Text

LER 90-011-00:on 900405,Tech Spec Violation Occurred Due to Missed Tests on Valve.Caused by Procedural Deficiencies. Procedures Revised & Plant Personnel trained.W/900507 Ltr
	ML18009A520
Person / Time
Site:	Harris
Issue date:	05/07/1990
From:	Richey R, Schwabenbauer; CAROLINA POWER & LIGHT CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	HO-900089-(O), LER-90-011, LER-90-11, NUDOCS 9005100230
	Download: ML18009A520 (6)
	v • d • e

ACCELERATED UTION DEMONSTlRATION SYSTEM f

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9005100230 DOC.DATE: 90/05/07 NOTARIZED: NO DOCKET g FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION SCHWABENBAUER Carolina Power 6 Light Co.

RICHEY,R.B. Carolina Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 90-011-00:on 900405,TS violation due to missed leakage tests on valve caused by procedural deficiencies.

W/9 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.

NOTES:Application for permit renewal filed. 05000400 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: ACNW 2 2 ACRS 2 2 AEOD/DOA 1 1 AEOD/DS P/TPAB 1 1 AEOD/ROAB/DSP 2 2 DEDRO 1 1 NRR/DET/ECMB 9H 1 1 NRR/DET/EMEB9H3 1 1 NRR/DLPQ/LHFB11 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB11 1 1 NRR/DREP/PRPB11 2 2 NRR/DST/SELB SD 1 1 NRR/DST/SICB 7E 1 1 1 1 NRR/DST/SRXB SE 1 1 1 1 RES/DSIR/EIB 1 1 RGN2 FILE 01 1 1 EXTERNAL: EG&G STUART,V.A 4 4 L ST LOBBY WARD 1 1 LPDR 1 1 NRC PDR 1 1 NSIC MAYS,G 1 1 NSIC MURPHYIG A~ 1 1 NUDOCS FULL TXT 1 1 NOTE TO ALL "RIDS" RECIPIENIS:

P~ HELP US TO REDUCE WASIZl CONTACT THE DOCUMENI'ONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENIS YOU DON'T NEEDI FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED'TTR 36 'ENCL 36 PI

Carolina Power jt Ught Company P. O. 8ox 165 ~ New Hill, N. C. 27562 MAY 0 7 1990 R. B. RICHEY Manager Harris Nuclear Project Letter Number'. HO-900089 (0)

U.S. Nuclear Regulatory Commission ATTN: NRC Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NOo 50-400 LICENSE NO. NPF-63 LICENSEE EVENT REPORT 90-011-00'entlemen:

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, Mana r Harris Nuclear Pro ect RBR:dgr Enclosure

'cc: Mr'. A. Becker (NRR)

Mr. S. D. Ebneter (NRC RII)

Mr. J. E. Tedrow (NRC SHNPP) 900 100230 900507 PDR ADOCK 0500040t7 S PDC

) s MEM/LER-90-011/1/OS1

NRC FORM 366 US, NUCLEAR AEGULATORY COMMISSION APPAOVEO OMS NO,3)504)104 (64)9) EXPIRES: 4/30/92 iMATED SUROEN PER RESPONSE TO COMPLY WTH THiS FORMATION COLLECTION REGUESTr 50.0 HRS. FORWARD LICENSEE EVENT REPORT ILER) COMMENTS AKGAAOiNG SUROEN ESTIMATE TO THE RECOADS ANO REPORTS MANAGEMENT BRANCH (Pe)30). U.S. NUCLEAR REGULATORY COMMISSION. WASHINGTON, OC 20555. ANO TO THE PAPERWORK REDUCTION PAO/ECT 131500104). OFFICE OF MANAGEMENTANO BUDGET. WASHINGTON, OC 20503.

FACILITY NAME (I) DOCKET NUMbER Il) PA E Ti'TLE (4)

SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 050004001OF04 TECHNICAL SPECIFICATION VIOLATION DUE TO MISSED LEAKAGE TESTS ON VALVE CAUSED BY PROCEDURAL DEFICIENCIES EVENT DATE (SI LER NUMSER (4) REPORT OA'TE (7I OTHER FACILITIES INVOLVED (4)

YEAR YEAR 4 E 0 U 4 N I' A L:~M AEYS~ MONTH DAY YEAR FACILITY NAMES DOCKET NUMSKRISI MONTH DAY N UM 4 E ti h~w NUM44/l N/A 0 5 0 0 0 0 4 0 5 9 0 9 0 0 1 1 0 00 507 9 0 0 5 0 0 0 THIS REPORT IS SUSMITTKD tUASUANT TO THE RLQUIREMENTS OF 10 CFR $ : /Chas one ot mots ol rhr looowintl (11)

OPERATING MODE (4) lb.402(4I 20.406 (c I 50.7l(s)(2)(ir) 73.7101)

POWER 20.405 (e) (I ) I I) SOW( ~ I(il 50.73(s))2)/r) 7l.71(c)

LEYEL 50.73(s ) (2) /rii) OTHKA ISprcity in i<<srrrr<<t 1 0 0 20.405(s) (1)(ii) 50.34 (<<) (2 I Ortow em/in Teer, HIIC Form 20A04( ~ I (I I (/4) 60.73I ~ )(2)II) 50.73(s)(2) (riii)(A) 344AI 20AOS(s)(1) (Ir) 50.73(s) (2) (Ii) 50.73(<<I (2) (r)4) (SI 20.406 Is) (I ) (r) 50.7 3 (s) (2 I D)I I 50.73( ~ ) (2) I<<)

LICENSEE CONTACT FOII THIS LER (12)

NAME TEI.EPHONE NUMSER AREA CODE RICHARD SCHWABENBAUER REGULATORY COMPLIANCE TECHNICIAN 91 936 2- 266 9 COMPLETE ONE LINK FOR EACH COMPONENT FAILVAE OESCRISKO IN THIS REtORT (Ili MANUFAC. AEPDATASLE MANVFAC KPOATASL CAUSE SYSTEM COMPONENT TVRER TO NPRDS CAUSE SYSTF.M COMPONENT TVAER TO NPROS P(($ 1 $/Ig P

IIIIIeIQybi CN:A&irk OM~

SVttLEMENTAL RKPORT EXPECTED (14) MONTH DAY YEAR EXPECTED SUSMISSION DATE (15I YES Illyrr, coinplerr tXPtCTKD SIISMISSIOH DATt/ X NO ASSTRACT ILimlr ro /400 rpeca, l.r.. <<pote<</merely tltrern Vntrreprce ryprrwtrrrn /ina/ (141 Abstract:

The plant wns operating in Mode I, POWER OPERATION, at 100 percent reactor power on April 5, 1990.

Technical Specifications (TS) 4,4.6,2,2.d requires that Reactor Coolant System Pressure Isolation valves specified in Table 3.4-1 shall be demonstr ated operable by verifying leakage to be within its limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following valve actuation due to automatic or manual ection or flow through the valve.

Ouring a review of a quarter(y Survei)l"ance test by plant personnel, if wUS discovered that the tes.

stroked valve ISI-359, but no leak test was performed, At 1300 hours0.015 days 0.361 hours 0.00215 weeks 4.9465e-4 months the valve was declared inoperable due to the missed leakage test, The valve was then leak tested using the appropriate procedure and declared operable at 1630 hours0.0189 days 0.453 hours 0.0027 weeks 6.20215e-4 months .

The cause of the event is procedural deficiency, The requirement to leak test the valve was not included in the surveillance procedures that stroked the valve, Corrective actions for the event include appropriate procedure revisions and training of plant personnel, In addition, a change to TS Table 3.4-1 to exclude valve ISI-359 from quarterly leak testing will be submitted, There were no safety consequences as a result of this event as subsequent leak testing demonstrated that leakage was within the TS acceptance criteria ~ ~

This 'event is being reported in accordance with IOCI:R50 ~ 73 (a) (2) (i ) (8) as a Technical Specification violation NRC Fono 364 (5 49)

NRC FOAM 355A ILS. NUCLEAR REGULATORY COMMISSION API'ROVED 0MB NO. 31500>OS (BJ>9>

EXP I RES I S/30/92 MATEO BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE E ENT REPORT ILER) FORMATION COLLECTION REQUEST( 500 HAS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (P030>. U,S. NUCLEAR REGULATORY COMMISSION. WASHINGTON, OC 205M, AND TO THE PAPERWORK AEOUCTION PROJECT (3I500104), OFFICE OF MANAGEMENTANO BUDGET, WASHINGTON. DC 20503.

FACILITYNAME (I) DOCKET NUMBER (2) LER NUMBER (5) PAGE (3)

YEAR SEQUENTIAL REVISION NVM ER NUMBER SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 TEXT /I/mom JIMEV /s /PqvPNL IIJP RI/~ H/>C %%dmI 35SAB/ (>2) 0500040090 0 1 1 00 02OF0 4 The plant was operating in Mode 1, POWER OPERATION, at 100 percent reactor power on April 5, 1990. Technical Specification (TS) 4.4.6.2.2.d requires that Reactor Coolant System Pressure Isolation Valves specified in Table 3.4-1 shall be demonstrated operable by verifying leakage to be within its following valve actuation due to automatic Safety Injection Valve

'r manual action 1SI-359, limit or within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months flow through the Recirculation valves. A motor operated Hot Leg Valve, is included in this table.

On February 13, 1990, Operations Surveillance Test (OST)-1008, LA-SA Residual Heat Removal (RHR) Pump Operability Quarterly Interval, was performed. This test stroked valve 1SI-359 along with several other valves. The valve cycling in OST-1008 is required by Inservice Inspection Program (ISI)-203, ASME Section XI Pump and Valve Program PLan. On April 5, 1990, during an Inservice Inspection review of the stroke times for the RHR valves, it was discovered that valve LSI-359 was required to be leak tested following the stroke time testing. However, OST-1008 did not identify the requirement for leak testing. At 1300 hours0.015 days 0.361 hours 0.00215 weeks 4.9465e-4 months the valve was declared inoperable, and the plant entered Limiting Condition of Operation (LCO) action'.4.6.2.c. The valve was then leak tested utilizing OST-1506, Reactor Coolant System Isolation Valve Leak Test. OST-1506 was completed satisfactoriLy and the valve declared operable at 1630 hours0.0189 days 0.453 hours 0.0027 weeks 6.20215e-4 months .

A review of previously performed OSTs has been completed and revealed that valve 1SI-359 has never been leak tested following the performance of OST-1008, or OST-1108, RHR Pump Operability Quarterly Interval, as required by TSs. However, the valve has been successful.ly Leak tested previously on December 16, 1989, 'and October 10, 1988, to satisfy the requirements of Surveillance 4.4.6 '.2.b.

Cause:

The cause of the event is inadequate procedural controls for identifying when the particular surveillance was required., When the initial Inservice Testing Program for Pumps and Valves was developed, the procedure (ISI-203) did not require the cycling of this valve during routine plant operations. An ASME Section XI Cold Shutdown justification was used to require valve cycling only when the plant was in Cold Shutdown if the test had not been completed .'n the previous quarter. This approach was approved by the NRC in the acceptance of the originaL version of the Inservice Valve Testing program. Notwithstanding this, OST-1008 and OST-1108 incl.uded the steps for cycling 1SI-359. Subsequently, in March 1989, ISI-203 was revised to require quarterly testing.

NRC FOIRI 35BA (009) ii

NRC FORM SSSA 1609)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION IAS. NUCLEAR REGULATORY COMMISSION t APPROVED 0MB NO. 21500104 F.XPIRESI A/20/92 ESTIMATED BURDEN PER RESPONSF. TO COMPLY WTH THIS INFORMATION COLLECTION REQUEST: 50A) HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS AND REPORTS MANAGEMENTBRANCH IP420), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO IHE PAPERWORK REDUCTION PROJECT IS)500)04). OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20502.

FACILITYNAME I)) DOCKEl'UMBER I2) LER NUMBER (5) PAGE ISI YEAR yr>S BEQUSNTIAL alaOA IIEvlsloN SHEARON HARRIS NUCLEAR PONER PLANT NVMSCII Poa NuMoea UNIT 1 0 5 0 0 0 4 0 0 9 0 0 1 1 0 0 03O" 04 TEXT //lrr>>ro J/>>r>>/1 n//cworL Irao //1/or>>//VRC %%dnIISSSAB/))7)

In the development of the specific OSTs, it was not recognized that the cycling of 1SI-359 would lead to the requirement for a specific leak t st. The need for the leak test was also part of a separate plant matrix covering "event related" surveillances. This matrix listed "event related" surveillances, the procedures which would identify and trigger the performance of the surveillance and the procedure implementing the surveillance. This matrix shows that the need for the leak test surveillance would be initiated only by actuation of the Safety Injection System. The matrix did not recognize that cycling of valve 1SI-359 would occur on a routine basis.

~Anal aia:

There were no safety consequences as a result of this event. Valve 1SI-359 is a motor operated gate valve which is opened during post-Loss of Coolant Accident (LOCA) long term recirculation to provide a means of injecting low head safety injection flow into -the RCS hot legs'n addition to 1SI-359, there are two in-series check valves which protect the RHR system from the higher pressures in the RCS. Technical Specifications include the requirement to leak test at least two of the valves in the interface between the RCS and the RHR system. For check valves and for 1SI-359 there is a requirement to perform the leak test following cycling of the valve or flow through the valve. For the other motor operated valves in Table 3.4-1, the requirement for the leak test following valve cycling is not required.

The purpose of the leak test is to verify that each applicable valve is actually closed and that an imminent inter-system LOCA hazard does not exist. During the development of the Technical Specifications, valve position indication was accepted as a means to provide sufficient assurance that the valve was shut. Therefore, leak testing could be done at a reduced frequency. The plant applied this exception to the RHR suction isolation valves but did not apply this exception to valve 1SI-359. Based on that exception it is concluded that the closed position indication for 1SI-359 and a reduced (18 month) testing frequency provided adequate assurance of isolation of the RHR system from the RCS. The subsequent l.eak test demonstrated that the valve's leakage was within acceptable amounts.

This event is being reported in accordance with 10CFR50.73 (a) (2) (i) (B) as a Technical Specification violation.

There have been no similar events reported.

NRC Form SSSA ISBB)

NRC FORM 355A (5$ 9) t LICENSEE EVENT REPORT ILER)

TEXT CONTINUATION (AS. NUCI.EAR REGULATORY COMMISSION APPROVEO OMS NO. 31500(04 EXPIRESI 4/30/92 IMATEO BURDEN PER AESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION AEOUEST: 50A) HRS. FOAWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE AECOROS ANO REPORTS MANAGEMENT BRANCH (PS30). U.S. NUCLEAR REGULATOAY COMMISSION, WASHINGTON. OC 20555, AND TO 1HE PAPERWORK REDUCTION PROJECT (315001St), OFFICE OF MANAGEMENTANO BUDGET, WASHINGTON, OC 20503.

FACILITYNAME (1) DOCKET NUMBER (2) LEA NUMBER (5) PAGE LS) gv~ sEGUENTIAL AEVrSION SHEARON HARRIS NUCLEAR POWER PLANT VEAA : 2 NUMSSN NUMSSN UNIT 1 0 5 0 0 0 4 0 0 90 01 1 00 04 OF 0 4 TEXT /IImort <<>>oo it trFt)td, Irtt ~ /J)/or>>l HRC %%de 35SA't/ (17)

Corrective Action/Action to Prevent Recurrence:

1. OST-1008 and OST-1108 are being revised to delete the stroke testing of valve 1SI-359 on a quarterly basis.

2. The stroke testing of valve 1SI-359 will be included in OST-1088, Low Head SI Check Valves ISI TEST Quarterly Interval Mode 5. Leak testing will be done prior to entry into Mode 2.

3. Appropriate personnel will be trained on this event.

4. ISI-203 was revised in April 1990, to change the test frequency of valve 1SI-359 to COLD SHUTDOWN, quarterly interval, instead of during plant operation.

5. A change to TS Table 3.4-1 will be submitted to the NRC to change the testing frequency of valve 1SI-359.

6. The "event related" TS surveillance matrix will be reviewed for any similar problems.

EIIS Code Information:

Reactor Coolant System AB Residual Heat Removal BP Valve 1SI-359 BP Safety Injection BQ N AC Form 3BSA ($ 09)

ML18009A520

Text

SUBJECT:

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