ML18005A250

LER 87-064-00:on 871102 & 1218,waste Processing Bldg Vent Stack 5A Wide Range Gas Monitor 1WV-3547-1 Declared Inoperable W/O Required Special Rept Submitted.Caused by Personnel Error.Procedure OMM-003 revised.W/880118 Ltr

ML18005A250
Person / Time
Site:	Harris
Issue date:	01/18/1988
From:	Jerrica Johnson, Watson R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
HO-880007-(O), LER-87-064, LER-87-64, NUDOCS 8801220204
Download: ML18005A250 (8)

Text

.+CFELERXTED IHSIBUTION DEMON STEON SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR: 8801220204 DOC.DATE: 88/01/18 NOTARIZED:

NO.FACZL:50-400 Shearon Harris Nuclear Power, Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION JOHNSON,J.R.

Carolina Power E Light Co.WATSON,R.A.

Carolina Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION DOCKET g 05000400

SUBJECT:

LER 87-064-00:on 871218,special rept re inoperative radiation monitor not submitted within required time frame.W/8 ltr.DISTRIBUTION CODE: IE22D COPIES RECEIVED:LTR

)ENCL SIZE: TITLE: 50.73 Licensee Event Report (LER), Inci&d nt Rpt, etc.RECIPIENT ZD CODE/NAME PD2-1 LA BUCKLEY,B COPIES LTTR ENCL 1 1 1 1 RECIPIENT ID CODE/NAME.PD2-1 PD NOTES:Application for permit renewal filed.COPIES LTTR ENCL 1 1 050004008 j A INTERNAL: ACRS MICHELSON AEOD/DOA AEOD/DSP/ROAB ARM/DCTS/DAB NRR/DE ST/ADS NRR/DEST/ELB NRR/DEST/MEB NRR/DEST/PS B NRR/DEST/SGB NRR/DLPQ/QAB NRR/DREP/RAB R-SZB EG 02 RES/DE/EI B RGN2 FILE 01 EXTERNAL: EGGG GROH,M H ST LOBBY WARD NRC PDR NSIC MAYS,G 1 1 1 1 2 2 1 1 1 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 11 1 5 5 1 1 1 1 1 1 ACRS MOELLER AEOD/DSP/NAS AEOD/DSP/TPAB DEDRO , NRR/DEST/CEB NRR/DEST/ICSB NRR/DEST/MTB NRR/DEST/RSB NRR/DLPQ/HFB NRR/DOEA/EAB NRR/DREP/RPB NRR/PMAS/ILRB RES TELFORD,J RES/DRPS DIR FORD BLDG HOY g A LPDR NSIC HARRIS,J 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1 1 , 1'1 1 (R TOTAL NUMBER OF COPIES REQUIRED: LTTR 46 ENCL 45 i

NRC Form 3 (943)LICENSEE EVENT REPORT (LER)UA.NUCLEAR REOULATORY COMMISSION APPROVED DMS NO.31604104 EXPIRES: 8/31/88 FACILITY NAME (II Shearon Harris Nuclear Power Plant Unit 1 DOCKET NUMBER (2)PACE 3 o 6 o o o4pp>'OFO 3 Special Report Concerning Inoperative Radiation Monitor Was Not Submitted Within the Re uired Time Frame EVENT DATE ISI LER NUMBER (8)REPORT DATE (7)OTHER FACILITIES INVOLVED (8)MONTH DAY YEAR YEAR Q SEClVENTIAL jK<<'UMBER REVtdlON NUMBER MONTH OAY YEAR FACILITY NAMES DOCKET NUMBER(S)0 5 0 0 0 1 2 18 87 8 7 0 6 4 0 0 0 1 1 8 8 8 0 5 0 0 0 OPKRATINO MODE (9)POWER LEVEL]p p i<'@g<p'o'a r NAMn 20A02(b)20.405(e)(1)(I)20AOS(a)(1)(El 20.405(al()HI(I) 20AOS(e)(1)(lv) 20.405(e)(1)(vl 20AOS(e)50.38(c)(1) 50.38(c)(2)50.73(a)(2 I II)50.73(e)(2)OI)50.73(el(2)(III)LICENSEE CONTACT FOR THIS LER (12)60.73(a)(2)(Iv)50.73(e)(2)(v) 50.73(e I (2)(v8)60.73(a I (2 I (v!II)(Al 50.73 4)(2)(vIQ I (8 I 60.73(e)(2)(x)THIS REPORT IS SUBMITTED PURSUANT T 0 THE REDUIREMENTB DF 10 cf R (): Icheck one or more of tne follovllnd)

(11 73.71(b)73.71(c)OTHER ISpeclfy In Abetract below end ln Text, IIRC Form 3664)TELEPHONE NUMBER Joseph R.Johnson'enior Specialist Regulatory Compliance AREA COOK 919362-2007 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)CAUSE SYSTEM COMPONENT MANUFAC TURER EPORTABLE TO NPROS CAUSE SYSTEM COMPONENT MANUFAC.TURER REPORTABLE TO NPRDS ,M v v'LR SUPPLEMENTAL REPORT EXPECTED (14)YES Ilf yer, cemplete EXPECTED SIIEIyiISSIDII DA TEI ABSTRACT IL!mlt to f400 rpecee, I.e., approximately fifteen elnple apace typervrinen lined (18)EXPECTED SUBMISSION DATE (15)MONTH DAY YEAR ABSTRACT'n November 2, 1987, at 1400, while the plant was in Mode 5, the Waste Processing Building Vent Stack 5A Wide Range Gas Monitor (WRGM), 81WV"3547"1, (EIIS:IL)was declared inoperable under Technical Specification 3.3.3.11, Radioactive Gaseous Effluent Monitoring Instrumentation.

This was due to a potential loss of sample flow caused by calibration of the stack flow transmitter and iso-kinetic sampling skid.At that time, it vas not recognized that the calibration would also make the monitor inoperable under Technical Specification 3.3.3.6, Accident Monitoring Instrumentation.

This determination was not made by Operations personnel until December 18, 1987.Efforts to return the monitor to service within 7 days vere unsuccessfu1, and a special report should have been written within 14 days as requi(d by Technical Specifications 3.3.3.6, Action C.Because of the late declaration of inoperability under Technical.

Specification 3.3.3.6, this special 2~port was not submitted within the specified time period.The delay in submitting the Corrective action included Inopexable Record (EIR), which aT)d tor maintaining cognizance 8801220204'801l8 PDR ADOCK 05000400 NRC Form 388 S.=,.D CD (943)special report was caused by personne')yor.

a revision to procedure OMM-003, Eq tipmet.t will provide better guidance for tracking ElRs of time requirements tt r LCps, gp 7 7 r~e Iy

NRC Perm 3&SA$4)3)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR AECULATORY COMMISSION APPAOVKO OMS NO.3150&)04 EXPIRES I 8/31/88 PACILITY NAMK ll)OOCXET NUMBER ll)LKR NUMBER 15)PACK (31 Shearon Harris Nuclear Power Plant Unit 1 TEXT//P IINVP 4PSC~/4 IPSU)aK USA ISA/Cna/HRC

%%dNII 38143/()3)DESCRIPTION:

0 5 0 0 0 4 P 0 YEAR@j 8 7 SEOUSNTIAL

'EUI4KVISION NUM 44~SP NUMSE4 06 4-00 P 20F 0 3 On November 2, 1987, at 1400, the Waste Processing Building Vent Stack 5A Wide Range Gas Monitor (WRGM}, glWV-3547-1, (EIIS:IL)was declared inoperable per Technical Specification 3.3.3.11, Radioactive Gaseous Effluent Monitoring Instrumentation.

This was due to the potential loss of sample flow.that could be caused by calibration of the stack flow transmitter and iso-kinetic sampling skid.Since the plant was in Mode 5 at the time, the shift Foreman that reviewed the Equipment Inoperable Record (EIR}did not recognize that inoperability of the Stack 5A WRGM could require entry into Action Statements of two different Technical Specifications'.

3.3.3.11 in all modes, and 3.3.3.6 in Modes 1, 2, and 3.On November 5, 1987, at 2238, the plant entered Mode 3, and Technical Specification 3.3.3.6 became applicable, although this had still not been recognized at this time.Technical Specification 3.3.3.6, Action C, required a special report to be written to the NRC if the monitor was not returned to service within 7 days.The plant experienced unexpected problems during the calibration of the stack flow meter and iso-kinetic sampling skid, and the monitor was not declared operable until December 23, 1987.Since the LCO action requirements specified on EIRs are used to ensure that the required actions are implemented within the required.time limits, and since an LCO against Technical Specification 3.3.3.6 requirements was not identified, the need for the special report was not recognized until December 18, 1987.The special report, which was due on November 19, 1987, was not submitted until January 4, 1988.Consequently, a noncompliance with Technical Specification 3.3.3.6, Action C, resulted since this special report was not submitted within 14 days.The failure to declare the WRGM inoperable per Technical Specification 3.3.3.6, and the subsequent failure to submit'he special report was discovered during a review of outstanding EIRs.The monitor was declared inoperable per Technical, Specification 3.3.3.6 at 1500 on December 18, 1987.CAUSE.'he failure to declare the monitor inoperable per Technical Specification 3.3.3.6, and to submit the special report within the required time frame resulted from personnel errors.The first error occurred on November 2, 1987, when the Operations Shift Foreman failed to recognize the potential applicability of two different Technical Spec'fications., Since the plant was in Mode 5, Technical Specification 3.3.3.6 was not applicable at that time, and there was no requirement to prepare an EIR declaring the WRGM inoperable per that Technical NRC POIIM 344A (84)31*U.S.OPO:)988 0424 538/4&5 0 I NRC Sons 388A (983(LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REOULATORY COMMISSION APPROVEO OMS NO.3(50M(04 EXPIRES: 8/31/88 SACILITY NAME (ll OOCKET NUMBER (3(LER NVMSER (el PACE (3I.Shearon Harris Nuclear Power Plant Unit 1 TEXT////Isso O>>co/4/ooo/RRE I/44 oANorW//RC Sons 38843/I(T)CAUSE: (continued) o s o o o 40 0 87 SEOVENTIAL NVMOER 0 6 4 REVISION NVMOER 0003 oF 0 3 Specification.

However, a"tracking EIR" should have been prepared to alert personnel to the inoperability of this monitor prior to entering Mode 3.Plant procedure OMM-003, Equipment Inoperable Record, did not adequately cover tracking an EIR in a situation such as this.Additional personnel errors occurred as on coming Shift Foremen reviewed the status of EIRs in effect between November 2, 1987 and December 18, 1987, and failed to recognize the requirement for a"tracking EIR," prior to Mode 3, or an active EIR after the plant had entered Mode 3.On November 5, 1987, at 2238, the plant entered Mode 3.The Operations Shift Foreman is required to review all LCOs prior to changing modes to verify that all Technical Specification requirements are met.Another error o'ccurred here in that the Shift Foreman failed to recognize the applicability of Technical Specification 3.3.3.6.ANALYSIS OF EVENT: This event was reportable due to a noncompliance with Technical Specification 3.3.3.6, Action-C, which required a special report to be submitted to the NRC within 14 days.Failure to'submft the special're'port within.the TequiTed/time period had no safety consequences.

The compensatory actions required by Technical Specification 3.3.3.11, Table 3.3-13, Actions 46, 47, and 49 required an auxiliary sampler to be hooked up to continuously monitor the stack while the installed monitor was inoperable.

This sampler was installed at the purge air inlet connection for the iso-kinetic sampling skid, and was in place the entire time the monitor was inoperable.

All compensatory measures for gaseous effluent and accident monitoring for Stack SA vere satisfied.

There have been no previous events similar to this.CORRECTIVE ACTIONS: 1.The WRGM was restored to service on December 23, 1987.2.The event/'as reviewed by all operating shift personnel during shift turnover meetings.3.Plant procedure OMM-003, Equipment Inoperable Record, is being revised to provide better guidance for tracking EIRs and for maintaining cognizance of time requirements for LCOs.N/IC SORM 344A (983 l R U.S.OPO:198bOb34 538/465 Carolina Power h Light Company HARRIS NUCLEAR PROJECT P.O.Box 165 New Hill, NC 27562 File Number.'HF/10-13510C Letter Number.'H0-880007 (0)U.ST Nuclear Regulatory Commission ATTN: NRC Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO.50-400 LICENSE NO.NPF"63 LICENSEE EVENT REPORT 87-064-00 Gentlemen.'n accordance with Title 10 to the Code of Federal Regulations, the enclosed Licensee Event Report is submitted.

This report fulfills the requirement for a written report within thirty (30)days of a reportable occurrence and is in accordance with the format set forth in NUREG-1022, September, 1983;Very truly yours, RAW:dj Enclosure R.A.Watson Vice President Harris Nuclear Project cc: Dr.J.Nelson Grace (NRC-RII)Mr.B.Buckley (NRR)Mr.G.Maxwell (NRC-SHNPP)MEM/H0-8800070/1/OS1