ML18010A334
| ML18010A334 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/25/1991 |
| From: | Richey R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-759 HO-910105-(O), NUDOCS 9107300118 | |
| Download: ML18010A334 (4) | |
Text
.. ACCELERATED DISTRIBUTION DEMONSTPMTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9107300118 DOC.DATE: 91/07/25 NOTARIZED: NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION RICHEY,R.B.
Consumers Power Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 910627 ltr re violations noted in Insp Rept 50-400/91-13.Corrective actions:instructions provided to operators to use main feedwater to feed steam generators whenever practical.
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TITLE: General (50 Dkt) -Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed.
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RE FILE 02 EXTERNAL: EG&G/BRYCE,J. H.
NSIC RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DST/DIR SE2 NRR/PMAS/ILRB12 COPIES LTTR ENCL 1
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RECIPIENT ID CODE/NAME MOZAFARI,B.
AEOD AEOD/TPAB NRR MORISSEAUiD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/OTSB 11E22 NUDOCS-ABSTRACT OGC/HDS1 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1
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NOTE TO ALL"RIDS" RECIPIENTS:
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PLEASE HELP US TO REDUCE iVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
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LTTR 24 ENCL 24
Carolina Power & Ljght Company P.O. Box 165 ~ New Hill,N,C. 27562 R. B. RICHEY Vice President Harris Nuclear Project JUL 2 5
)99)
Letter Number.'O-910105 (0)
Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20SSS NRC-759 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen.'n reference to your letter of June 27, 1991, referring to I.E.
Report RII:
50-400/91-13, the attached is Carolina Power and Light Company's reply to the violation identified in Enclosure 1.
It is considered that the corrective actions taken are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Very truly yours, Vice President Harris Nuclear Project MGW:mbr Attachment cc.'s.
B. L. Mozafari (NRC)
Mr. S.
D. Ebneter (NRC RII)
Mr. J.
E. Tedrow (NRC - SHNPP) 910730011c; 9l07 Poli ADOCl'5000400 g
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MEM/HO-9101050/1/OS1
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Attachment to CPKL Letter of Res onse to NRC I. E.
Re ort RII:
50-400/91-13 Violation Re orted Violation'.
Technical Specification (TS) Limiting Condition for Operation 3.7.1.2 requires three auxiliary feedwater pumps and associated flow paths to be operable.
Action b of this specification requires the plant to proceed from Hot Standby to Hot Shutdown within six hours if two auxiliary feedwater pump flow paths are inoperable.
Contrary to the
- above, from approximately ll:18 a.m.
5:22 p.m.
on May 19,
- 1991, and 12:14 a.m.
6:47 a.m.
on May 20,
- 1991, the plant was operated in the Hot Standby mode with two inoperable auxiliary feedwater pump flow paths.
This is a Severity Level IV violation (Supplement I).
Denial or Admission and Reason for the Violation'.
The violation is denied.
On May 20,
- 1991, the plant was in MODE 3 preparing for plant startup.
Steam generator levels were being maintained by feeding with one of the motor-driven auxiliary feedwater pumps.
To perform this feeding without causing a plant cooldown, flow was provided to only one steam generator at a time.
The use of the Auxiliary Feedwater System to feed the steam generators during plant startup is described in the plant FSAR and had been previously reviewed by the NRC during plant licensing.
A concern was identified by the NRC Resident Inspector with whether the way auxiliary feedwater was being used resulted in two auxiliary feedwater pumps being inoperable.
The Auxiliary Feedwater System is required operable in MODES 1 - 3 by Technical Specification 3.7.1.2.
The Auxiliary Feedwater System is designed to have all motor-operated and electro-hydraulic valves full open when it is aligned for emergency standby operation.
The steam generators are isolated from the auxiliary feedwater pumps by check valves that open to allow forward flow when the Auxiliary Feedwater System is actuated.
During plant start-up the requirement to have full Auxiliary Feedwater flow available is not necessary as the decay heat present to be removed is minimal.
If Auxiliary Feedwater did actuate during plant startup, one of the operators immediate actions in accordance with the plant Emergency Operating Procedures would be to throttle or secure flow to prevent overfilling the steam generators.
Technical Specification Surveillance Requirement 4.7.1.2.1.a.3 specifies that each valve in the flow path shall be in its correct position.
Feeding the steam generators during plant startup requires flow to be isolated to two steam generators and flow to be throttled to the third steam generator during the filling process.
This is done under operator control as necessary to maintain steam generator level.
The use of the Auxiliary Feedwater System for plant startup was the original design of the system.
The NRC reviewed and concurred with this design as disc'ussed in Section 10.4.9 of the Shearon Harris Safety Evaluation Report (SER).
In addition, Supplement 4 of the Shearon Harris SER specifically credits use of the Auxiliary Feedwater System MEM/HO-9101050/2/OS1
Denial or Admission and Reason for the Violation: (continued) during plant startup as a basis for accepting the draft Auxiliary Feedwater System Technical Specification.
It has been determined the Auxiliary Feedwater System was being used as originally
- designed, reviewed and accepted.
The use of the Auxiliary Feedwater System for startup has minimal safety significance, as flow would be throttled or secured immediately by the operators during this mode to prevent steam generator overfill if the system actuated.
It is agreed that Technical Specification 3.7.1.2 does not clearly allow this mode of operation, therefore a
Technical Specification change will be submitted to clarify that in MODES 2 and 3 flow can be throttled under operator control as required to maintain steam generator levels.
Interim corrective actions were implemented as a result of this'dentified problem.
Instructions were provided to the operators to use main feedwater to feed the steam generators during MODES 1
3 whenever practical.
Auxiliary feedwater pumps may still be used in an off-normal situation provided they are declared inoperable whenever associated valves are not fully open.
If the Auxiliary Feedwater System is used to feed the steam generators, the auxiliary feedwater pumps are returned to operable when the system is realigned to its emergency standby lineup with all valves fully opened.
This places the plant into a
six hour Limiting Condition of Operation each time the Auxiliary Feedwater System is used to feed the steam generators during plant startup.
These instructions on system operability were included into the following plant procedures on the dates indicated:
GP-002 Normal Plant Heatup from Cold Solid to Hot Subcritical July 12, 1991 GP-004 GP-006 Reactor Startup (Mode 3 to Mode 2)
Normal Plant Shutdown from Power Operation to Hot Standby (Mode 1 to Mode 3)
June 07, 1991 June 07, 1991 GP-007 Normal Plant Cooldown (Mode 3 to Mode 5)
July 12, 1991 OP-137 Auxiliary Feedwater System June 07, 1991 A Technical Specification Change Request will be of the Auxiliary Feedwater System for feeding MODES 2 and 3.
Upon approval of this
- request, will be revised as appropriate.
This Technical will be submitted by December 1,
1991.
submitted to clarify the use the steam generators'uring the procedures listed above Specification Change Request MEM/HO-9101050/3/OS1