ML18011A382

Responds to NRC 940203 Ltr Re Violations Noted in Insp Rept 50-400/93-25.Corrective Actions:Tie Wraps Will Be Installed on Field Cables in Two Dc Distribution Panels & PSU-111 Connectors Replaced

ML18011A382
Person / Time
Site:	Harris
Issue date:	03/07/1994
From:	Robinson W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-94-018, HNP-94-18, HO-940507, NUDOCS 9403140274
Download: ML18011A382 (9)

See also: IR 05000400/1993025

Text

ACCELERATED

DISTMBUTION

DEMONSTRATION

SYSTEM REGULATORY

INFORMATION

DISTRXBUTION

SYSTEM (RXDS)CESSION NBR:9403140274

DOC.DATE: 94/03/07 NOTARIZED:

NO FACIL:50-400

Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME'UTHOR AFFILIATXON

ROBINSON,W.R.

Carolina Power&Light Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)DOCKET 05000400 SUBJECT: Responds to NRC 940203 ltr re violations'oted

in insp rept 50-400/93-25.Corrective

actions:tie

wraps will be installed on field cables in two dc distribution

panels&PSU-111 connectors

replaced.DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

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

of Violation R sponse D NOTES:Application

for permit renewal filed.05000400 A RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DSP/ROAB

AEOD/TTC NRR/DORS/OEAB

NRR/DRIL/RPEB

NRR/PMAS/ILPB1

NUDOCS-ABSTRACT

OGC/HDS1 RES/HFB EXTERNAL: EG&G/BRYCE,J.H.

NSIC COPIES LTD ENCL 1 (1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME LE,N AEOD/DE IB AEOD/DSP/TPAB

DEDRO NRR/DRCH/HHFB

NRR/DRSS/PEPB

NRR/PMAS/ILPB2

OEM%EG~02 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 D D D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOiVI Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!TAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24 D D

J t

<jy CPA.L Carolina Power 8 Light Company PO Box 165 New Hill NC 27562 , MAR-"f lgg File: HO-.940507

William R.Robinson Vice President Harris Nuclear Plant Serial: HNP-94-018

10CFR2.201

United States Nuclear Regulatory

Commission

Attention:

Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO.50400/LICENSE

NO.NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen:

In reference to your letter of February 3, 1994, referring to NRC Inspection

~~~Report 50-400/93-25, the attached is Carolina Power Bc Light Company's reply to the violations

identified

in Enclosure 1.II It is considered

that the corrective

actions taken/planned

are satisfactory

for resolution

of the violations.

Questions regarding this matter may be referred to Mr.D.C.McCarthy at (919)362-2100.Very truly yours, W.R.Robinson SDC:sdc Attachment

c: Mr.S.D.Ebneter (NRC-RII)M.N.S.Z (NRR)Mr.J.E.Tedrow (NRC-SHNPP)

9403140274

940307 PDR ADOCK 05000400 9 PDR State Road1134 New Hill NC Tel 919362-2502

Fax 919362-6950

Attachment

to HNP-94-018

REPLY TO A NOTICE OF VIOLATION NRC INSPECTION

REPORT NO.50400/93-25

Re orted Violation A: 10 CFR 50, Appendix B, Criterion XVI requires that measures shall be established

to assure conditions

adverse to quality, such as failures, malfunctions,'deficiencies, deviations, and non-confor'mance

are properly identified

and corrected.

The licensee's

Corporate Quality Assurance Manual, Section 12, requires that significant

conditions

adverse to quality be identified

and that corrective

actions be determined

which-will preclude repetition

of the condition.

Contrary to the above, following the failure of an auxiliary feedwater system valve in November 1992, the identification

and determination

of corrective

actions for deficiencies

noted in the motor control center wiring of auxiliary feedwater system motor operated valves was not sufficient

to preclude the repetition

of another auxiliary feedwater system valve failure on December 14, 1993.This is a Severity Level IV violation (Supplement

g.Denial or Admission:

The violation is admitted.Reason for the Violation:

Plant Change Request PCR-3551 was initiated for the DC electrical

distribution

system in August 1988 by the Technical Support Unit to disposition

concerns of loose electrical

connector strips found in DC distribution

panels DP-1A2-SA and DP-1B2-SB'.

The connectors

of concern were Connectron

Model PSU-111, separable modular plugs.The PCR prompted an investigation

to discern the scope of potential problem(s)

with the connectors.

A review of records found no equipment failures resulting f'rom these connectors

coming loose.It was believed that the PCR was initiated as a result of problems experienced

f'rom movement of the cables associated

with activities

within the DC" distribution

panels during construction

of the facility.Given that no documented

failures could be associated

with these connectors

after commencement

of plant operations, PCR-3551 was canceled in August 1990.Meanwhile, on July 18, 1989, the Operations

Unit issued a Standing Order and mounted placards on the access doors of the two DC distribution

panels to heighten operations

and maintenance

personnel awareness of concerns associated

with these connectors.

The There are a total of five valves routed through the distribution

panels DP-1A24A and DP-1B2-SB.MEM/HO 940507/OS1

Attachment

to HNP-94-018

4 tw Standing Order required verifying proper operation of each valve whose control circuitry is~~~~~~~~~~routed through a DC distribution

panel in which work is done in the breaker cubicle or to the access doors.PCR-5511 was initiated in September 1990 by the Operations

Vnit based on the same concerns that resulted in initiation

of PCR-3551.Subsequently, a single failure attributable

to a loose PSU-111 connector occurred on November 26, 1992 in the control circuit of valve 1MS-70'.The engineering

review stemming from the failure'concluded

that the design of the distribution

panels, including the PSV-111 terminals, was sufficient

if the cables are supported in accordance

with design requirements., Further, the review stated that the terminal blocks unlatch due to forces on them f'rom supporting

cable weight and pulling forces exerted by the moving of cables.The pull-apart

terminal blocks used in the two DC.~'.".l~hu<3on.

g~a~ls have s>>fficient

frictional

force holding them together such that without the introduction

of outside forces the terminal blocks would not pull apart.Investigation

of PCR 5511 prompted another review to discern if there had been any changes since the previous PCR's review.This review identified

the single failure on November 26, 1992 in the control circuit of valve 1MS-70 as the only failure.However, given the population

of greater than 3500 PSU-111 terminal blocks in service for seven years of operation, a single failure attributable

to a loose PSU-111 connection

was not considered

to be sufficient

cause to warrant any design changes.Therefore, PCR-5511 was also canceled on November 12, 1993 and no additional

actions were taken.On December 14, 1993, valve 1AF-137 failed.The root-cause

investigation

attributed

the failure to a loose PSU-111 connector resulting from movement of the cables, possibly by settling, given that the cables had been recently disturbed and were not properly supported by tie-wraps.

The PSU-111 separable modular connectors

are used in the two DC distribution

panels as well as in other AC Motor Control Centers (MCC).Carolina Power&Light Company believes that the component inoperability

concern is limited to the two DC distribution

panels because 1)inspection

of several AC MCCs confirmed that the cables were appropriately

supported by tie-wraps, 2)the AC distribution

panels are not entered for routine testing comparable

to the two DC panels, and 3)there have been no documented

problems with loose connectors

within the AC MCCs.The combination

of the cables being disturbed to acquire current test readings for DC motor driven MOVs and the lack of supporting

tie-wraps has been determined

as the probable cause of the two terminal block failures.Note: A second failure of 1MS-70, on March 8, 1993, referred to in the Inspection

Report 93-25 Details Section Paragraph b.(2)was the result of a main contactor problem with the motor operator for valve iMS-70.It did not have any correlation

to loose PSU-111 connectors.

MEM/HO940507/osi

Attachment

to HNP-94-018

Corrective

Ste s Taken and Results Achieved: Since the failure of 1MS-70, revision to the Root Cause Investigation

Procedure (AP-605)requires a more rigorous root cause evaluation.

That more rigorous process was followed for the 1AF-137 valve failure investigation.

As a result of the failure of 1AF-137 on December 14, 1993, Adverse Condition Report (ACR)93-594 was initiated.

Investigation

reconfirmed

the findings of the engineering

review performed in association

with PCR-5511, i.e., that the design of the distribution

panels was sufficient

if the cables are tie-wrapped

and not disturbed.

To that end, the ACR requires the installation

of tie-wraps on field cables in the two DC distribution

panels.Corrective

Ste s To Be Taken to Prevent Further Violations:

As stated above, tie-wraps will be installed on the field cables in the two DC distribution

panels.In addition, Carolina Power&Light Company will replace the PSU-111 connectors

in the DC distribution

panels DP-1A2-SA and DP-1B2-SB with a non separable connector.

Date When Full Com liance Will Be Achieved: Full compliance

is expected upon completion

of the corrective

actions described above.The reinstallation

of tie-wraps will be completed by March 25, 1994.The replacement

of the DC panels PSU-111 connectors

will be performed during the upcoming outage.This action will be completed by May 15, 1994.M EM/H 0940507/Osl

Attachment

to HNP-94-018

Re orted Violation B: Technical Specification 6.8.1(a)requires that written procedures

be properly established

and implemented

covering procedures

outlined in Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978.Regulatory

Guide 1.33, Appendix A, paragraph 2.f requires procedures

for changing turbine load, Operating Procedure OP-131.01, Main Turbine, Section 7.1 provides specific guidance for reducing turbine load., Ccr~avg to the above, on December 31, 1993, the directions

provided in procedure OP-131.01 were determined

to be inadequate

and could not be performed in the sequerice specified to reduce the turbine load.This is a Severity Level V violation (Supplement

I).Denial or Admission:

The violation is admitted.Reason for the Violation:

On December 31, 1993, the plant was to reduce power to perform required testing.In preparation

to reduce load, the Control Operator added 50 gallons of boric acid (about an 8 ppm increase in the RCS boron concentration).

When the boron took effect, approximately

10 minutes after injection, the turbine load reduction was to start per OP-131.01.

While preparing for the power down, the Balance of Plant (BOP)Operator saw that two procedure steps in OP 131.01 were out of sequence.OP-131.01 gives instructions

for changing turbine load with the DEH control panel.Step 7.1.2.1.g should have directed the enabling of the Megawatt and Turbine Impulse'ressure

feedback loops and then inputting the desired load change.However, the steps were reversed, which would result v the ioac coiiilnand

oeing deleted upon activation

of the feedback control.A check of the Operator Feedback Report (OFR)database showed that the problem was already identified.

At the time the OFR was initiated, the time frame for revising the procedure was not considered

to be critical given the operator knowledge of this evolution through training and experience, plus the fact that this evolution was correctly sequenced in General Operating Procedure GP-006.Hence, the information

was in the procedure working file to be added to the procedure during the next revision.However, in October 1993, this work sequence was removed from GP-006 since it was believed to be redundant to OP-131.01.

Management

in the Control Room directed the BOP Operator to reduce load based on his knowledge of how to reduce turbine load.The plant load reduction was subsequently

completed, but no action was taken to immediately

correct OP-131.01.

Thus the violation M EM/HO 94507/os1

Attachment

to HNP-94-018

C t occurred because the identified

procedure defect was not corrected when first identified.

'econdly, the rediscovery

of the error was not appropriately

addressed.

Proper application

of plant procedural

use and adherence requirements (AP-100)allows achieving safe stable conditions.

In this event, performing

a load decrease to maintain RCS average temperature

at the program value would be acceptable.

However, this should have been immediately

followed'with

a temporary change to OP-131.01.

Corrective

Ste s Taken and Results Achieved: Procedures

have been revised to incorporate

the correct sequence of steps for reducing turbine load.This was completed by January 20, 1994.~.b.~..~.>iv~~>.;,s, Yaken to Prevent Further Violations:

The individuals

involved were counseled on the proper response to the discovery of errors in procedures.

A discussion

of compliance

with AP-100 was presented by the Manager-Operations

in a Shift Supervisor

-Nuclear meeting held on February 8, 1994.The Operations

Unit procedure revision working files were reviewed and seven additional

procedure revisions were identified.

The seven procedures

were subsequently

revised.Date When Full Com liance Will Be Achieved: Full compliance

was achieved as described above by February 14, 1994.MEM/HO940507/osl

0