ML18009A741
| ML18009A741 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/03/1990 |
| From: | Richey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-734 HO-900186-(O), NUDOCS 9012110138 | |
| Download: ML18009A741 (10) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR:9012110138 DOC.DATE: 90/12/03 NOTARIZED: NO ACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION RICHEY,R.B.
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) 1
SUBJECT:
Responds to NRC 901102 ltr re violations noted in Insp Rept 50-400/90-20 re inoperable waste tank discharge monitor..
DISTRIBUTION CODE: IE01D'OPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vi lation Response NOTES:Application for permit renewal filed.
DOCKET 05000400 D
S 05000400
/
INTERNAL:
RECIPIENT ID CODE/NAME PD2-1 PD ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DRIS/DIR NRR/PMAS/ILRB12 OE DIR LE 02 COPIES LTTR ENCL 1
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RECIPIENT ID CODE/NAME BECKER, D AEOD AEOD/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS1 RGN2 FILE 01 COPIES LTTR ENCL 1
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D EXTERNAL EG&G/BRYCEiZ H NSIC 1
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D NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE iVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO EL!MINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 24 A
D D
1'
Carolina Power & Light Company P.O. Box165 ~ New Hill,N. C.27562 R. B. RICHEY, Vice President Harris Nuclear Project DEC - 3 1990 Letter Number'.
H0-900186 (0)
Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 NRC-734 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO. 50-400 LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen:
In reference to your letter of November 2,
- 1990, referring to I; E.
Report RII:
50"400/90"20, the attached is Carolina Power and Light Company's reply to violation "C"
identified 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 y urs, B. Richey Vice President Harris Nuclear Project RBR:sic Enclosure cc:
Mr. R. A. Becker (NRR)
Mr. S.
D. Ebneter (NRC RII)
Mr. J.:E.
Tedrow (NRC SHNPP)
MEM/H0-9001860/1/Osl 9012110138 901203 PDR ADOCK 05000400 0
ATTACHMENT TO CP&L LETTER OF
RESPONSE
TO NRC I. E.
REPORT RII:
50-400/90-20 Re orted Violation'.
Technical Specification 3.3.3.10 and associated table 3.3"12
- require, in part, that the secondary waste sample tank discharge monitor be operable.
Table 3.3"12, action 36, specifies that if the monitor is inoperable while performing a continuous
- release, then grab samples to detect radioactivity must be collected every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, dependent on the specific activity of the secondary coolant.
V Contrary to the
- above, from approximately September 5
'eptember 13,
- 1990, the secondary waste'ample tank discharge
'onitor (REM-3542) was inoperable and no grab samples were taken and analyzed for radioactivity.
This is a Severity Level IV violation (Supplement I).
Denial or Admission and Reason for the Violation.
The violation is admitted.
On September 12,
- 1990, the plant was operating at full power.
The Secondary Waste Sample
-Tank (SWST) was in continuous release operation with, the SWST Radiation Monitor assumed to be operable.
None of the four (4) remote monitoring locations were experiencing low sample flow annunciator alarms for SWST Radiation Monitor (REM-21WS-3542).
An I&C -Tech was working on the Waste Monitor Tank Radiation Monitor (REM-21WL-3541).
He heard a noise coming from the vicinity of the SWST Radiation Monitor.
He found REM-21WS-3542 was indicating sample flow but the sample pump was not operating.
- There was a loss of sample flow deficiency tag on the monitor and he assumed the monitor was already inoperable.
On September 13;
- 1990, the I&C Tech contacted the Radiation Monitoring System (RMS) Tech to request the work ticket number to repair REM-31WS-3542.
The RMS Tech told the I&C Tech that there were no open work tickets for REM-21WS-3542 and the monitor was operable with sample flow indication present.
After receiving the I&C Tech's observation from the day before, the RMS Tech went down to the monitor to investigate.
He found the monitor sample pump
- switch was in the off. position and the sample flow switch reading 3
gpm (alarm setpoint 1 gpm).
He contacted the Main Control Room and recommended that REM-21WS-3542 be declared inoperable.
At 08:30 on September 13, 1990 the monitor was declared inoperable and Equipment Inoperable Record (EIR) 0 OP-90-7699 was written.
At the time of discovery there was no release being made from the SWST.
Compensatory sampling actions required by TS table 3.3-12 were initiated.
MEM/HO 9001860 j2/OS '.
Denial or Admission and Reason for the -Violation (continued)
The last confirmed date the monitor was known to be functioning properly was on September 5,
1990.
On this date, the monitor went into a loss of sample flow alarm and was restarted at the monitor by a RMS Tech.
Since it cannot be verified that the monitor was operating properly thereafter, it must be concluded that it was malfunctioning during the period between September 5
and September 13, 1990.
It could not be determined who placed the pump switch in the off position.
RMS personnel that were on site during the period between September 5 - 13,
- 1990, were interviewed to determine why and when the pump was turned off.
No one remembers turning the pump to the off position.
- However, had the flow switch been functioning
- properly, as of September 5, 1990, plant personnel would have been alerted to the loss of sample flow via alarms at the Radiation Monitor (RM)-11 computers located in the Main and Radwaste Control
- Rooms, the Radiation Control Office and the Main Control Room computer room.
The presence'f resin in the radiation monitor sample line which resulted in the flow switch sticking on an artificial setting also-contributed to the event.
Resin is being carried over to the Secondary Waste System during Condensate Polisher regeneration.
This resin is reaching the SWST and is being drawn into the sample lines for REM-21WS-3542.
Certain factors contributed to the amount of
'time (September 5 13, 1990) that this abnormal flow condition went unnoticed.
There was a deficiency tag (90-ALJF1) for "loss of sample flow" on the monitor that had not been removed following completion of work for a prior problem on August 22, 1990.
This
- tag, in conjunction with the pump switch being in the OFF position,, would lead someone looking at the monitor to assume that the -monitor was inoperable.
On the other hand, because the flow switch was stuck, the local flow gauge was indicating flow and the operate light on the monitor was lit (indicating no abnormal condition) which would lead people to think the monitor was operating properly.
- However, these conflicting indicators should have been noticed by the RMS Techs during their daily monitor walkdowns and prompted further investigation.
Corrective Actions Taken and Results Achieved:
Compensatory sampling actions required by Technical Specification Table 3.3-12 were initiated at the time of discovery on September 13, 1990.
There is a composite sample collected and analyzed on a weekly basis when continuous releases are made via the SWST.
A review of analyses performed on these samples for the first three (3) weeks of September indicate that no activity was present in
\\
MEM/HO-9001860/3/OS1
I II
Corrective Actions Taken and Results Achieved':
(continued) the SWST effluent during this time.
Therefore it can be concluded that there were no significant safety consequences as a result of this event.
Corrective Actions Taken to Prevent Further Violations.'his event has been reviewed with Radiation Control RMS personnel to stress the importance of knowing the current status of each TS monitor and of verifying their condition during routine TS monitor walkdowns.
This review was completed-on October 24, 1990.
Quarterly aduits of deficiency tags are being performed.
Appropriate retraining of personnel will be conducted if the audit indicates the need.
Plant Change Request (PCR) 1339 will be implemented which adds resin traps/screens to the Condensate Polisher Demineralizers.
Successful completion of this modification will preclude resin from entering the secondary waste system.
Date When Fuel Com liance Will Be-Achieved:
The completion of the deficiency tag quarterly audit and any retraining deemed necessary is expected to be completed by
.December 31",
1990.
Implementation of PCR-1339 is expected to be completed by February 28, 1991.
MBN/HO-9001860/4/OS1