ML18009A383
| ML18009A383 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/09/1990 |
| From: | Richey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-698 HO-900026-(O), NUDOCS 9002220128 | |
| Download: ML18009A383 (9) | |
Text
ACCEMRATED DlSTKBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
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'ACCESSION NBR:9002220128 DOC.DATE: 90/02/09 NOTARIZED: NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina
~
~
UTH.NAME AUTHOR AFFILIATION CHEY,R.B.
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control'Desk)
SUBJECT:
'Responds to 900112 ltr re violation noted in Insp Rept 50-400/89-35.Corrective actions:
I DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed.
DOCKET ¹ 05000400 D
'0'5000400 S
RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DRIS/DIR NRR/PMAS/ILRB12 OE LIEBE MAN,J G
RGN2 FILE Ol COPIES LTTR ENCL 1
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RECIPIENT ID CODE/NAME BECKER,D AEOD AEOD/TPAD NRR SHANKMAN,S NRR/DOEA DIR 11 NRR/DREP/PRPB11 NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS1 RES MORISSEAU,D COPIES LTTR ENCL 1
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1 EXTERNAL: LPDR NSIC 1
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I NCTE 'IO ALL "RIDS" RECIPIENIS:
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TOTAL NUMBER OF COPIES REQUIRED:
LTTR 26 ENCL 26
Carolfna Power S Light Company P. O. Box 165 ~ New Hill, N. C. 27562 R. B. RICHEY Manager Harrta Nuclear ProJect f'EB 0 9 1990 Letter Number.'HO-900026 (0)
Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 NRC-698 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 12, 1990, referring to I.E.
Report RII:.
50-400/89-35, the attached is Carolina Power and Light Company's reply to the violation identified in Enclosure l.
It is considered that the corrective actions taken/planned are satisfactory for resolution of the item.
In regard to your cover letter, you identify a concern with the implementation of our inservice testing program for valves, and also stated that our review of Generic Letter 89-04 was not'horough.
In a
generic sense,,
we believe that the SHNPP IST Program is consistent with the requirements of GL 89-04.
We believe this because
.the SHNPP IST Program was developed by CP&L and reviewed and approved by the NRC using the principles finally published in GL 89-04.
- However, CP&L will conduct further reviews of the components included in the program and the testing criteria provided by GL 89-04.
The inspection report and the transmittal letter discuss several weaknesses noted in our motor operated valve program.that were discussed with the inspectors during the inspecton.
The inspection report correctly states that the specific weaknesses will be evaluated as part of the implementation of the commitments made for NRC Generic Letter 89-10.
Our experience with previous diagnostic equipment was that the equipment did not provide sufficient confidence in the determination of thrust.,
Because of this the issues that were raised as weaknesses could not be reliably resolved.
As part of the GL 89-10
- program, we are participating in a corporate effort which has 'recently selected POO~Pr.0)a 8 900"r'0'i' DR ADOC Vw 05000 "J 00 Q
Pill)
MEM/HO-9000260/1/OS1
Document Control Desk Page 2
testing equipment for the implementation of the motor operated valve diagnostic testing.
In the mean
- time, several programs at SHNPP provide assurance of valve operability.
These include a
comprehensive maintenance history and repetitive failur'e analyses program to detect and analyze equipment failure', extensive delta pressure testing of valves in the preoperational test program',
inservice testing and other surveillance testing which is
- intended, to the extent practical, to test valves under design delta pressures',
and acceptable equipment performace to date.
In
- summary, we intend to aggressively implement our commitments to GL 89-10, but do not consider the identified weaknesses to have an adverse impact.on valve operability.
Your cover letter also requested that we re-evaluate our Technical Specification 3.4.4 interpretation regarding operability of power operated relief valves.
Enclosure B
provides CP6L's position regarding this matter.
Thank you for your consideration in this matter.
Very truly yours, Harris Nuclear Proje t MGM:dgr Enclosure cc'.
Mr. R. A. Becker (NRC)
Mr. S.
D. Ebneter (NRC RII)
Mr. J.
E. Tedrow (NRC SHNPP)
MEM/H0-9000260/2/OS1
ENCLOSURE A Technical Specification 4.0.5 requires inservice testing of'ASME Code Class 1,
2, and 3 pumps and valves in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda.
The licensee is committed to inservice testing in accordance with the 1983 Edition of the Code and Summer 1983 Addenda.
A.
Section XI, Subsection IWV-3521 requires check valves to be exercised at least once every three months."
Contrary to the
- above, check valves CS-775, CS-776, and CS-525 were not being exercised.
B.
Section XI, Subsec'tion IWV-3522 requires check valves to be exercised to the position required to fulfilltheir function.
Valves that cannot be exercised during plant operation shall be full-stroke exercised during cold shutdowns.
Contrary to the
- above, check valve CS-179, CS-207, and CS-193 were inadequately
- tested, in that, the testing procedure did not ensure each check valve was full-stroke exercised.
C.
Section IX, Subsection IWV-3415 requires testing valves with fail-safe actuators by observing the operation of the, valves upon loss of actuator power.
Contrary to the
- above, valves RH-20 and RH-58 have fail-safe actuators, and the fail-safe function was not being tested.
This is a Severity Level IV violation (Supplement I).
The violation is admitted.
Our response is organized similarly to Inspection Report No.
50-400/89-35, Enclosure 1,
which subdivides the violation in accordance with the ASME Section XI Subsection that is relevant.
For each subcomponent of the Violation, a specific reason for the violation, corrective steps
- taken, corrective steps to prevent further violations and full compliance date is given.
A.
Section XI, Subsection IWV-3521 requires check valves to be exercised at least once every three months.
Contrary to the
- above, check valves 1CS-775, 1CS-776, and 1CS-525 were not being exercised.
REASON FOR V10LATION (1CS-775, 1CS-776)
These valves were added by Field Change Request FCR-M-2002 (9-18-86), just prior to commercial operations and subsequent to the original program plan submittal to the NRR.
FCR-M-2002 was not reviewed for its impact on the IST Program.
MEM/HO-9000260/3/OS1
REASON FOR VIOLATION (continued)
(1CS-525)
This valve was deleted from the IST program by Revision 6
(Reference Letter g
MS-882826 "(0)).
The personnel involved in the development of the IST program decided not to take credit for the flow path through 1CS-525,
- however, the SHNPP Technical Specifications and the applicable Operations procedures were not-revised accordingly.
It should be noted that this flow path has never been used to fulfillTech.
Spec.
Operability requirements.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED (1CS-775, 1CS-776)
These valves were added to the IST program for back seat and full flow testing.
(1CS-525)
The applicable Operation procedure(s) have been revised to eliminate the possibility of using the flow path associated with 1CS-525 to satisfy Tech.
Spec. operability requirements.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS (1CS-775, 1CS-776)
Plant modifications are now reviewed for impact on Technical Specification 4.0.5.
(1CS-525)
Not Applicable.
DATE FULL COMPLIANCE WAS ACHIEVED December 10, 1989.
B.
Section XI, Subsection IWV-3522 requires check valves to be exercised to the position required to fulfilltheir function.
Valves that cannot be exercised during plant operation shall be full-stroke exercised during cold shutdowns..
Contrary to the
- above, check valve 1CS-179, 1CS-207, and 1CS-193 were inadequately
- tested, in that, the testing procedure did not ensure each check valve was full-stroke exercised.
REASON FOR VIOLATION I
The above stated valves are installed in the charging/safety injection pump (CSIP) minimum flow recirculation lines.
Their safety-related function is to provide a flow path to 'the alternate minimum flow relief valves during an Safety Injection when the CSIPs may be in a dead head condition.
At the time when the valves are tested, the pressure at the check valve's disk is nominally 2700 psig.
Plant personnel perceived that under these conditions audible tone changes were sufficient evidence MEM/HO-9000260/4/OS1
that the valves had changed position to provide design flow (i.e. full stroked).
Design flow is recognized as the design minimum recirculation flow rate for the CSIPs (nominally 60 gpm).
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Applicable
.Operational Surveillance Test procedures (OST-1007 and OST-1106) have been revised to measure downstream pressure as a
verification of full stroke.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS Not Applicable.
FULL COMPLIANCE WAS ACHIEVED December 10, 1989.
C.
Section XI, Subsection IWV-3415 requires testing valves with fail-safe actuators by observing the operation of the valves upon loss of actuator power.
Contrary to the above, valves 1RH-20 and 1RH-58 have fail-safe actuators, and the fail-safe function was not being tested.
REASON FOR VIOLATION These valves were initially designated as passive and were not included in the program plan originally submitted to the NRR (The SER apparently supported this through the absence of comments).
It is now recognized that the possibility exists for these valves to be throttled open when the Residual Heat Removal System (RHRS) is in service.
An accident at the time when these valves may be open (Modes 4
& 5),
is highly unlikely.
Also, assuming that 1RH-20 and 1RH-58 were to hang open, cold shutdown most likely would be achieved with the resulting partial flows through both RHR heat exchangers in addition to other plant safety-related systems (i.e. Main Steam/AFW).
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The valves have been added to the IST program and are now stroke time tested to the fail closed position in accordance with good engineering practices.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS Plant personnel will continue their ongoing review of the IST Program Plan.
DATE FULL COMPLIANCE WAS ACHIEVED December 14
'989.
MEM/HO-9000260/5/OSl.
ENCLOSURE B
PORV TECHNICAL SPECIFICATION INTERPRETATION Technical Specification Interpretation No.
89-1 provides that the automatic operation of the Pressurizer Power-Operated Relief. Valves (PORVs) is not considered to be an operability requirement for the valves to comply with Technical Specification 3.4.4.
The basis by which CP&L reached this interpretation follows.
Technical Specification 1.21 provides the definition of operability, which, in
- part, states that a
component must be capable of performing its specified functions.
It must be recognized that many components perform both safety-related and non-safety functions, and that operability of the component is dependent only on the ability to perform safety-related functions.
For example,,
a specified function of the Charging
- Pumps, required to be operable by Technical Specification 3.1.2.4, is to provide makeup to the Reactor Coolant System at the existing boron concentration.
If this function were to be unavailable, the action statement of the Technical Specification would not be applied, since normal RCS makeup is not a safety function of the Charging Pumps.
In evaluating the safety functions of the Pressurizer
- PORVs, the FSAR was reviewed to determine safety analysis assumptions, and the mitigating actions performed by the PORVs.
As stated in Section 5.2.2.1 of "the
- FSAR, no credit has been
- taken for the automatic functioning of the Pressurizer PORVs in response to a design basis RCS overpressure event.
The PORVs function to allow manual RCS depressurization for safe
- shutdown, and provide for manual RCS depressurization in the event of a
Steam Generator Tube Rupture accident.
These functions are required to be available to satisfy Technical Specification 3.4.4.
- Further, SHNPP contracted with its NSSS
- vendor, Westinghouse Electric Corporation, to develop a
computer database of component and Technical Specification relationships.
The issue of requiring the instrumentation which provides th'at automatic opening of the PORVs was reviewed and addressed, with Westinghouse agreeing that the automatic functioning of the PORVs is not a
required safety function, and would not be subject to Technical Specification Control.
CP&L performs the Technical Specification 3.4.4 required calibrations of the pressure transmitters as a condition,for the "operability of the PORVs.
These calibrations ensure proper response of the PORVs.
These calibrations ensure proper response of the PORVs to a high RCS pressure, and ensure the PORVs do not open prematurely.
If the PORVs are determined to
- open, the PORVs are declared inoperable unless immediate action is taken to. ensure the PORV cannot inadvertently open and depressurize the RCS.
It is noted that 1) no pressure setpoint is provided by Technical Specifications, 2) no opening time is provided by Technical Specifications, 3) no acceptance tolerance (error band) is provided by Technical Specifications, and
- 4) the instrumentation channels and power supplies are a non-safety grade control system.
MEM/HO-9000260/6/OS1
CP&L policy is t'o maintain the automatic function capability of the PORVs by appropriate system lineup and testing.
The interpretation ensures that limiting conditions for operation are entered only when the required safety functions of the PORVs are not avail. able.
If the automatic function of the PORVs was interpreted as a required function, then a single failure of non-safety grade power or'ontrol instrumentation channel would require a plant shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, despite the fact that the plant would have all equipment necessary to mitigate any accident, even assuming an additional single failure.
In addition, application of Technical Specification 3.4.4 would require the PORVs or their associated block valves to be closed with power
- removed, eliminating the availability of the safety-related function of the PORV based on the unavailability of the non-safety function.
Interpreting the Technical Specification in this manner is, therefore, non-conservative to plant overall safety.
In
- summary,
,CP&L complies with Technical Specification 3.4.4 Limiting Condition for Operation and the action requirements, and it performs listed surveillance requirements of this specification.
The lineup of the
- PORVs, block valves, and the associated instrumentation and power supplies supports the availability of the automatic operation of the PORVs.
- However, because the SHNPP FSAR takes no credit for the automatic function of the
- PORVs, CP&L does not interpret this to be a specified function requiring application of the action requirements of this specification.
- Further, such an interpretation degrades overall plant safety by requiring defeat of the safety function of the
- PORVs, specifically their manual depressurization capability of the
- RCS, by requiring the depressurization flow path be isolated and power removed from the valves.
Based on these
- facts, CP&L believes its interpretation of Technical Specification 3.4.4 is consistent with the SHNPP safety analysis requirements and with the intent of ensuring overall plant safety.
If the intent of the NRC is to require the functioning of the non-safety control
- system, the Technical Specification should be revised to address this requirement, and the action statements should also be revised to-avoid unwarranted defeat of the safety function of the PORVs when addressing the unavailability of the non-safety control function.
MEM/HO-9000260/7/OS1