ML18022A671

Responds to NRC 880622 Ltr Re Violations Noted in Insp Rept 50-400/88-11.Corrective Actions:Operating Procedures Revised to Highlight Need to Consider Operability of Equipment & Personnel Trained

ML18022A671
Person / Time
Site:	Harris
Issue date:	07/20/1988
From:	Watson R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-633 HO-880139-(O), NUDOCS 8807290126
Download: ML18022A671 (9)

Text

AC CELE RATED D1STRIBUT1 ON DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:8807290126 DOC.DATE: 88/07/20 NOTARIZED- NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION WATSON,R.A. Carolina Power & Light Co.

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

SUBJECT:

Responds to NRC 880622 50-400/88-11.

ltr re violations noted in Insp Rept DISTRIBUTION CODE TITLE: General (50 IE01D COPIES RECEIVED LTR L ENCL 2 SIZE:

Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 PD 1 1 BUCKLEY,B 2 2 INTERNAL: ACRS 2 2 AEOD 1 1 DEDRO 1 1 NRR MORISSEAU,D ' 1 1 NRR/DLPQ/PEB 11 1 1 NRR/DLPQ/QAB 10 1 NRR/DOEA DIR 11 1 1 NRR/DREP/EPB 10 1 1 NRR/DREP/RPB 10 2 2 NRR/DRIS DIR 9A 1 1 NRR/PMAS/I LRB1 2 1 1 NUDOCS-ABSTRACT 1 1

/J 1 1 OGC 15-B-18 1 1 G IL 02 1 1 RES/DSIR DEPY 1 1 RGN2 FILE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 D

TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

HARRIS NUCLEAR PROJECT P. O. Box 165 New Hill, North r

Carolina 27562 gjgf Q Q )ggp~

File Number'SHF/10-13510E Letter Number.'O-880139 (0) NRC-633 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO.

NO. NPF-63 50-400'ICENSE REPLY TO A NOTICE OF VIOLATION Gentlemen'.

In reference to your letter of June 22, 1988, referring to T.E.

Report RII: 50-400/88-11, the attached is Carolina Power & Light Company's reply to the violation identified in Enclosure 1.

The violation transmittal letter requested additional discussion on the implementation of the configuration control program. As pointed out in the attached response, we believe that the violation was caused by the failure to recognize the impact of the solid state protection system test on the ability of plant safety systems to perform their intended safety function. Personnel that allowed the test to be performed were licensed operators and trained to recognize, the operability of safety systems.

We do not believe that the procedures which govern the control of operating systems need to be revised beyond that described in the response and that the specific training provided to license operators is sufficient to address the generic implications of this violation.

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PLEB AGGCK -

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MEM/H0-8801390/1/OS L

G Document Control Desk Page 2 It is considered that the corrective actions taken are satisfactory for resolution of tne item.

Thank you for your consideration in this matter.

Very truly yours, g(i'i': c. "..7-"

R. A. Watson Vice President Harris Nuclear Project MGW:lem Attachment cc: Messrs. B. C. Buckley (NRC)

G. Maxwell (NRC-SHNPP)

Dr. J. Nelson Grace (NRC)

MEM/HO-8801390/2/OSl

Attachment to CP&L Letter of Response to I. E. Report RII:

50-400/88-11 Violation Re orted Violation:

Technical Specification 6.8.1a requires that written procedures be implemented covering the procedures outlined in Appendix A of Regulatory Guide 1.33, Rev. 2, February 1978. Administrative Procedures are identified in Appendix A of the Regulatory Guide.

Administrative Procedure AP-006, Rev. 7, Section 5.7, titled "Procedure Review and Approval", requires procedures to provide sufficient guidance to maintain control of plant safety systems to assure that the systems will perform their intended functions.

Contrary to the above, Operations Management Manual Procedures Oiif-003, Equipment Inoperable Record, and OMM-001, Conduct of Operations, and Ooerations Work Procedure OWP RP-17, Reactor Protection Automatic Trip Logic, did not ensure control of plant.

safety systems during testing of the solid state protection system. Specifically, on April 19, 1988, and August 18, 1987, the licensee unknowingly placed the unit under the requirements of Technical Specification (TS) 3.0.3 by allowing testing of "A" train solid state protection system to proceed, even though some of the plant safetv equipment in the "B" train was not operable.

Consequently, the plant continued operating at full power (Mode 1), rather than beginning a power reduction within the one hour time limit that TS 3.0.3 requires.

This is a Severity Level IV violation (Supplement I).

Denial or Admission and Reason for The Violation:

The violation is correct as stated.

On April 19, 1988, at 1310, the plant was operating in Mode 1 at 100X power. Train "A" of the Solid State Protection System (SSPS) was placed in test for routine, required surveillance from 1310 until 1426. The plant Technical Specifications allow an SSPS channel to be in test for up to two hours if the other channel, is operable, however, several components of the "B" train had been previously declared inoperable at various times during the day for preventive maintenance and testing. The "B" train components which had been declared inoperable included the "B" Motor Driven Auxiliary Feed Water (AFW) Pump, the "B" Emergency Service Water (ESW) Pump, the "B" Control Room Emergency Filtration unit, and the "B" Reactor Auxiliary Building (RAB) Emergency Exhaust.

MEN/HO-8801390/1/OS1

The conflict between the "B" train inoperable equipment and the "A" train SSPS test was not recognized by operations personnel at the time, consequently, Technical Specification 3.0 ' applied for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 16 minutes while the train "A" SSPS was in test. This situation was discovered on April 22, 1988, during review of Equipment Inoperable Records (EIRs).

This event was caused by an error made by 'the Operations personnel in the Clearance Center and the Main Control Room, coupled with a situation which was not adequately covered by Technical Specifications or applicable operations procedures. Neither the plant Technical Specifications nor the operating procedures explicitly addressed mechanical equipment associated with instrument channels. Each of the EIRs were done at a different time, and the interrelationship was not noticed by the preparers or reviewers. The oversight was identified during a subsequent review of a group of EIRE Corrective Ste s Taken and Results Achieved:

A thorough review was conducted of EIRs that were in effect during performance of monthly SSPS tests during the previous 12 months.

It was discovered that a similar event occurred on August 18, 1987. At that time, Train "A" of the SSPS was placed in test for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 25 minutes while the "B" ESW Screen Wash Pump and the RAB Exhaust Damper (D-61) were inoperable.

Corrective Ste s Taken to Avoid Further Noncom liance:

1. Relevant operating procedures have been revised to highlight the need to consider the operability of equipment on the other train when performing testing of the solid state protection system.

2. The "Operator Prerequisite Summary Sheet" in the SSPS Actuation Logic and Master Relay tests will be revised to remind operators that opposite train equipment must be evaluated before permitting these tests to be run (MSTI-0001 and MSTI-0320).

3. Training on this event has been provided to active licen'sed personnel.

Date When Full Com liance Was Achieved:

Full compliance will be achieved upon revision to the "Operator Prerequisite Summary Sheet" as stated above. Projected completion date is August 1, 1988.

MEM/HO-8801390/2/OS1