ML18010B063

Suppls 930107 Response to Violations Noted in Insp Rept 50-400/92-27.Corrective Actions:Local EDG Operator Implemented Annunciator Panel Procedure APP-DGP-H-2 & Clearance Procedure AP-020 Will Be Revised

ML18010B063
Person / Time
Site:	Harris
Issue date:	03/12/1993
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-806 HO-930073, NUDOCS 9303180079
Download: ML18010B063 (5)

Text

ACCELERATED DOCUMENT DISTRIBUTIONSYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9303180079 DOC.DATE: 93/03/12 NOTARIZED: NO ACYL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION VAUGHN,G.E.

Carolina Power

& Light Co.

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

SUBJECT:

Suppls 930107 response to violations noted in Insp Rept 50-400/92-27.Correvtive actions:local EDG operator implemented Annunciator Panel Procedire APP-DGP-H-2 Clearance Procedure AP-020 will be revised.

DISTRIBUTION CODE:

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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed.

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D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEl CONTACI'HEDOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED(

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Carolina Power & Light Company P.O. Box t65 ~ New Hiil, NC 27562 G.E. VAUGHN Vice President Hania Nuctear Ptant MAR t 2

l995 Letter Number:

HO-930073 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 NRC-806 Gentlemen:

SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 SUPPLEMENTARY REPLY TO A NOTICE OF VIOLATION As stated j.n Carolina Power and Light Company's January 7, 1993, reply to, Notice of Violation 400/92-27-02, the attached:supplementary reply is hereby submitted which addresses corrective steps taken to avoid further violations.

It is'considered that the corrective actions taken/planned are satisfactory for resolution of the violation.

Thank you for your consideration in this matter.

G.

E. Vaughn Vice President Harris Nuclear Plant MGW:kls Attachment I

cc:

Mr. S.

D. Ebneter (NRC-RII)

Mr. N. B. Le (NRC-NRR)

Mr. J.

E. Tedrow (NRC-SHNPP)

MEM/HO-930073/1/OS(

P P P q 9

=eti303i80079 9303i2 PDR ADOCK 05000400 Q

PDR

Attachment to 'NRC-806 SUPPLEMENTARY-REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/92-27 VIOLATION 400 92-27-02 Re orted Violation:

Technical Specification 6.8.1.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, Clearan'ce Procedure, Step 5.7.1 requires that ground devices installed for wo'rk 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.

Surveillance procedure MST-M0011,'mergency 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.

3 On November 12, 1992, while returning penetration M-7 to service, drain valves,lCS-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 the 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 1A-SA Emergency Diesel Generator (EDG), and were added to clearance 0 OP-92-1054 without the knowledge of the MEM/HO-930073/2/OS1

Attachment to NRC-806 SUPPLEMENTARY 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, 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)

Operators inadvertently failed to restore the proper 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)

While performing MST-M0011, mechanics weie 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, 1A-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-930073/3/OS1

Attachment to NRC-806 SUPPLEMENTARY REPLY TO A'OTICE 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.

The responsible operations personnel were counseled regarding this incident.

(Example 3)

The cylinder petcocks were shut as soon as the condition was discovered.

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 1)

AP-020 (Clearance Procedure) will.be revised to make it clear who the clearance holders are and what their responsibilities are regarding the status of work being performed under the clearance.

The revision will provide for a better interface with AP-024 (Grounding Device Control) by providing a

separate signature blank for removal of grounds.

(Example 1 and 2)

Plant Management will express expectations for adherence to clearance procedures to appropriate plant personnel through site safety meetings.

Expectations regarding clearances willbe expressed to contractors during initial training and retraining.

(Example 3)

Procedure SPP-0025 Rev.

0, Emergency Diesel Generator Barring Proceduie was approved on February 25, 1993 to provide detailed instructions to maintenance personnel for barring of the Emergency Diesel Generator Diesel Engine.

The Manager Maintenance issued a

memorandum to first line supervisors

.instructing personnel that, until procedural guidance was implemented, they would obtain support from the Operations group whenever their procedures called for one of the diesels to be barred.

This interim instruction is no longer required with the implementation of procedure SPP-0025, Rev.

0.

Date When Full Com liance Will Be Achieved The corrective actions as stated above will be completed by June 1,

1993.

MEM/HO-930073/4/Osl