ML18009A411

Responds to NRC 900227 Ltr Re Violations Noted in Insp Rept 50-400/90-02.Corrective Actions:Personnel Involved W/ Quadrant Power Tilt Ratio Calculations & Operability Determination Counseled

ML18009A411
Person / Time
Site:	Harris
Issue date:	03/23/1990
From:	Richey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-707 HO-900059-(O), NUDOCS 9004030116
Download: ML18009A411 (5)

Text

ACCELERATOR) DRIBUTION DEMONSHQTION SY!B BEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9004030116 DOC.DATE: 90/03/23 NOTARIZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION RICHEY,R.B. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 900227 50-400/90-02.

ltr re violations noted in Insp Rept DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR i ENCL / SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed. 05000400 COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL'ECIPIENT PD2-1 PD 1 1 BECKER,D 1 1 ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA DIR 11 1 1 NRR/DREP/PEPB9D 1 1 NRR/DREP/PRPB11 2 2 NRR/DRIS/DIR 1 1 NRR/DST/DIR SE2 1 1 OGC/HDS 1 I

NRR/PMAS/ LRB 1 2 1 1 BOGS AB&Z 1 1 1 1 1 1 RES MORISSEAU,D 1 1 RGN2 FILE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOIX TO ALL "RIDS" RECIPIEWIS:

PLEASE HELP US TO REDUCE WAS'ONI'ACTTHE DOCUMENI'ONIROLDESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISHUBUTION LISIS FOR DOCUMENIS YOU DON'T NEEDI OTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

Caroljna Power S Ught Company "P. O. Box t65 ~ New Hill, N. C. 27562 R. B. RiCHEY Manager Hanis Nuctear Project MAR 2 5 1990 Letter Number: H0-900059 (0)

Document Control Desk NRC-707 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 February 27, 1990, referring to I.E. Report RII: 50"400/90-02, the attached is Carolina Power and Light Company's reply to violations "A" and "Bdentified in Enclosure 1.

It is considered that the corrective actions taken/planned are satisfactory for resolution of the item.

Thank you for your consideration in this matter.

Very truly yours, R. B. Richey, Ma ager Harris Nuclear Project MGW:dgr Enclosure cc'Mr. R. A. Becker (NRC)

Mr. S, D. Ebneter (NRC - RII)

Mr. J. E. Tedrow (NRC SHNPP) 9004030116 900323 PDR ADOCK 05000400 0 PDC MEM/HO-9000590/1/OS1

ATTACHMENT TO CP&L LETTER OF RESPONSE TO NRC I.E.

REPORT RII: 50-400/90"02 VIOLATIONS "A" AND "B" Re orted Violation:

A. Technical Specification (TS) 6.8.1.a requires that written procedures be established and implemented covering procedures outlined in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Appendix A, Paragraph 8.B requires that written procedures be provided for surveillance tests.

Operations Surveillance Test OST-1039, Calculation of Quadrant Power Tilt Ratio, provides the steps necessary to manually calculate the quadrant power tilt ratio. Step 7.1 of this procedure requires that detector currents be recorded from all operable power range channels at the Nuclear Instrument cabinets.

Contrary to the above, on December 28, 1989, procedure OST-1039 was not properly implemented in that the detector currents required by step 7.1 were improperly recorded and a subsequent review by two senior licensed shift foremen failed to identify the improperly performed TS surveillance.

This is a Severity Level IV violation (Supplement I).

B. Technical Specification 4.2.4.1 requires that the quadrant power tilt ratio shall be calculated at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the alarm is inoperable.

Contrary to the above, after receiving the upper and lower quadrant power tilt alarms and subsequently bypassing the NI-44 channels, from 6:55 a.m.

on December 28, 1989, through 2:25 a.m. on December 30, 1989, the quadrant power tilt ratio was not calculated at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the alarm was inoperable.

This is a Severity-Level IV viola)ion (Supplement I).

Denial or Admission and Reason for the Violation'.

The violations are correct as stated.

On December 28, 1989, initial power ascension for cycle three operation was in progress. When the reactor power level reached approximately 55X, annunciators alarmed, indicating a potential flux tilt in the reactor. The shift operators performed a manual calculation of the QPTR per OST-1039, and the calculated value was 1.018, within the 1.02 limit of TS 3.2.4.

MEM/HO-9000590/2/OS1

As identified in Violation "A," the detector currents recorded in OST-1039 were incorrect. A review of the recorded values determined that the operator must have read the incorrect scale on the meter, causing his currents to be high by a factor of two. This had no effect on his calculated value of QPTR, however, since QPTR is a ratio of the maximum to normalized average of the four detectors, so the error cancels out when the ratio is determined.

Reviews of the calculation performed by the shift foremen failed to detect the error.

With QPTR determined to be within limit, and with the annunciators alarming intermittently, the situation was discussed by Operations and Instrument and Control personnel. It was decided that power range channel N-44 was causing the intermittent alarm. Initial calibrations of the power range nuclear instrumentation would be performed for cycle three when equilibrium Xenon conditions at a 75K power level were established, as per TS 4.3.1.1. It was expected that these scheduled calibrations would correct N-44, and clear the intermittent alarms.

Operations personnel then bypassed the N-44 channel input to the QPTR annunciators in order to clear the intermittent alarm, and to ensure that any flux tilt on the remaining three channels would be detected by the alarm.

However, neither the N-44 channel nor the QPTR alarm were 'eclared inoperable. Subsequent reviews of the event have determined that all four power range channel inputs must be available to consider the QPTR alarm operable, except as provided in TS 3.3.1, Table 3.3-1, Action 2.c., which provides compensating action for inoperable power range nuclear instrument channel. Since N-44 was not declared inoperable, TS 4.2.4.1 was applicable and, as identified in Violation "B," TS 4.2.4.1 was not compLied with, in that QPTR was not determined to be within limit each 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the alarm was inoperable. This condition existed from 1600 on December 28, 1989, until 0225 on December 31, 1990, when the calibrations of channel N-44 were completed.

These calibrations, as anticipated, did correct the spurious alarm, so no actual flux tilt had occurred.

Corrective Ste s Taken to Avoid Further Violations:

Personnel who were involved with the QPTR calculations and who made the operability determination on the QPTR alarm were counseled.

Additional guidance will be included in the QPTR annunciator response procedure to indicate the appropriate actions to take to comply with TS requirements.

This event will be reviewed by licensed operators.

Date When Full Com liance Will Be Achieved:

Review of the event by licensed operators will be completed by May 7, 1990.

Procedure changes will be completed by June 1, 1990.

Reference. 'Licensee Event Report 90-002-00 MEM/H0-9000590/3/OSl