ML18005B053

LER 89-014-00:on 890821,determined That Two Accessible Discharge Piping High Point Vents Not Verified Full of Water at Least Once Per 31 Days.Caused by Procedural Deficiency. Vents Verified Free of Air & Procedure revised.W/890920 Ltr

ML18005B053
Person / Time
Site:	Harris
Issue date:	09/20/1989
From:	Richey R, Schwabenbauer CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HO-890095-(O), LER-89-014-01, LER-89-14-1, NUDOCS 8909250246
Download: ML18005B053 (6)

Text

ACCELERATED DKBU'nON DEMOh SATION SYFI'EM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8909250246 DOC.DATE: 89/09/20 NOTARIZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION SCHWABENBAUER Carolina Power & Light Co.

RICHEY;R.B. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 89-014-00:on 890821,two high point ECCS vents not tested as required due to procedural defz.ciencies.

W/8 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR~ ENCL TITLE: 50.73/50.9 Licensee .,Event Report (LER), Incident Rpt, etc.

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NOTES:Application for permit renewal filed. 05000400 h

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 1 BECKER,D 1 1 INTERNAL: ACRS MICHELSON 1 1 ACRS MOELLER 2 2 ACRS WYLIE 1 1 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 "

1 AEOD/ROAB/DSP 2 2 DEDRO 1 1 IRM/DCTS/DAB 1 1 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1- 1 NRR/DEST/ICSB 7 1 1 NRR/DEST/MEB 9H 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/PSB 8D 1 1 NRR/DEST/RSB 8E 1 1 NRR/DEST/SGB 8D 1 1 NRR/DLPQ/HFB 10 1 1 NRR/DLPQ/PEB 10 1 1 NRR/DOEA/EAB 11 1 1 NRR RPB 10 2 2 NUDOCS-ABSTRACT 1 1 FILE 02 1 1 RES/DSIR/EIB '1 1 GN9 E 01 1 1 EXTERNAL: EG&G WILLIAMS,S 4 4 L ST LOBBY WARD 1 1 R l LPDR 1 1 NRC PDR 1 1 NSIC MAYS,G 1 1 NSIC MURPHY,G.A 1 1 NUDOCS FULL TXT 1 1 D

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Carolina Power 8 Light Company HARRIS NUCLEAR PROJECT P.O. Box 165 New Hill, NC 27562 SEP 2 0 1989 File Number.'SHF/10-13510C Letter Number: HO-890095 (0)

U.S. Nuclear Regulatory Commission ATTN: NRC Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR .POWER PLANT UNIT 1 DOCKET NO. 50-400 LICENSE NO. NPF-63 LICENSEE EVENT REPORT 89-014-00 Gentlemen:

In accordance with Title 10 to the Code of Federal Regulations, the enclosed Licensee Event Report is submitted. This report fulfills the requirement for a written report within thirty (30) days of a reportable occurrence and is in accordance with the format set forth in NUREG-1022, September 1983.

Very truly yours, R. B. Richey, Manage Harris Nuclear Project RBR:djs Enclosure cc'Mr. R. A. Becker (NRR)

Mr. W. H. Bradford (NRC SHNPP)

Mr. S. D. Ebneter (NRC RII) 8905'2.3024k '5'0 ~20 F'Ltg ADCtCK t.t5000400 8 FDC MEM/LER-89-014/1/OS1

NRC FOAM366 V S. NVCLSAR4ICC VLATORYCOMMISSION (64)9) APPROVED 0MB NO. 31504104 EXPIRES: 4/30/92 ESTIMATED BUADEN PER RESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT (LER) COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS AND REPORTS MANAGEMENT BRANCH (F430). V.S. NUCLEAR REGULATORY COMMISSION. WASHINGTON, OC 20555, AND TO

'THE PAPERWORK REDUCTION PROJECT (31500104), OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1I DOCKET NUMBER (2) PA E SHEARON HARRIS NUCLEAR POWER PLANT UNIT TITLE (4), TWO HI 1 050004001OF04 T STED S REQUIRED DUE TO PROCEDURAL DEFICIENCIES.

EVENT DATE IS) LER NUMBER (4) REPORT DATE (7) OTHER FACILITIES INVOLVED (SI MONTH DAY YEAR YEAR gj'P'EOUENTIAL I(N REVS'QNTH DAY YEAR FACILITYNAMES DOCKET NUMBER(SI

X(IO NUMBER (:rr NUMBER 0 5 0 0 0 08 21 8 9 8 9 0 1 4 00 09 20 8 9 0 5 0 0 0 THIS REPORT IS SUBMITTED PURSUANT 7 0 THE RLQUIAEMENTS OF 10 CFR (): IChech one or more of the lopowinpl (11 OPERATING MODE (9) 20A02(h) 20.405(cl 50,73 le)12) I iv) 73.71(II)

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LICENSEE CONTACT FOR THIS LER (12)

TELEPHONE NUMBER RICHARD SCHWABENBAUER AREA CODE REGULATORX COMPLIANCE TECHNICIAN 91 9 36 2 -2 66 9 COMPI.ETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) s w6' '

MANUFAC. EPORTABLE ' g " ' MANUFAC. EPORTAB CAUSE SYSTEM COMPONENT TO NPRDS . CAUSE SYSTEM COMPONENT TURER LE:,'O TVRER NPADS

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SUPPLEMENTAL REPORT EXPECTED l14) MONTH DAY YEAR EXPECTFD SUBMISSION DATE (15)

YES Ilfyer, complete EXPECTED SUEMISSIOIY DATE) NO ABsTRACT (Limit to le00 tpecer, l.e., epproslmetely llfreen tlnple tpece typewritten linrnl (14)

The plant was operating in Mode 1, Power Operation, at 100 percent reactor power on August 21, 1989. A walkdown of the low pressure Emergency Core Cooling System (ECCS) piping and associated procedures identified two accessible discharge piping high point vents that were not being verified full of water at least once per 31 days as required by Technical Specification (TS) surveillance requirement 4.5.2.b.l. This was identified at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on August 21, 1989. The subject vents were being tested on a quarterly basis in contrast to the required monthly frequency. The two vents were tested, and verified free of air at 1540 hours0.0178 days <br />0.428 hours <br />0.00255 weeks <br />5.8597e-4 months <br /> on August 21, 1989.

The cause of the event was procedural deficiency as plant procedures stated TS surveillance requirements were being satisfied, when in fact they were not.

The immediate corrective action was to verify the vents were free of air, and plant procedures are being revised to correct the deficiencies.

There were no safety consequences as a result of this event. There are five other points in the Residual Heat Removal (RHR) system which have been vented monthly, the two subject vents (one per RHR train) were being vented on a quarterly basis, and when checked on August 21, 1989, no air was detected in either line.

This event is being reported in accordance with 10CFR50.73(a)(2)(i)(B) as a violation of Technical Specifications Action 4.5.2.b.l.

NRC Form 368 (64)9)

NRC FORM 386A US. NUCLEAR REGULATORY COMMISSION (64)9) APPROVED OMB NO. 31500104 EXPIRES: 4/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT (LER) INFORMATION COLLECTION REQUEST: 50J) HRS. FORWARD COMMENTS REGARDING BURDEN FSTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH IP430). U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON. DC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (31504)104), OFFICE OF MANAGEMENTAND BUDGET. WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (8) PAGE IS)

YEAR Ld? SEQUENTIAL ?~r~+ REVISION SHEARON HARRIS NUCLEAR,POWER PLANT, o??3?. NVMSEII '/?& NVMOEII UNIT 1 TEXT ///moro 4Ooce /4 rer)rr/red, ooo odd/done//t/RC Form 36649/ (12) 0 5 0 0 0 4 0 0 89 01 4 OF DESCRIPTION:

The plant was operating in Mode 1, Power Operation, at 100 percent reactor power on August 21, 1989. A walkdown of the low pressure Emergency Core Cooling System (ECCS), and associated procedures identified two accessible discharge piping high point vents which were not being verified full of water at least once per 31 days as required by Technical Specification (TS) surveillance requirement 4.5.2.b.l. The two vents (one per train) are located in the Residual Heat Removal (RHR) discharge piping to the Reactor Coolant System (RCS).

This was identified at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on August 21, 1989. The subject vents were being opened on a quarterly basis in contrast to the required monthly frequency. The two vents were then tested and verified free of air at 1540 hours0.0178 days <br />0.428 hours <br />0.00255 weeks <br />5.8597e-4 months <br /> on August 21, 1989.

The vent paths which were excluded from the monthly surveillance are for valves 1RH-32, and 1RH-33 (A-TRAIN), and 1RH-67, and 1RH-68 (B-TRAIN). These vents were originally included in Operating Surveillance Test Procedure (OST)-1107, ECCS Flow path and Piping Filled Verification Monthly Interval Modes 1-2-3-4, Revision 1, dated April 9, 1986. A Plant Change Request (PCR)-423 initiated September 5, 1986, added several more vent lines to both the high and low pressure ECCS discharge piping. Revision 2 to OST-1107, dated December 12, 1986, added the new vents installed by PCR-423 for monthly testing, however, it also deleted the two subject vents.

The subject vents were being tested on a quarterly basis in accordance with procedures OST-1008, RHR Pump Operability Quarterly Interval for Modes 1-2-3, and OST-1108, RHR Pump Operability Quarter Interval for'odes 4-5-6. While these two procedures'urpose statements listed 4.5.2.b.l as being completed in the procedure, OST-1008 and OST-1108 covered only 2 of the 7 accessible vent locations identified for the RHR system. To satisfy 4.5.2.b.l both OST-1107 and OST-1008 or OST-1108 should have been scheduled on a monthly basis. It is not clear why the vents were separated between these procedures.

Plant General Order (PGO)-031, Technical Specifications Cross Reference Index, lists OST"1008 as satisfying TS 4.5.2.b.l, and OST-1108 as satisfying TS 4.5.3.1. Surveillance 4.5.3.1 is a surveillance specification that simply references all of the 4.5.2 surveillances as being necessary for operability in Mode 4. PGO"031 is also in error because of the information provided in the purpose section of OST-1008 and OST-1108.

NRC F orm 368A (64)9)

NRC FORM 366A UrL NUCLEAR REGULATORY COMMISSION (6$ 9) APPAOVED OMB NO.31500104 EXPIRES: 6/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT ILER) INFORMATION COLLECTION REQUEST: 50l) HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECOADS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (P$ 30), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO THE PAPERWOAK REDUCTION PROJECT (31504)04), OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, OC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

SHEARON HARRIS NUCLEAR .POWER PLANT YEAR ~

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SEQUENTIAL NIJMBSR

)~ +EVISION

'.re'UM86R UNIT 1 0 5 0 0 0 OF TEXT /l/neve e>>co /1 nqukaf, ooo odd/9'ono/ HRC Foon 366AB/ (17)

DESCRIPTION: (continued)

A review of the high pressure ECCS discharge piping high point vents was conducted to verify/determine if any similar situations existed in this system on August 22, 1989. This review identified one potential high point vent associated with the Boron Injection Tank (BIT) which is not being vented on a routine basis. An engineering evaluation was initiated August 22, 1989, to determine if this normally isolated section of the high pressure ECCS should be included in the TS 4.5.2.b.l requirements. This evaluation is being performed by PCR-4730.

CAUSE:

The cause of the event was procedural deficiencies as plant procedures stated TS surveillance requirements were being satisfied, when in fact they were not.

An investigation was done to determine the cause of the procedure ommissions.

However, the cause of the error could not be determined. The procedure change was performed by contractor personnel no longer on site, and the historical file does not provide enough information to indicate why the error was made.

ANALYSIS:

r There were no safety consequences as a result of this event. There are five other high point vents in the RHR system which have been tested monthly in accordance with TS requirements, and no unsatisfactory results being reported. Also, the two'subject vents were being tested on a quarterly basis, and when tested on August 21, 1989, sati'sfactorily passed with no air being detected in either line.

This event is being reported in accordance with 10CFRS0.73(a)(2)(i)(B) as a violation of Technical Specifications Action 4.5.2.b.l.

An event reported in LER-87-043-00 stated that six outside containment isolation valves were omitted from monthly surveillance tests due to procedural deficiencies. However, there were no events which involved the failurre to test high point vents.

CORRECTIVE ACTION/ACTION TO PREVENT RECURRENCE:

1) OST-1008 is being revised to delete the reference and.acceptance criteria associated with TS 4.5.2.b.l.

2) OST-1108 is being revised to delete the reference and acceptance criteria associated with TS 4.5.3.1.

NR C Form 368A (8$ 9)

NRC FORM'SSBA U S. NUCLEAR REGULATORY COMMISSION (649) APPAOVED OMB NO. 31500)OS EXPIRES; e/30/92 LICENSEE EV ESTIMATED BUADEN PER RESPONSE TO COMPLY WTH THIS REPORT (LER) INFORMATION COLLECTION REQUESTI 50/J HRS. FOAWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (P.530). U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO 1'HE PAPERWORK AFDUCTION PROJECT (31504104). OFFICE OF MANAGEMENTAND BUDGET. WASHINGTON. DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2)

LER NUMBER (6) PAGE (3)

~

YEAR  ;)(*5 SEOUENTIAL ): REVISION SHEARON HARRIS NUCLEAR POWER PLANT NUMBER 6 NUMBER 0 5 0 0 0 OF 1

TEXT /I/ hh>>he Z>>ce /e eeIh/hed. Ihee edd/I/oh>>/I/RC %%dhIII 3664'e/ (12)

3) PGO-031 is being revised to delete the TS reference for procedures OST-1008, and OST-1108 as required.

4) OST-1107 is being revised to include the two omitted vents for monthly testing.

5) 'CR-4730 is being completed to determine if this normally isolated section of the high pressure ECCS should be included in the TS 4.5.2.b.l requirements. Appropriate action will be taken if required.

6) A review will be made of quarterly OSTs which include monthly surveillances to assure that these surveillances are being adequately covered by the procedures, the scheduling process, and PG0-031.

EIIS CODE INFORMATION:

EMERGENCY CORE COOLING SYSTEM (ECCS) BP RESIDUAL HEAT REMOVAL (RHR) BP REACTOR COOLANT SYSTEM (RCS) AB BORON INJECTION TANK (BIT) Bg NRC Form 366A (BJ)9)