ML18010A969
| ML18010A969 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/07/1993 |
| From: | Vaughn G CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-794 HO-920181, NUDOCS 9301130012 | |
| Download: ML18010A969 (6) | |
Text
A.CCEI.ERAT DOCUVlENT DIST VTION SYSTEM REGULAT INFORMATION DISTRIBUTIO STEM (RIDS).
ACCESSION NBR:9301130012 DOC.DATE: 93/01/07 NOTARIZED: NO FACIL:50-$00 Shearon Harris Nuclear Power Plant, Unit 1, Carolina UTH.NUMB AUTHOR AFFILIATION GHNiG.E.
Carolina Power
& Light Co.
ECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 921208 ltr re violations noted in Insp Rept
. 50-400/92-27.Corrective actions:work requests written to bridge a meggar generator
& to investigate cause of trip 6 maint procedures re barring of DG will be reviewed.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed.
DOCKET 05000400 05000400 RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DEIB AEOD/TTC NRR MORISSEAUiD NRR/DLPQ/LPEB10
. NRR/DREP/PEPB9H-NRR/PMAS/ILRB12 NUDOCS-ABSTRACT OGC/HDS1 RGN2 FILE 01 EXTERNAL: EGSG/BRYCEiJ.H.
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RECIPIENT ID CODE/NAME LE,N AEOD AEOD/DSP/TPAB DEDRO NRR/DLPQ/LHFBPT
'RR/DOEA/OEAB NRR/PMAS/ILPB NRR/PMAS/PDTSB OE DI EG FI E 02 NRC PDR COPIES LTTR ENCL 1
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1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL. NUMBER OF COPIES REQUIRED:
LTTR 25 ENCL 25
to Carolina Power 8 Light Company Harris Nuclear Plant P. O. Box 16S New Hill,North Carolina 27562 O. E VAUGHN Vice President Harris Nuclear Plant JAN 7
]99'etter Number:
HO-920181 Document Control Desk United States Nuclear Regulatory Commiss'ion Washington, DC 20555 NRC-794'HEARON 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 December 8,
1992, referring to NRC Inspection '
Report RII:
50-400/92-27, the attached is Carolina Power and Light Company's reply to the notice of violation identified in Enclosure l.
1 It is considered that the corrective actions taken/planned are satisfactory for resolution of the violat:ion.'hank you for your consideration in this matter.
Vice President Harris Nuclear Plant MGW:dmw
~
Attachment 12000'c:
Mr. S.
D. Ebneter (NRC-RII)
Mr. N., B. Le (NRC-NRR)
Mr. J.
E. Tedrow (NRC-SHNPP)
~~~ 'tt<-o>O'i81/1/OS1 9301l30012 930i07 PDR ADOCK 05000400 8
Attachment to NRC-794
'EPLY TO' NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/92-27 VIOLATION 400 92 27-02 Re orted Violation:
Technical Specification 6.8.l.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, paragraphs l.c and 8, require procedures for the conduct of equipment control and surveillance testing activities.
Administrative procedure AP-020, Clearance Procedure, Step 5.7.1 requires that.
ground devices installed for work be removed following maintenance completion.
Surveillance procedure EST-212, Type C Local Leak Rate
- Tests, Attachment 1,
Step 6.1 specifies the steps necessary to return penetration M-7 to service and requires that drain valves be closed prior to opening the isolation valve to refill the system.
e Surveillance procedure MST-M0011, Emergency Diesel Generator Crankshaft Web Deflection and Thrust Clearance
- Check, Steps 7.1.3 and 7.2.2 specify that the engine be barred over prior to taking measurements.
Contrary to the above, l.
On November 6,
- 1992, ground devices were not properly removed from the "A" Emergency Diesel Generator following maintenance which resulted in an automatic generator differential trip upon engine startup.
2.
On November 12, 1992, while returning penetration'-7 to service, drain valves 1CS-12 and 1CS-13 were not closed prior to opening isolation valve 1CS-16 which spilled approximately 50 gallons of contaminated liquid in the auxiliary building.
On November 8,
- 1992, procedure MST-M0011 was found to be inadequate in that it failed to specify appropriate steps to open and reclose cylinder petcocks following engine barring.
This resulted in a subsequent start of'he engine with the cylinder petcocks open.
This is a Severity Level IV violation (Supplement I).
Denial or Admission:
The violation is admitted.
Reason for the Violation:
(Example 1)
Ground straps were placed on the output of the lA-SA Emergency Diesel Generator (EDG), and were added to clearance ¹ OP-92-1054 without the knowledge of the MEM/HO-920181/2/OS1
Attachment to NRC-794 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/92-27 clearance holder.
This indicates a possible weakness in the interface between AP-020 (Clearance Procedure) and AP-024 (Grounding Device Control).
The ground straps were properly installed and tagged, but were located inside a" closed electrical cabinet which is not normally inspected-following routine mechanical maintenance.
With work completed and no knowledge of the install'ed grounds, the clearance holder signed off the clearance as having "All work complete with electrical grounds
. removed".
On subsequent
- startup, the EDG immediately tripped on generator differential.
(Example 2)
I'perators inadvertently failed to restore the pioper system valve lineup while removing a clearance.
As a result, approximately 50 gallons of, Reactor Coolant System (RCS) water was leaked into the Reactor Auxiliary Building (RAB) through an open drain line in the letdown portion of the Chemical and Volume Control System (CVCS).
The reactor was shutdown for refueling at the time.
(Example 3) r While performing,MST-MOOll, mechanics were instructed to open the EDG cylinder petcocks during a barring step.
The barring instruction in MST-M0011 gives no guidance as to the desired position of the cylinder petcocks at the completion of the
- MST, and they were left open.
The condition of the petcocks was not adequately communicated to operations personnel.
OST-1013, lA-SA Emergency Diesel Generator Operability Test, Monthly Interval Modes 1-2-3-4-5-6, was begun shortly. after MST-M0011 was completed.
- Since the diesel had been run within the previous four hours, a barring step in OST-1013 which would have verified proper position of the petcocks was NA'd.
As a result, the diesel was started with the cylinder petcocks open.
Reasons for this incident were:
- 1) MST-M0011 gives inadequate instruction for the diesel barring step, and 2) there was inadequate communication between maintenance and operations personnel.
Corrective,Ste s Taken and Results Achieved:
(Example 1)
The local EDG operator implemented Annunciator Panel Procedure, APP-DGP-H-2 due to the Generator Differential Protection Trip alarm and verified that all automatic actions required had occurred.
He then. placed the diesel in maintenance mode, and the diesel was declared inoperable.
Work requests 92-AQWT1 and 92-AQWT2 were written to bridge and meggar the generator and to investigate the cause of the trip.
The 87-DG relay was tested satisfactory.
During the investigation, the ground straps were discovered and removed.
MEM/HO-920181/3/Osl
Attachment to NRC-794 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION-REPORT NO. 50-400/92-27 (Example 2)
Upon notification by Health Physics personnel of a spill in the RAB, control room operators promptly isolated Residual Heat" Removal (RHR) letdown and dispatched operators to investigate.
The drain line was isolated and RHR letdown was restored.
(Example 3)
The cylinder petcocks were shut as soon -as the condition was di.scovered.
The control room was notified, and the diesel was shutdown per OP-155, Diesel Generator Emergency Power System.
After performing appropriate checks per, OP-155
-Attachment 8, Emergency Diesel Generator Engine Barring Checklist, the diesel was restarted and OST-1013 was satisfactorily completed.
Copies of the Adverse Condition Reports (ACRs) documenting the three examples of the violation described above have been distributed to the operating shifts for review.
Corrective Ste s Taken to Avoid Further Violations:
\\
~
~
~
~
(Example 3)
Maintenance procedures that involve barring of the diesel generators will be reviewed.'
The level of detail for diesel barring instruction will be made consistent with OP-155 Attachment 8.
The Manager
- Maintenance has issued a
memorandum to first line supervisors'nstructing personnel that, until these procedure revisions are implemented, they will obtain support from the Operations group whenever their procedures call for one of the diesels to be barred.
(Examples 1,
2, and 3)
The three violation examples-have been iricluded along with a number of-other
- ACRs, under ACR 92-562; which will investigate a
perceive'd adverse trend pertaining to clearance related ACRs.
A root cause analysis will be performed by members of the Plant Management
- Section, and appropriate corrective actions willbe recommended.
The scheduled completion date for the root cause analysis is February 26, 1993.
Date'hen Full Com lienee Will Be Achieved:
The review of and revision to maintenance procedures that involve diesel generators will be completed by March 5, 1993.
barring of the A supplement to this response willbe submitted by March 13, 1993, results of the root cause analysis and schedule for implementing actions to prevent further clearance related violations.
describing the the corrective MEM/HO-920181/4/OS1