ML18005A669

Documents Licensee Request for Enforcement Discretion Per 881013 Telcon Between Cw Hehl & CS Hinnant Re Tech Spec 3.6.3 Re Isolation Valve for Bypass Line Around Main Feedwater Isolation Valve for Steam Generator a

ML18005A669
Person / Time
Site:	Harris
Issue date:	10/13/1988
From:	Watson R CAROLINA POWER & LIGHT CO.
To:	Ernst M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8811020232
Download: ML18005A669 (5)

Text

A.CCZlxmTED Dl BUTloN DExoHsTz~wo Y svprzz REGULATO INFORMATION DISTRIBUTION LITEM (RIDS) j ACCESSION NBR:8811020232 DOC.DATE: 88/10/13 NOTARIZED: NO DOCKET FACIL:50-400 Shearor:;qHarris Nuclear Power Plant, Unit 1, Carolina 05000400

, AUTH.NAME AtRHOR AFFILIATION WATSONgR.A.

Carolina Power 8 Light Co.

'RECIP.NAME RECIPIENT AFFILIATION ERNST,M.L.

Region 2, Ofc of the Director

SUBJECT:

Documents licensee request for enforcement discretion per 881013 telcon between CW Hehl

& CS Hinnant re Tech Spec 3.6.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR 1

ENCL 0 SIZE:

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

05000400 RECIPIENT ID CODE/NAME PD2-3.

PD INTERNAL: ACRS DEDRO NRR/DLPQ/PEB 11 NRR/DOEA DIR ll NRR/DREP/RPB 10 NRR/PMAS/ILRB12 OE I=EBEBgAN g J EG~L~

02 RGN2 FILE 01 EXTERNAL: LPDR NSIC COPIES LTTR ENCL 2

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1 2

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RECIPIENT ID CODE/NAME BUCKLEY,B AEOD NRR MORISSEAU,D NRR/DLPQ/QAB'0 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS1 RES/DSR DEPY NRC PDR RESL MARTIN,D COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

D S

h TOTAL NUMBER OF COPIES REQUIRED:

LTTR 25 ENCL

F,orm 244 Carolina Power tt Light Company

.';U

~ 27 Company Correspondence HARRIS NUCLEAR PROJECT P.O.

Box 165 New Hill, North Carolina 27562 OCTZ S mSB Mr.. Malcolm L. Ernst Acting Regional Administrator United States Nuclear Regulatory Commission Region II Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323 The purpose of this letter is to formally document Carolina Power

& Light's (CP&L) request for enforcement discretion as discussed in a telephone conference between C.W. Hehl of your staff and C.S.

Hinnant of my staff on October 13, 1988.

The request involves Technical Specification 3.6.3 as it applies to valve 1FW-307.

Valve 1FW-307 (shown as valve no.

2FW123-SAB-1 on FSAR Figure 10.1.0-3) is the isolation valve for the, bypass line around the Main Feedwater Isolation Valve (MFIV) for the A

Steam Generator.

Valve 1FW-307 was discovered to have an excessive stroke time during surveillance testing.

The valve was declared inoperable per Technical Specification 3.6.3 and was closed and deenergized in accordance with action b of that specification.

Investigation of the inoperable valve has determined that the problem is internal to the valve body and not with the actuator.

As a result repairs to the valve cannot be made unless the plant is cooled down to Mode 5

and the containment integrity no longer required.

Valve 1FW-307 is a

containment isolation valve and it is closed by a Main Feedwater Isolation Signal (MFIS).

It is located in a three inch bypass line around the MFIV The valve is opened only during power escalation for a period of approximately forty-five minutes to warm up the steam generator preheater region with feedwater at relatively low flowrates.

After heatup of the feedwater line between the MFIV and the Steam Generator is accomplished, the MFIV.is opened 'and the bypass isolation is closed.

This evolution occurs at approximately 20 4 power.

This evolution cannot be performed on A Steam Generator and remain in compliance with Technical Specification 3.6.3 or its action statements.

88il020232 88i0i3 PDR ADOCK 05000400 PNU

L Valve 1FW-307 recieves a MFIS because it is in parallel with the MFIV.

The MFIS is generated from High High Water Level in a

Steam Generator and Safety Injection Signal.

The closure of the valve assures that overfill of the Steam Generator is prevented, limits the mass addition to a

faulted Steam Generator during a postulated Main Steamline

Break, and provides containment integrity along with the closed system of the Steam Generator.

We conclude that it is acceptable to open 1FW-307 for the short amount off time required by the startup evolution because capability continues to exist to automatically and manual'ly isolate the 3 inch bypass line by other means.

First, in series with 1FW-307 is a flow control valve.

This

bivalve, 1FW-306, is operated from the main control room.

It fails closed on loss of power or loss of i'nstrument air, and receives a close signal if high flowrates occur in the three inch line.

This valve is used to regulate the warmup flowrate to the preheater.

This valve is also a

Class 2

valve and is located in close proximity to lFW-307 in the steam tunnel.

Second there is a

check valve in the Main Feedwater Line upstream of the bypass line.

Third, the Main Feedwater Regulating Valve and the Bypass Regulating Valve also receive a MFIS.

The redundancy provided by these valves provides assurance that feedwater can be isolated and that containment integrity can be established.

CPS L requests the permission to open lFW-307 for the short period of time required to support normal warmup of the preheater section of the steam generator.

This action will be compensated by three actions:

(1) stationing of an operator (with direct communication to the Main Control Room) at 1FW-307 to manually close the valve should a

MFIS be generated; (2) stationing an operator at the controls in the Main Control Room for lFW-306

(

2FW-F9SN-1 as shown on FSAR Fig 10.1.0-3) to isolate this valve should a

MFIS be generated; (3) limiting the valve opening to only that required to complete the evolution required by the General Operating Procedure.

This enforcement discretion is requested to remain in effect until 1FW-307 can be repaired.

This valve will be repaired at the next reasonable opportunity.

Very truly yours, R.

A. Watson, Vice President Harris Nuclear Project cc:

Mr.

B.

C. Buckley (NRC)

W.'H. Bradford (HNP NRC Resident Office)

Mr. M. L. Ernst Page 3

0 cc:

Mr. B. C. Buckley (NRC)

Mr. W. H. Bradford (HNP NRC Resident Office) bcc: Messrs.

Mr. H.

Mr. R.

Mr. R.

Mr. C.

Mr. R.

Mr.

CD Mr. A.

Mr. G.

Mr. B.

Mr. L.

Mr.

W.

Mr. C.

Mr. D.

R. Banks T. Biggerstaff K. Buckles (LIS)

Carmichael (2)

M. Coats W. Crawford B. Cutter/MGG/SM L. Forehand J. Furr T. Gucwa J.

Hindman S., Hinnant E. Hollar Mr. L.

Mr. R.

Mr. C.

Mr. M.

Mr. R.

Mr.. R.

Mr. D ~

Mr. R.

Mr. B.

Mr. S."

File'.

File:

I'oflin E. Lumsden H. Moseley, Jr.

R. Oates B. Richey B. Starkey, Jr.

L. Tibbitts A. Watson M. Williams R. Zimmerman HI/A"2D H-X-MEM/HO-8802150/3/OS1

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