ML18016A250

LER 97-023-00:on 920721,RCS PIV Testing Deficiency Was Noted.Caused by Failure to Consider All Testing Variables During Initial Sp Development.Surveillance Tp OST-1506 Was Revised to Incorporate Correction factor.W/971124 Ltr

ML18016A250
Person / Time
Site:	Harris
Issue date:	11/24/1997
From:	Donahue J, Verrilli M CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-97-212, LER-97-023, LER-97-23, NUDOCS 9712100265
Download: ML18016A250 (8)

Text

CATEGORY 1

- REGULA Y. XNFORMATION.rDISTRIBUTIO 'YSTEM (RIDS) ll ACCESSION NBR :9712100265 . DOC.DATE: 97/11/24 NOTARIZED: NO DOCKET FACXL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NEQIE AUTHOR AFFILIATION 0('T VERRKLLI,M. Carolina .Power & Light Co.

DONAHUE,J.W. Carolina Power R Light Co.

RECIP.NAME "RECIPIENT AFFILIATION SUBJECT,:. LER 97-023-00:on 920721,RCS PIV .testing deficiency-was noted. Caused by failure to consider all testing variables during initial SP development.'Surveillance TP OST-1506 was revised to..incorporate correction "') factor.W/971124 ltr.

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, DISTRIBUTION LISTS CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES'REQUIRED: LTTR 25 ENCL 25

P COL Carolina Power & Light Company.

Harris Nuclear Plant PO Box 165 New Hill NC 27562 I ~ U $

NOV 2 4 1997 ~ ~ 4'

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U.S; Nuclear Regulatory Commission 'Serial: HNP-97-212 ATTN: NRC Document'Control Desk 10CFR50.73 Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO. 50-400 LICENSE NO. NPF-63

'LICENSEE EVENT REPORT 97-023-00 Sir or Madam:

In accordance with 10CFR50.73, the enclosed Licensee Event Report (LER) is submitted. This LER describes a Reactor Coolant System pressure isolation valve testing deficiency that resulted in a violation of Technical Specifications.

Sincerely, J. W. Donahue Director of Site Operations Harris Plant MV Enclosure

+Cd c: Mr. J. B. Brady (HNP Senior-NRC.Resident),-.- ";:,

Mr. L. A. Reyes (NRC Regional Administrator,'Region II)

Mr. V. L. Rooney (NRC - NRR Project Manager) 97i2%00265 97fi24 PDR ADQCK 05000400 8 PDR llllllllllllllllllllllllllllllllllllllll State Road 1134 New Hill NC

U. S. Nuclear Regulatory Commission.

Document Control Desk / HNP-97-212 Page 2 of 2 bcc: D. B. Alexander Mr. R. W. Baylor

's.Mr. T. C. Bell Mr. H. K. Chernoff (RNP)

Mr. B. H. Clark Mr. G. W. Davis Mr. W. J. Dorman (BNP)

~ Ms:. J.:P,. Gawron (BNP)

~ 'I Mr. H.'W. Habermeyer Mr; W."J. Hindman Ms. C. W. Hobbs (HEEC)

Mr. W. D. Johnson Mr. R. M. Erich Mr. M. B. Keef (HEEC)

Ms. W. C. Langston Mr. C. W. Martin (BNP)

Mr. R. D. Martin Mr. J. W. McKay Mr. B. A. Meyer Mr. P. M. Odom (RNP)

Mr. W. R. Robinson Mr. R. F. Saunders Mr. F. E. Strehle Mr. D. L. Tibbitts Mr. C. A. VanDenburgh Mr. R. L. Warden (RNP)

HNP Real Time Training INPO Harris Licensing File Nuclear Records

0 NRC Fl ' 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 3150-0104 H.B5l EXPIRES 04/30/96 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATORY

)NFORMATION COllECTION REOUEST: 500 HRS. REPORTED LESSONS LEARNED ARE LXCENSEE EVENT REPORT (LER) )NCORPORATED )NTO THE UCENSDIG PROCESS ANO FED BACK TO )NDUSTRY.

fORWARO COMMENTS REGAROUIG BURDEN ESTIMATE TO THE )NFORMATION ANO RECORDS MANAGEMENT BRANCH Ire FSSL US. NUCLEAR REGULATORY COMMISSION, (See reverse for required number of WASHUIGTON, OC 205550M). ANO TO THE PAPERWORK REOUCTlON PROJECT IS)50.

digits/characters for each block) 0104L Off)CE OF MANAGEMENT AND BUDGET, WASH)NGTON, DC 205)EL FACIUTY NAME tt) DOCKET NUMBER (2) PAGE f3)

Harris Nuclear Plant Unit-1 50-400 1 OF 2 TITLE f4)

Reactor Coolant System Pressure isolation Valve Testing Deficiency (OST-1506)

EVENT DATE (Sl LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (6)

FACIUTY NAME DOCKET NVMBER OAY ~R SEOUENTIAL NUMBER REYISION NUMBER MONTH DAY YEAR FACIUTY NAME DOCKET NUMBER 21 92 97 023 00 24 97 '5000 OPERATING THIS REPORT)S SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR DI (Check one or. morel (11) 1 MODE (9) 20.2201(b) 20.2203(e) (2)(v) X 50 73(s)(2)(i) 50.73(a)(2)(viiil POWER . 20.2203(s)(1) 20.2203(a) (3) (i) 50.73(a) (2)(ii) 50.73(a)(2)(x)

LEVEL (10) 20.2203(0)(2) (I) 20.2203(a)(3)(ii) 50.73(a) (2)(iii) 73.71 20.2203(e)(2) (ii) 20.2203(e) (4) 50.73(s)(2)(iv) OTHER 20.2203(e)(2) (iii) 50.36(c)(1) 50.73(a) (2](v) Specify in Abstract below or in NRC Form 366A 20.2203(a)(2) (iv) 50.36(c) (2) 50.73(a)(2)(vii)

LICENSEE CONTACT FOR THIS LER t12l NAME TELEPHONE NUMBER One)vee Aree Coee)

Michael Verrilli Sr. Analyst - Licensing (919) 362-2303 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DES CRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTUAER'EPORTABLE REPOATABLE CAUSE SYSTEM COMPONENT MANUFACTURER TO NPAOS TO NPAOS SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR EXPECTED YES SUBMISSION tlf yes, complete EXPECTED SUBMISSION DATE). X No DATE (16)

ABSTRACT (Limitto 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On October 23, 1997, with the plant at approximately 100% power in mode 1, an evaluation was completed by Operations personnel related to a deficiency in the Reactor Coolant System (RCS, EIIS Code:AB-V) Isolation Valve Leak Test Procedure (Operations Surveillance Test, OST-1506). This procedure deficiency involved the calculation used to determine the actual leak rate for the RCS pressure isolation valves being tested. Specifically, a correction factor was not included in the calculation as it should have been to consider the effects of back pressure on the downstream side of the valve being tested and the frictional headloss and elevation differences between the valve and testing rig. With this correction factor not applied, test results for certain valve testing configurations could have been influenced in the non-conservative direction. During the above mentioned Operations evaluation, past testing results were reviewed and the appropriate correction factor was applied. One instance was identified where application of the correction factor resulted in the test results failing to meet the leak rate limit allowed by Technical Specification (TS) 3.4.6. This occurred on July 21, 1992, during leak rate testing for 1SI-346, which is a 10 inch check valve in the low head safety injection header. This condition represents a TS violation for not meeting the required 5 gallon per minute maximum allowed leakage through 1SI-346 and subsequently, not taking the appropriate actions as required by TS.

The leak rate calculation procedural deficiency in OST-1506 and resulting TS violation were caused by the failure to consider all testing variables during initial surveillance procedure development.

Surveillance test procedure OST-1506 was revised to incorporate. the appropriate correction factor to account for head loss and elevation differences durin RCS ressure'isolation valve leak rate testin .

NRC FORM iA ILS. NUCIBLR REGUIATORY COMMISSION F4BSI LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET lER NUMBER IBI PAGE ISI SEOUENTULl REYISION R

NUMBER NUMBER Shearon Harris Nuclear Plant - Unit IIl 50400 2 OF 2 97 =. 023 - 00 TEXT P/ oon ooooo io npviod, ooo od&eoor oapoo ot NRC Fooo SSQI 1111 EVI;NT DESCRIPTION:

On October 23, 1997, with the plant at approximately 100% power in mode 1, an evaluation was completed by Operations personnel related to a deficiency in the Reactor Coolant System (RCS, EIIS Code:AB-V) Isolation Valve Leak Test Procedure (Operations'Sur'veillance Test, OST-1506). This procedure deficiency involved a calculation used to determine the actual leak rate for the RCS.'pressure isolation valves being tested. Specifically, a correction factor was not included in the calculatioii as it should'have been.to consider the effects of back pressure on the downstream side of the valve being tested and the frictional headloss and elevation differences between the valve and testing rig.

With this correction factor not applied, test results for certain valve testing configurations. were influenced in the no'nconservative direction. During the above mentioned Operations evaluation; past testing results were reviewed and the appropriate correction'factor was applied.'ne instance was identified where application of the correction factor resulted in the test results failing to meet the leak rate limit allowed by Technical Specification (TS) 3.4.6.2. This occurred on July 21, 1992, during leak rate testing for 1SI-346, which is a 10 inch check valve in the low head safety injection header. The TS 3.4.6.2 limit for 1SI-346 valve leakage is 5 gallons per minute. Action statement "C" of TS 3.4.6.2 requires isolation of the high pressure portion of the affected system from the low pressure portion within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by the use of two closed manual or deactivated automatic valves, or be in at. least Hot Standby within the next six hours and in Cold Shutdown within the following'30 hoilrs.,Since personnel were not aware that the actual valve leakage exceeded the 5 gallon per minute TS limit, these actions were not taken, therefore this condition represents a TS violation.

The deficient leak rate calculation is contained in one other surveillance test procedure at HNP used to satisfy TS surveillance requirement 4.4.6.2.2. This procedure (Residual Heat Removal System Loop Isolation Valve Leak Test procedure, OST-1507) did not require revision due to the use of a different test configuration'. A comprehensive TS surveillance procedure review project is currently in progress to support HNP's conversion to the new Westinghouse Standard Technical Specifications. This project had not rev'iewed the surveillance procedures associated with TS 3.4.6.2 when this condition was identified. Review of this section of TS and the. corresponding surveillance procedures are currently scheduled to begin in December 1997. Based on the scope of the review process and past results, there is a high level of confidence that the condition reported in this LER would have been identified by the review project.

CAUSE:

The leak rate calculation procedural deficiency in OST-1506 and resulting TS violation was caused by the failure to consider all testing variables during initial surveillance procedure development.

SAFETY SIGNIFICANCE:

There were no actual safety consequences associated with this event. Leak rate limits for RCS pressure isolation valves are set sufficiently low to ensure early detection of possible in-series check valve failures. Based on subsequent satisfactory testing performed on 1SI-346 since the July 1992 test, there is no indication of check valve failure.

This event is being reported per 10CFR50.73(a)(2)(i)(B) as a condition prohibited by TS.

PREVIOUS SIMILAREVENTS:

HNP submitted recent LERs96-002 and 97-021 to report surveillance procedure deficiencies caused by incorrectly interpreting TS testing requirements during initial surveillance test procedure development or during procedure revisions. LER96-002 was the result of HNP's actions toaddress NRC Generic Letter 96-01. A comprehensive TS surveillance procedure review project is currently in progress to support HNP's conversion to the new Westinghouse Standard Technical Specifications.

CORRECTIVE ACTIONS COMPLETED:

1. Surveillance test procedure OST-1506 was revised on October 30, 1997 to incorporate the appropriate correction factor to account for head loss and elevation differences during RCS pressure isolation valve leak rate testing.

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