was Achieved:
Full compliance was achieved on December 22, 1987.
MEM/HO-8800680/6/OS1