ML18009A408

Responds to NRC 900226 Ltr Re Violations Noted in Insp Rept 50-400/90-01.Corrective Actions:All Calibr Required by Tech Specs for Power Range Nuclear Instrumentation Satisfactorily Completed

ML18009A408
Person / Time
Site:	Harris
Issue date:	03/19/1990
From:	Richey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-704 NUDOCS 9003270341
Download: ML18009A408 (8)

See also: IR 05000400/1990001

Text

ACCELERATOR)

DISTRIBUTlON

DEMON.H1MTION.

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ESSION NBR:9003270341

DOC.DATE: 90/03/19 NOTARIZED:

NO ACIL:50-400

Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION

RICHEY,R.B.

Carolina Power 6 Light Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 900226 ltr re violations

noted in Insp Rept 50-400/90-01.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Vi lation esponse DOCKET.,'5:

05000400 NOTES:Application

for permit renewal filed.050004'00 INTERNAL: RECIPIENT ID CODE/NAME PD2-1 PD ACRS AEOD/DEIIB

DEDRO NRR/DLPQ/LPEB10

NRR/DREP/PEP

B9 D NRR/DRIS/DIR

NRR/PMAS/ILRB12

OGC/HDS 1 RES MORISSEAU,D

COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME BECKER,D AEOD AEOD/TPAD NRR SHANKMAN,S

NRR/DOEA DIR ll NRR/DREP/PRPBll

NRR/DST/DIR

SE2 OC-ABSTRACT REG 02 2 FILE 01 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1'1 2 2 1 1 1 1 1'1 1 1 EXTERNAL: LPDR NSIC 1 1'.1 1 NRC PDR 1 1 NOTE TO ALL"RIDS" RECIPIENIS

I PLEASE HELP US TO REDUCE WASIZI CONTACT THE DOCUMENI'ONSOL

DESK;ROOM Pl-37 (EXT.20079)TO ELMINATE YOUR NAME FROM DISHUBUTION

LISIS FOR DOCUMENTS YOU DON'T'NEEDl

TAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

Carolina Power 8 Ught Company P.O.Box 165~New Hill, N.C.27582 R.B.RCHEY Manager Harris Nuclear Prolect iIAR i 9 1990 Letter Number: HO-900050 (0)Document Control Desk United States Nuclear Regulatory

Commission

Washington, DC 20555 NRC-704 SHEARON 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 February 26, 1990, referring to I.E.Report RII: 50-400/90-01, the attached is Carolina Power and Light Company's reply to the violation identified

in Enclosure 1.k It is considered

that ,the corrective

actions taken/planned

are satisfactory

for resolution

of the item.Thank you for your consideration

in this matter.Very truly yours, R.B.Richey, Mana er Harris Nuclear Project AJH:tbb Enclosure cc'.Mr.R.A.Becker (NRC)Mr.S.D.Ebneter (NRC-RII)Mr.J.E.Tedrow (NRC-SHNPP)Pv03~70341

$0C>2 ADiil K 05'000400 PDC MEM/HO-9000500/1/OS1

ATTACHMENT

TO CPGL LETTER OF RESPONSE TO NRC I.E.REPORT RII: 50-400/90-01, VIOLATION Re orted Violation'.

Technical Specification (TS)'3.3.1 requires the Reactor-Trip System Instrumentation

of Power Range, Neutron Flux, High and Low Setpoints, and the High Negative and Positive Rate Trips be operable in Modes 1 and 2.TS 2.2.1 requires the Reactor Trip System Instrumentation

setpoints to be set consistent

with the trip setpoint values shown in Table 2.2-1.Table 2.2-1, in part, lists the power range setpoints as shown below.a~b.c~'d~High Setpoint Low Setpoint High Positive Rate High Negative Rate (=109X of Rated Thermal Power (RTP)<=25X of RTP 5X of RTP 5X of RTP TS 3.7.1 requires that the Power Range Neutron Flux High Setpoint be lowered to (=87K of RTP for an inoperable

main steam safety valve.Contrary to the above, at approximately

3:23 a.m.on December 20, 1989, when the plant entered Mode 2 with an inoperable

main steam safety valve, until approximately

3:30 a.m.on December 23, 1989, when the power range instrument

adjustments

werecompleted, the Reactor Trip System Instrumentation

setpoints were not set consistent

with the trip values shown in Table 2.2-1 and TS 3.7.1.Actual established

Reactor Trip setpoints were calculated

to be the following for the Power Range Neutron Flux'.a.b.c~d.High Setpoint Low Setpoint High Positive Rate High Negative Rate 127.5X of Rated Thermal Power (RTP)37.5X of RTP 7.5X of RTP 7.5X of RTP This is a Severity Level IV violation (Supplement

I)~Denial or Admission:

The violation is admitted.The high setpoint was calculated

at 125.5X, rather than 127.5X.Reason for the Violation'.

A low leakage core loading pattern was installed for cycle three operation to improve fuel efficiency.

Although the vendor Nuclear Design and Operations

Report identified

a reduction in neutron leakage flux and provided recommended

adjustments

to the power range nuclear instrumentation (PR NIS)to compensate

for this effect, these compensating

adjustments

were not made.Initial criticality

and power operation up to 28.1X indicated reactor power (42.5X actual reactor power)occurred prior to the point when the first calorimetric

heat balance was performed, on MEM/HO-9000500/2/Osl

December 23, 1989, at approximately

2:30 a.m.The PR NIS were adjusted at approximately

3:30 a.m.that morning.The root cause was the lack of formal control over power ascension activities

for refueling start-ups, and insufficient

management

attention to the planning and implementation

of power ascension.

Testing requirements

for pow'er ascension were identified

by the reactor engineering

group and placed on the outage schedule.This schedule could be changed without appropriate

management

reviews and approvals.

The test procedure (EPT-008)which would have provided the compensating

adjustments

to the PR NIS was on the schedule, but was subsequently

removed, based on the belief by the reactor engineer that the intent of the procedure had been achieved by previous activities.

Specifically, EPT-008 makes adjustments

to the intermediate

range instrumentation

as well as the PR NIS.The intermediate

range detectors had been relocated further away from the reactor core, and so required recalibration

to compensate

for the movement.This compensation

had been previously

determined

and the instruments

recalibrated, so when EPT-008 came due on the schedule, it was not performed.

The shift operations

personnel did not detect the significant

discrepancy

between indicated reactor power from the PR NIS and other indications

of power, especially

the core delta temperature, which was providing an accurate indication

of actual power level.Plant procedures

did not require any monitoring

of specific indications

of power level, and comparison

of diverse indications.

The operators did note that the main generator load was higher than that which had previously

been achieved for the indicated reactor power level, but this was attributed

to efficiency

improvements

from modifications

to the plant cooling tower made during the outage, and from the extreme cold weather which was experienced

during the period.Training for cycle three operations

did identify an expected reduction in the neutron flux leakage and the impact on the PR NIS, but this training had not emphasized

the significance

of the impact, and the training had been conducted several months prior to cycle three start up.Following the incident, an evaluation

was made to determine the safety significance.

It was determined

that the diverse trip features of the Reactor Protection

System, specifically

the overtemperature

and overpower delta temperature

reactor trips, provided protection

for the core for the existing conditions

at which the plant operated, and for power levels at which it was planned to operate prior to stabilizing

to perform the calorimetric

heatbalance.Corrective

Actions Taken and Results Achieved: The PR NIS was immediately

adjusted to indicate the actual power level once the calorimetric

heat balance indicated a miscalibration.

All calibrations

required-by Technical Specifications

for the PR NIS have been satisfactorily

completed.

MEM/HO-9000500/3/OS1

Briefings on the event and its significance

have been conducted for plant management

and supervisors, licensed operators, and reactor engineering

personnel.

Further investigation

of this event was conducted to evaluate human, performance.

An investigation

by personnel not associated

with the plant was also conducted.

Corrective

Ste s Taken to Avoid Further Violations:

A formal program to identify the cycle specific requirements

of the Power Ascension Test Program is being developed and will be in place prior to the next refueling start up.The plant start up procedure has been changed to require comparison

of the PR NIS to other diverse indications

of reactor power, and resolution

of any gross discrepancies.

Additional

training of technical staff and management

personnel is planned, as well as changes, where appropriate, to licensed operator training and requalification

training.Practices for scheduling

cycle-specific

training will be reviewed and revised as appropriate.

The test procedures

for power ascension activities

are being reviewed and will be revised as necessary prior to their next use.Reference:

LER 89-023-00 MEM/HO-9000500/4/OS1

,A