ML18022A785

Responds to NRC 900131 Ltr Re Violations Noted in Insp Rept 50-400/89-34.Corrective Actions:Valve SI-332 Closed & Gravity Drain Path Isolated & Shift Foreman Required to Review MMM-012 Re Priority/Emergency Maint Work Control

ML18022A785
Person / Time
Site:	Harris
Issue date:	03/02/1990
From:	Richey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-701 HO-900041-(O), NUDOCS 9003130028
Download: ML18022A785 (10)

See also: IR 05000400/1989034

Text

-ACCELERATED

DISTIUBUTION

DEMONSHRATION

SYSTHM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ESSION NBR: 9003130028

DOC.DATE: 90/03/02 NOTARIZED:

NO ACIL:50-400

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

RICHEY,R.B.

Carolina Power&Light Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)DOCKET 05000400 SUBJECT: Responds to NRC 900131 ltr re violations

noted in Insp Rept 50-400/89-34.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

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

of Violation Response NOTES:Application

for permit renewal filed.1 S 05000400/INTERNAL RECIPIENT ID CODE/NAME PD2-1 PD ACRS AEOD/DEIIB

DEDRO NRR/DLPQ/LPEB10

NRR/DREP/PEPB9D

NRR/DRIS/DIR

NRR/PMAS/ILRB12

OGC/HDS 1 RES MORISSEAU,D

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

1 NRR/DOEA DIR 11 1 NRR/DREP/PRPB11

1 NRR/DST/DIR

8E2 1'U OCS-ABSTRACT

1 EG FIL 02 1 E 01 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1 1 A, D EXTERNAL: LPDR NSIC 1 1 NRC PDR 1 1 1 1 RJ D NOIX TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WAS%I CONTACT THE.DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENIS YOU DON'T NEED!OTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25 D D S

Carolina Power 8 Light Company P.O.Box 165~New Hiil~N.C.27562 R.B.RICHEY Manager 2 l990 Letter Number.'HO-900041

(0)Document Control Desk United States Nuclear Regulatory

Commission

Washington, DC 20555 NRC-701 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 January 31, 1990, referring to I.E.Report RII: 50-400/89-34, the attached is Carolina Power and Light Company's reply to violation"A" identified

in Enclosure 1.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, Man ger Harris Nuclear Pr ject MGW:dgr Enclosure cc: Mr.R.A.Becker (NRC)Mr.S.D.'Ebneter (NRC" RII)Mr.J.E.Tedrou (NRC-SHNPP)5'003i3002S

900302 PDR ADOCK 05000400 I.J nr ni nu-v8utII4

JO/1/OS1 xo/~rII

ATTACHMENT

TO CP&L LETTER OF RESPONSE TO NRC I.E.REPORT RII: 50-400/89-34, VIOLATION"A" Re orted Violation.'echnical

Specification

6.8.1.a requires that written procedures

be 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 8.b requires ,that written procedures

be provided for surveillance

tests.Operations

Surveillance

Test OST-1804, Residual Heat Removal (RHR)Remote Position Indication

and Timing Test, provides the steps and prerequisites

necessary to verify proper valve operation.

Step 3.1 of this procedure requires that the system being tested be aligned in a manner that will support the performance

of the test.Operations

Surveillance

Test OST-1004, Power Range Heat Balance, provides the steps necessary to adjust the power range nuclear instruments.

Note 1 on attachment

VII of this procedure, requires that if there is insufficient

adjustment

of the fine gain potentiometer, that a work request be generated to adjust the course gain potentiometer.

Contrary to the above, l.On November 28 1 989, procedure OST-1804 was not properly implemented

in that the RHR system lineup was not adequately

aligned to allow test performance

which resulted in the overflow of contaminated

borated water from'the reactor vessel to the seal table area of containment.

2.On December 23, 1989, procedure OST-1004 was not properly implemented

in that a work request was not generated-and course gain adjustments

were made.This is a Severity Level IV violation (Supplement

I).Denial or Admission:

The violation is admitted.Example 1 and 2 of the violation are addressed separately, each with a specific reason for the violation, corrective

steps taken, corrective

steps taken to prevent further violations

and full compliance

date given.1.Reason For The Violation:

a'n November 22, 1989, Sections 7.1.and 7.3 of OST-1804 (RHR Remote Position Indication

and Timing Test, Eighteen (18)Month Interval, Modes 5 and 6)were successfully

completed for the B train.(The vessel was defueled and both trains of RHR were secured.)On November 28, 1989, refueling was complete and B train RHR was in operation.

OST-1804 was to MEM/HO-9000410/2/OS1

be performed on the"A" train valves.The Shift Technical Advisor (STA)was running the test.The STA conducted a briefing on the test with the Reactor Operator (RO), who would operate the valves and the Auxiliary Operator (AO), who would verify valve position locally.The briefing included the purpose and general methods used to accomplish

the test.The"A" RHR train had two valves in series (RH-1 and RH-2)that isolate RHR from the Reactor Coolant System.-When the testing began, RH-2 was open and under clearance for maintenance.

RH-1 was also open, but capable of being closed.With RH-2 under clearance, Section 7.1 (RHR Valve Timing Test)could not be performed.

The STA therefore skipped Section 7.1 and proceeded to 7.2 (Remote Position Indication

Verification, Train"A").He did not realize that Section 7.1 ensured that RH-1 and RH-2 were closed prior to starting Section 7.2.Section 7.2 requires cycling the Refueling Water Storage Tank (RWST)to RHR pump suction valve.If this is done with RH-1 and RH-2 open, the RWST will gravity drain to the reactor vessel.Section 7.2 did not contain a specific caution addressing

gravity drain, because this could not occur if RH-1 or RH-2 was shut (as would be the case if Section 7.1 had been performed).

The RO was responsible

for all operations

involving the primary side of the plant.He was tasked with monitoring

primary system operations, outage activities

affecting his indications, and log taking.When the STA requested him to stroke SI-322, RWST suction to a RHR pump, he also failed to detect that this would establish a gravity drain flow path via the open loop suction valves.Mhen requested, the RO opened SI-322.The valve took approximately

20 seconds to open and was open for approximately

20 seconds while the AO verified its position.Then it was stroked shut.After taking the valve switch to shut, the RO noticed his Reactor Vessel Level Instrumentation

System (RVLIS)trend on a CRT screen increasing.

About one minute after cycling the valve, the Control Room got a call from the Containment

refueling level HP Technician.

He reported water was coming out from around the vessel head flange.The vessel head was in place,'ut the bolts were not yet torqued down, which allowed reactor coolant to leak through the gap between the head and vessel flanges.Vessel level increased from 19-3/4" below the flange to approximately

18" above the flange.Mater spilled through the gap at the flange into the refueling cavity and the seal table room (previously

not contaminated).

RWST level decreased by approximately

1 percent which corresponds

to approximately

3,000 gallons.Corrective

Ste s Taken and Results Achieved: Valve SI-32&was'losed

and the gravity drain path was isolated.Corrective

Ste s Taken to Avoid Further Violations:

Procedure OST-1804 is being revised to include a caution relative to gravity drain prior to cycling RWST suction valves.A review of other OSTs that cycle RWST suction valves is being performed and revision to include cautions where applicable

will be made.MEM/HO-9000410/3/OS1

This event wilL be reviewed with appropriate

Operations

personnel.

The review will emphasize that when skipping steps/sections

in a procedure, it must be ensured that the existing system lineup is consistent

with what it would have been if the skipped step/section

had been performed.

J Date Full Com Liance Wi11 Be Achieved: OST-1804 will be revised and other OSTs will be reviewed and revised, as appropriate, by December 31, 1990.A review of this event with appropriate

Operations

personnel will be completed by March 31, 1990.2.Reason For The Violation'.

On December 23, 1989, a calorimetric

calibration

was complete'd

for the nuclear instruments (NIs).The power range NIs were found to be reading lower than actual core power, as determined

by the calorimetric.

The calorimetric

indicated actual power at approximately

41 percent while the power range NI indicated approximately

28 percent.The shift foreman on duty directed an IhC Technician

to adjust the course gain on the instruments.

Procedure MMM-012, Maintenance

Work Control Procedure Section 5.4 Priority/Emergency

Maintenance, allows the Shift Foreman to direct maintenance

activities

without preplanning

and without a Work Request in an emergency or abnormal operating conditions.

The Shift Foreman considered

the difference

between the actual and indicated power to be an abnormal operating condition and therefore directed the adjustments

be made.MMM-012 Section 5.4 also requires that if maintenance

activities

are directed as stated above those actions shall be'documented

after the fact and receive the same degree of review as if they had been preplanned.

The Shift Foreman failed to,initiate

the required documentation

at this time.This resulted in no Work Request initiation

until January 9, 1990.Corrective

Ste s Taken and Results Achieved: A Work Request and Authorization

(90-AAMY1)

was initiated on January 9, 1990.Corrective

Ste s Taken to Avoid Further Violations:

Shift Foreman and Senior Reactor Operators are being required to review the applicable

sections.for MMM-012, to ensure an understanding

of theserequirements.

Date Full Com liance Will Be Achieved: The above stated reviews will be completed by March 9, 1990.MEM/HO-9000410/4/OS1