ML18009A562

Responds to NRC 900504 Ltr Re Violations Noted in Insp Rept 50-400/90-06.Corrective Actions:Procedures OST-1008 & OST-1108 Revised to Delete Stroke Testing of Valve 1ST-359 on Quarterly Basis

ML18009A562
Person / Time
Site:	Harris
Issue date:	05/30/1990
From:	Richey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HO-900095-(O), NUDOCS 9006050048
Download: ML18009A562 (7)

Text

ACCELERATED DISTMBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

SSION NBR:9006050048 DOC.DATE: 90/05/30 NOTARIZED: NO DOCKET IL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 UTH.NAME AUTHOR AFFILIATION RICHEY,R.B. Carolina Power 6 Light Co.

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

SUBJECT:

Responds to NRC 900504 50-400/90-06.

ltr re violations noted in Insp Rept SIZE: D DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL TITLE: General'(50 Dkt)-Insp Rept/Notice of Violation Response S

NOTES:Application for permit renewal filed. o5ooo4oo

/

RECIPIENT COPIES RECIPIENT COPIES A ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 PD 1 1 BECKER,D 1 1 D',

INTERNAL: ACRS 2 2 AEOD 1 1 D AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO NRR SHANKMAN,S NRR/DOEA DIR 11 1,

1 1

1 1

1 NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9 D 1

1 1

1 1

1 NRR/DRIS/DIR 1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 1 1 OGC/HDS1 1 1 LE 02 1 1 RGN2 FILE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 D

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

Carolina Power 8 Ught Coinpany P. O. Box 165 ~ New Hill N. C. 27562

~

R. B. RICHEY Manager Harrla Nuclear Prelect MAY B 0 1990 Letter Number: HO-900095 (0)

Document Control Desk NRC-714 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 May 4, 1990, referring to I.E.

Report RII: 50-400/90-06, the attached is Carolina Power and Light Company's reply to violation "A" identified in Enclosure l.

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, Manag r Harris Nuclear Proj ct MGW:msb Enclosure cc'. Mr. R. A. Becker (NRC)

Mr. S. D. Ebneter (NRC RII)

Mr. J. E. Tedrow (NRC SHNPP) 5'00' 0 00qe 900

~I OC'i 0 i0r>0gi< g PDC 4lEM H0-9000950/1/OS1

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ATTACHMENT TO CP&L LETTER OF RESPONSE TO NRC I.E. REPORT RII: 50-400 90-06 VIOLATION "A" Re orted Violation:

Technical Specification 4.4.6.2.2.d requires that with the plant operating at po~er, leakage by a reactor coolant system pressure isolation valve shall be verified to be within its limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation.

Contrary to the above, during power operation from March 1987 through February 13, 1990, reactor coolant system pressure isolation valve 1SI-359 has been manually actuated on approximately 13 different occasions without the subsequent performance of leakage verificat'ions.

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

Denial or Admission and Reason for the Violation.'he violation is correct as stated. 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 limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valves. Safety Injection Valve 1SI-359, Hot Leg Recirculation Valve, is included in this table.

On February 13, 1990, Operations Surveillance Test (OST)-1008, 1A-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 the Inservice Inspection Program (ISI)-203, ASME Section XI 'Pump and Valve Program Plan. On April 5, 1990, during an Inservice Inspection revie~ of the stroke times for the RHR valves, it was discovered that valve 1SI-359 was required to be leak tested following the stroke time testing. However, OST-1008 did not identify the requirement for leak testing.

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 Interval, as required by TSs. However, the valve has 'uarterly been successfully leak tested previously on December 16, 1989, and October 10, 1988, to satisfy the requirements of Surveillance 4.4.6.2.2.b.

MEM/HO-9000950/2/OS1

Denial or Admission and Reason for the Violation.'(contiaued)

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 in 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 included the steps for cycling 1SI-359. Subsequently, in March 1989, 1SI-203 was revised to require quarterly testing.

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 test. 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.

Corrective Ste s Taken and Results Achieved:

On April 5, 1990, at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> valve 1SI-359 was declared inoperable, and the plant entered Limiting Condition of Operation (LCO) action 3.4.6.2.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 was declared operable at 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br />.

Corrective Ste s Taken to Prevent Further Violations:

The following corrective actions will be implemented to prevent further violations.

1. OST-1008 and OST-1108 will be 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.

MEM/HO-9000950/3/OSl

l) 0

Corrective Ste s Taken to Prevent Further Violations (continued)

4. ISI-203 was revised on April 17, 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'elated" TS surveillance matrix will be reviewed for any similar problems.

Date When Full Com liance Will Be Achieved The corrective actions stated above are expected to be completed by July 13, 1990.

HEN/HO-9000950/4/OS1